Thanks to Everyman.
I also found it on the difficult side (stalled out for a while mid-solve), overall high level of cluing.
FOI 2, LOI 17.
COD is 21 because of misdirection. Also liked 23, 11, 22, 16d, 4, 8, 12 and 9.
A few less than stellar clues: 25, 15 and 3 were really easy and I don't love 24, though on reflection they're all OK.