A draft of this position paper was circulated ahead of a licensee working group meeting held on November 26, 2025. Following input from the workshop, this updated draft is being circulated for further feedback from wider energy data stakeholders. 

Open Energy members hope that all RIIO-2 licensees, and the users of their data, will benefit from a clearly-articulated position on Open Data classification and access control. They would particularly welcome feedback from licensees who use third-party data platforms.

The Google version of the position paper is open to comments. Alternatively, interested parties may download a Word version. 

Please send comments or feedback to openenergy@ib1.org before February 2, 2026.

Key points from the position paper

RIIO-2 licensees that are members of Open Energy will:

• Adopt and enact an updated Assured Open Data definition that includes purposes for registration:

• D1.5.3 Anonymous downloads of open data is strongly preferred, but where the dataset requires compulsory registration before download:
  • D1.5.3.1 Registration is only conditional on completion of a lightweight challenge necessary for technical measures to minimise spam and bot abuse, such as verifying receipt of an email
  • D1.5.3.2 Acceptance of registration is automatic and immediate
  • D1.5.3.3 Registration may only be denied or withdrawn for misuse
  • D1.5.3.4 The registration process does not introduce any barriers to automated downloads or API access. Access to data is identical in all respects to a simple HTTP download of a published URL or API, except for the addition of a static credential or token that does not need renewing
  • D1.5.3.5 Require additional opt-in consent to use registration data for any further purpose. Data access must not be made conditional on obtaining any additional consents (e.g. use of registration data for analytics)
  • D1.5.3.6 If registration is only available via a third party platform (Data Controller), the third party must also comply with conditions D1.5.3.1 – D 1.5.3.5
  • D1.5.3.7 Third parties must transparently provide privacy policies and terms and conditions to the user if/where these differ from those of the Data Publisher.

• Apply the definition to metadata and data, meaning either or both may require registration
• Classify data requiring this form of registration as Open
• Licence data requiring this form of registration with either CC-BY-4.0 or OGLv3
• Implement information on registration forms/access gating screens making clear the purpose of this form of registration to end users and work with other licensees to align this language
• As required for compliance with UK GDPR, ensure privacy policies correctly reflect the use and protection of registration data, the length of time the data will be held, the situations where it would be disclosed
• Ensure terms of service for data portals do not contradict the Open Data licence being asserted for datasets on the portals
• Provide information in the registration process and/or the dataset listings that clearly separates Open Data “lightweight” registration from Shared Data registration requirements where registration may be used for other purposes, including limitations on access or use of the data
• Use registration as an opportunity, on a strictly opt-in basis, to provide additional benefits to users such as subscription to dataset update notifications or notifications of training opportunities

• The scheme agreement [pdf, Google Doc for comment]
• The assurance levels:
  • Organisation assurance [specification]
  • Dataset assurance [specification]
  • Both specifications are also available in a Google Doc for comment

Please comment directly on the Google Docs if you are able, or email feedback to openenergy@ib1.org. Comments received before June 2 2025 will be considered for inclusion in the initial scheme implementation.

Background

Open Energy is proposing to add an Assured Open Data scheme to the Energy Sector Trust Framework (ESTF). The scheme has these main aims:

• Provide assurance to consumers of Open Data published by Members
• Enhance the quality, consistency, and reliability of published data
• Ensure Members comply with relevant data protection, privacy, and security regulations (e.g. members don’t publish any data subject to data protection regulations such as GDPR as Open Data under the scheme)
• Promote transparency and accountability within the data-sharing ecosystem.

The scheme incorporates updated organisational and dataset assurance levels based on feedback on the original levels that Icebreaker One announced in September 2023. These levels are already being used, for example by Open Energy members SSEN-D on their data portal.

Joining the scheme will be free to ESTF members. In order to assert the assurance levels members must execute the scheme agreement that sets out their commitments, and liabilities should they fail to meet them.

A particularly interesting update for those of us aiming to improve interoperability and accelerate data sharing was the specification of Dublin Core as the minimum metadata standard, with a requirement for it to be implemented within 12 months i.e. August 6, 2024.

Decision on updates to Data Best Practice Guidance and Digitalisation Strategy and Action Plan Guidance

3.35. 71% of respondents approved of the proposal to mandate Dublin Core as a common Metadata standard, with an additional 21% approving but with queries or caveats. When asked for alternative suggestions for a common standard, the only option considered was DCAT, a variant of Dublin Core.
3.36. We have considered this, weighing its merits against the established and tested nature of Dublin Core, and the international and multi-sector uptake of Dublin Core as a standard, and have decided to mandate Dublin Core as the Metadata standard.

In our response to the consultation that led to Ofgem’s update we advocated for the standard to be DCAT, a refined and extended version of Dublin Core that is widely supported by data catalogue software, and in the form of DCAT-AP is the primary format in the EU for government data catalogues and the organisations that report into them.

DCAT and CKAN are mostly 1:1 compatible with the 15 Common Fields in the Dublin Core but there are some gaps. DCAT doesn’t include the coverage, date and subject fields, and the standard CKAN DCAT plugin doesn’t import or export the creator, contributor and relation fields.

Icebreaker One has searched for definitive guidance for mapping these gaps between DC and DCAT (these mappings are called “crosswalks”). We didn’t find anything that answered the question once-and-for-all, but there are some clues.

• The Research Data Alliance built a crosswalk into schema.org from various standards, including DC and DCAT. The data behind this is in a CSV on the RDA GitHub. By seeing how they think DC and DCAT should map to schema.org, we can infer what a mapping between the two would mean.

• The EU is putting a lot of effort into this at the moment under the European Open Science Cloud (EOSC) initiative. Specifically a report on interoperability that proposes a lingua-franca for metadata in Appendix I, and the work to establish a crosswalk registry between standards, which is still in the requirements-gathering stage. We’re looking forward to this work reaching determinations that will help drive universal crosswalk standards.

In the absence of clear external standards, we have developed a proposed mapping – see below.

We would welcome feedback on this. You can leave comments directly in the document.