Please note that throughout this consultation, Icebreaker One uses the terms Open, Shared and Closed data as defined here.

If you have any questions about our submission or require clarifications please do not hesitate to contact us via policy@ib1.org. We have omitted questions which we did not answer. 

Call for input response

Prioritisation of sectors and use cases

Through IB1 programmes and years of expertise, IB1 supports following a use case approach to data sharing initiatives. This approach centres user needs, makes a business case for the investment in data sharing, and allows for:

1. Market incentives: there must be an economic argument that policy can then amplify or mandate. If there is no financial incentive, there will be no movement.
2. Removal of transactional friction: There must be “something in it” for everyone, or at least a path to cost reduction or a new business model. Removing friction can help everyone go together: this is never solely a ‘technology problem’ (e.g. absence of a data ontology).
3. Documentation with the identified problem statement, actors and stakeholders, a clear goal, and the envisaged impact. 

Smart Data becomes effective when it is connected

In terms of prioritisation of sector, use cases requiring cross-sector interoperability and cohesion offer the greatest immediate ability to create impact, with a manageable degree of complexity involved in rollout. These use cases support private sector growth and require achievable government intervention, allowing green growth and environmental goals to be met.

User and customer needs should be identified through a robust governance process which can understand, process, and define use cases with relevant stakeholders. In IB1’s Scheme governance (standard operating procedures), IB1 emphasises the importance of having a user needs & impact advisory group which explores, prioritises, and works through use cases (including identifying users, their needs, and mapping data value chains). This process allows for the development of business, value, and impact cases and their impact on policy, businesses, and financial instruments. 

To maximise the benefits, use cases must:

• Address governance, user needs, business, social, legal, engagement and communications to ensure the solution is fit for purpose, and can be adopted by the market. IB1 observes that technical-led programmes tend to fail to gain traction or deliver against material user needs.
• Foster a community to ensure there is cross-sector collaboration. IB1 strongly recommends taking a joined up approach which is interoperable with initiatives across the economy. IB1 suggests defining relationships with adjacent bodies in the sector and beyond to enable cross sector interoperability.

For identified energy use cases, see IB1’s response to DESNZ energy smart data scheme call for evidence question 14. 

The interplay between industry and government progress in developing schemes or regulations, and how to encourage fast progress

It is important that progress toward sharing data is incentivised before waiting for one perfect data sharing solution to be built as there is demand for data immediately. 

For example, in the near-term it is unlikely that the energy data sharing infrastructure (DSI) will be suitable for all use cases, as it is currently unclear when and how non-regulated actors will be able to access data via the DSI, for what purposes, and under what assigned roles. These actors constitute major customers for connections data (e.g. heavy industry, retail, local authorities etc). While they may well be users of the DSI in future, opportunities to service these data customers in a secure, structured and well-governed manner must not be put on hold until the DSI is ready. 

As there is demand by non-regulated users for data now, there would be benefits to developing high-impact schemes in the short term that operate autonomously, but are legally and technically structured to facilitate integration with future common data sharing infrastructure. It is essential that as the government makes progress on developing schemes and regulations that they do not block valuable industry initiatives from being established quickly.

The coordination layer

To enable valuable government and industry schemes to progress quickly in parallel while remaining coherent and interoperable, IB1 strongly recommends intentional coordination of the cross-programme rules, standards, credentials and access controls that make data flow possible at scale. We recommend that responsibility for the coordination layer sits in an independent mission-locked entity that holds – or subcontracts – the sector’s Trust Framework and provides the sector’s neutral data coordination function. While different ownership options exist, industry co-ownership and co-Directorship of such a body provides a meaningful route for ensuring stakeholder buy-in and co-funding, akin to the model of Open Banking Ltd.

