The Press Complaints Commission wants us to think it has renewed itself. That it is no longer the feeble outfit that was derided for doing nothing about the McCann scandal and thinking everything was fine at the News of the World. It has new people in charge, it has carried out a governance review and its code of conduct for journalists is being revised. It’s also Tweeting to draw attention to how proactive it is.

So, is the investigation it has just announced into last month’s Daily Telegraph sting against the Liberal Democrats evidence of a new assertiveness? There’s a hint in their press release that they want us to think so, where they say: “The PCC was contacted by around 200 members of the public on this subject, and proactively sought the comments of party representatives.” That word “proactive” again: it is code for “we don’t just sit here waiting for complaints to come to us”.

Now they have received a formal complaint from the Lib Dem president, Tim Farron, alleging that the Telegraph breached the PCC editors’ code rules on use of subterfuge, and in consequence have launched their investigation.

It will be an interesting case. You might argue that the Telegraph uncovered something that was in the public interest in Vince Cable’s remarks (to reporters posing as constituents) about the Murdoch media. But then you have to note that the Telegraph, for reasons of its own, didn’t actually intend to publish that story.

The real issue, however, is likely to be this: before they visited the MPs’ surgeries, and before they turned on their hidden recorders, did the Telegraph journalists have an idea of what they were going to hear? Did they have reason to believe, for example, that Cable would tell them what he told them? If not, then they were merely fishing, and in the past the PCC has taken the view that newspapers are not justified in lying to law-abiding people and secretly recording them just to see what they might get out of it.

It is obviously a big case for the PCC. A finding against the Telegraph will be unpopular in the industry that pays the PCC’s bills and would doubtless be presented as bad for journalistic freedom. A finding that absolves the Telegraph will be unpopular with MPs, who already believe the PCC is wimpish and toothless.  It’s good to see this tackled, and we watch with interest.

But to come back to the opening point: does the launching of this investigation reveal a new and assertive PCC? Maybe it’s a good sign, but it’s not convincing. The Commission’s rules allow it to investigate an issue of concern on its own authority, without waiting for — or soliciting, or negotiating — a complaint from anyone, victim or otherwise. It doesn’t do that, and it hasn’t done it here.

It has been proactive in only a limited sense since in the end the authority and initiative for the investigation have been carefully located with the LibDems. Maybe that’s appropriate in this case, but it means this can’t be described as a real flexing of muscles by a reformed PCC. It’s complaints processing — what they always did.

Until we see it being seriously proactive, elbowing its way into difficult areas of public concern and showing initiative and authority, the PCC’s claim to the role of serious industry regulator and its claim that it upholds standards in anything more than an indirect and intangible way will remain weak.

Brian Cathcart is professor of journalism at Kingston University London, he tweets @BrianCathcart