It's an interesting question. Do they have the power of a regulation? Perhaps not. It's interesting because section 93 of this act goes on to say that instructions are not subject to the Statutory Instruments Act, which deals with regulations.
I think it's a question the courts are going to have to answer: what is the power of these instructions? From a practical standpoint, they will have the same effect as regulations. But they haven't gone through the process that you and I would expect with respect to regulatory changes.