A neutral data coordination function must consider:

• How will schemes’ governing bodies coordinate with developments within and beyond their own scope? 
• How will this feed into goals, design choices, and definition of technical/architectural parameters? 
• How might this need to evolve over time? For example, sectoral coordination laddering up to cross-sector.
• How might Scheme development interact with overarching sector and national data/digitalisation strategies?
• How can Schemes encourage competition, markets and service creation within and across boundaries?

The coordination function requires a Secretariat to act as a neutral facilitator for participatory governance processes which can adapt flexibly to evolving coordination needs and ensure accountability. This requires:

• Strong governance processes – e.g. covering participant selection, means of input, minuting, reporting, and decision-making
  • Ability to offer tailored mechanisms where required – e.g. working groups to focus on specific sectors or data flows, or task-and-finish groups to support elements of data strategy delivery.
  • Flexible staffing, with ability to take on additional domain specialists/contractors as necessary
• Experienced administrators to execute governance processes and communicate expectations of timescales, plans, key decisions etc.
• Where required, the provision of independent chairing or facilitation services
• Dispute resolution processes, linked to existing sector mechanisms and to individual Scheme governance processes where relevant.
• Participant accountability mechanisms 
• Commitment to open publishing as a default approach (unless there is strong reason to do otherwise) 

It is vital for the coordination body to be fully independent; it cannot be nested in a body with pre-existing market functions without risking conflict of interest or transparency problems. 

Effective coordination should also be supported by monitoring in two key areas:

• Mapping of the domain(s) in which coordination is enacted in order to support effective participatory governance in an ongoing manner
• Monitoring and reporting on the outcomes of coordination activity to improve transparency and join-up with adjacent policy/regulatory goals
  • Where relevant, this may additionally include monitoring the delivery of a sector’s data strategy / roadmap.

We suggest that the above activities would require a small permanent staff to ensure continuity of process and expertise, with additional needs met via subcontracting and secondment on a time-limited basis for agile response to emergent needs (e.g. particular technical or domain expertise concerning a coordination challenge). This lightweight approach delivers the intended benefits at a reasonable cost to the bill or tax payer, supporting the general principle of minimisation outlined earlier in this response.

Finally, we propose that any enforcement powers for the coordinator can be most readily delivered via existing regulatory and legislative capabilities. This reduces cost and risk of establishing new statutory bodies.

Best practice in scheme design, including for vulnerable and other consumers, and to maximise how well the system works for services that use data from more than one sector

A core centralised capability must be the design principles. Critically, aligning on design principles for governance will lead to greater cohesion and interoperability of outcomes. 

Governance processes should collaboratively agree upon:

• The intent to work toward interoperability and working in widely understood formats. 
• Licence compatibility – creation of preemptive multilateral contracts/agreements, including appropriate permissioning where required
• Human- and machine-readable representations of scheme rules
• Adoption of common open web standards as the default (unless insufficient) to allow for widest possible number of technologists to understand
• Open publication of new specifications (legal, procedural and technical) that may be adopted by other schemes to aid interoperability
• The use of consistent tooling that is well understood by stakeholders
• Appropriate proven security standards
• The use of open source 
• Conceptual alignment on what metadata means (better yet  – technical compatibility), and aligning around standards

Within this governance function, there must be adequate consideration of the amount of communications and time needed to convene, design, implement and develop consumer messaging for schemes.

To enable interoperability, IB1 recommends considering how Schemes will interact. Key aspects of this are:

Identity. IB1 suggests this should not be a centralised identity, but a mechanism which can enable cross scheme identity verification. This is a key area of research with further needs around how a federated identity system may work. IB1 is exploring this within Perseus, to enable an identity interaction with Open Banking’s identity establishment. 

Access, licensing and permissions. There is a need to invest in research into this, as uncertainty in rights to access, use, combine, sell or share data is a drag on innovation and introduces unnecessary cost. Different regulatory environments can lead to additional confusion for cross-sector data use. There is potential to develop permissioning and purpose representations that can be understood readily by data users and their customers, but interpreted at scale by machines.

