With a twist of the throttle (in off-road mode) it will do 19mph under the right conditions.The EAPC regulations specifically state that to qualify as an electric assist pedal cycle and be exempt from motor vehicle legislation the bike must not be able to assist above 15 mph. There is an assumption by some of a 10 % tolerance, meanig around 17 mph absolute maximum, and the DfT may have indicated that, but that is not stated in law.
Since yours doesn't assist above 15 mph anyway, you seem to be safe in either mode.
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Normal Mode: Pedelec ~11-13mph Throttle ~13-15mph
Off-road Mode: Pedelec ~13-15mph Throttle ~15-19mph