Assurance: Schemes need to address the assurance needs of data users in order to deliver value. Considerations include provenance, quality, processes, auditability, liability and redress. Protections for scheme participants (companies) and the customers they serve must be clear. A common language and machine-readable representation for these aspects of data sharing enables confident use of data and accelerates adoption.

Potential cross-sector innovation support, or data or regulatory sandbox services, and how they are designed 

IB1 recommends investment in common tooling to develop public digital infrastructure and open source support which can be re-used across schemes. 

There is a potential role for the National Data Library to curate common standards for scheme rules and their representations and convene the working groups that define them.

The places and methods through which competition should be enabled or promoted in the smart data system, and the pros and cons involved

Scheme development will be a part of the public digital infrastructure development, with appropriate governance oversight to avoid anticompetitive practices, and to guard against cartels to ensure it is a fair place to do business. IB1 thinks of this as “collaborate on the [data sharing] rules, compete on the [services] game.” It is part of the governance process to delineate what is considered pre-competitive and to have short term targeted projects (e.g. mapping stakeholders who must be consulted when developing a specific area of pre-competitive activity).

IB1 also recommends to include value-mapping guidance in the handbook (recommended approaches to do it for a scheme) and to identify and caution against perverse incentives.

Underlying trust services (for example identity, verification, compliance monitoring, permission management, version-controlled registries of scheme rules) must have open standards, ideally with Open Source reference implementations. Scheme operators should have a competitive market of trust service providers to choose from, whose services comply with these standards. The aim is to create a market that operates along the same lines as the HTTP web standard and web hosting providers. 

Methods and forums for engagement with those outside government and join-up between sector-level and cross-sector developments (such as the guidebook)

• Opportunity to capitalise on existing data sharing governance forums:
  • Perseus
  • Open Energy 
  • Stream
  • https://ib1.org/sops/governance-schemes/
• Any coordinating entity must be accountable to its stakeholders. We suggest this is supported by the following:
  • Openness policies enabling scrutiny (e.g. of methodologies, processes, minutes, reports)
  • Where required (for security purposes), clear rules defining how scrutiny will be undertaken among closed audiences
  • Defined process for dispute resolution integrated with existing sector mechanisms
  • Clear processes for change management
  • Defined avenues for external involvement in participatory processes
• Wider engagement than just the incumbents and/or regulated entities within a sector (e.g. in the energy sector this must include actors beyond the roles licensed by Ofgem)
• Cross sector convening needs to be around coherent use cases with a wide range of stakeholders representing the different roles and stakeholders within the data value chain

Join-up between smart data and other data policy, and with international partners

There are developing debates in sectors such as energy and property as to what is considered under the realm of smart data, versus what is considered ‘system data’  There is potential for some issues emerging there and in other sectors which need to be considered and worked through with the relevant stakeholders. Definitions established under the Data Use and Access Act must be respected where relevant.

It is worth noting that not all data is smart data but will need to interact with other data which could/should be shared for key use cases. We caution against excluding ‘non-smart’ data stakeholders when convening around smart data and other data policy. 

Our most prominent international partner – the EU – has invested heavily in technical infrastructure via its Gaia-X initiative. Outcomes have been mixed, due in part to an apparent assumption that “if we build it they will come”. Recent work by the Data Spaces Support Centre on design principles and governance has the promise to encourage more use cases to be brought forward and be implemented. The UK should have a goal of alignment with EU developments on data spaces, but to aim for eventual harmonisation (as with the advice on interoperability within the UK above) as opposed to full technical interoperability at an early stage. As with all data sharing work, the use case is key here. If a use case requires interoperability with EU dataspaces, or interoperability drives very high value, then it is worth the investment to align and connect. Many use cases will not require this, at least in their initial phases.

Links between smart data and AI adoption and innovation, either within the Industrial Strategy sectors or more widely across the economy. 

AI is moving rapidly from performing tasks for people (“summarise this document in under 300 words”, “tell me the top considerations when buying a new fridge”) to performing tasks on behalf of people (“deploy this software”, “find and book a reasonably-priced vegetarian restaurant in Soho for me and 3 others next Thursday evening”). To perform these tasks, agents will need to access the instigator’s personal data, and to exercise delegated authority to act on their behalf. Both of these may implicate multiple providers, using data and access that the instigator didn’t foresee.

AI and smart data intersect in governance and assurance, enabling trust in AI operation by answering questions such as: 

• Where is personal data stored and processed, and to whose benefit?
• Where did the data the model is using come from? (Both for training and for retrieval-augmented generation)
• What personal data did the model use?
• How much reliance can the user put on the inference?
• How are permissions delegated to AI, and how are consumers protected?
• How does the agent ensure that personal information is protected under GDPR when shared?

Relevant materials

Please see other relevant IB1 call for evidence responses:

• DSIT’s Smart Data call for evidence
• DSIT’s Data intermediaries call for evidence
• DESNZ energy smart data scheme call for evidence
• IB1’s response to Ofgem’s Energy digitalisation governance: architectural coordination letter

General principles

Additional comments:

• Reusability: the methodology for exploring and getting Schemes off the ground can have generic/reusable items. But the Schemes themselves must have capacity for tailoring.
• Minimisation: Schemes should do the minimum possible that enables the use case to be addressed.

“There are 300,000 assets on the platform, but only 300 are I&C (Industrial & Commercial)… that’s 0.1% of assets delivering around 60% of capacity.” Yingyi Wang, Flexibility Commercial Manager at National Grid Electricity Distribution

Early on in our Open Energy webinar, panelist Yinghi Wang highlighted the outsized role I&C flexibility is already playing in the energy system. Despite representing a tiny fraction of total assets, I&C providers are delivering a significant share of flexibility capacity. Yet participation remains surprisingly low.

In fact, I&C flexibility fell from around 1.7GW in 2021 to just 0.8GW in 2023. At a time when the energy system needs greater flexibility to support electrification and renewable generation, participation appears to be moving in the wrong direction.

Part of the challenge lies in how businesses capture value from flexibility. In the move towards maximising implicit flexibility(where organisations adjust energy use in response to price signals) participation can be complex, requiring upfront investment in control systems and automation, internal resources, and operational change. For many organisations, uncertainty around long-term returns only adds to the perceived risk of participation.

Not one-size-fits-all

Another reason participation remains low is that flexibility cannot be approached in the same way across every organisation. When it comes to energy use, every organisation has a flexibility profile that’s shaped by its operations. A manufacturing site, a commercial building, and a data centre each have very different capabilities and constraints.

For industrial processes in particular, flexibility is not simply a matter of switching off or shifting demand. Doing so can have significant operational and commercial impacts. Add in changes to decarbonise a business – such as process electrification or installation of low carbon technologies – and the picture can become even more complex.

Data, the great enabler

Across the regulators, networks, suppliers, and trade bodies that joined our OE webinar, one view shared throughout was that data is the critical enabler of flexibility.

The energy sector is operating in an environment with limited visibility of available assets, inconsistent standards for data sharing and fragmented systems that do not easily interoperate. As a result, even where flexibility exists, it is difficult to identify, access, and integrate into markets.

This lack of visibility also impacts network planning, as discussed by Open Energy Co-chair, Sara Vaughan: “It is vitally important to have visibility of what assets are out there to support network planning. In order to achieve this, we need trusted data sharing.”

Without trusted and interoperable data sharing, scaling I&C flexibility will remain a challenge and Clean Power targets will suffer as a result.

Join Open energy

Open Energy plays a critical role in addressing these barriers by tackling one of the root causes behind slow flexibility adoption: fragmented and inconsistent data sharing. It also tackles the participation challenge by bringing together industry, networks, and market participants to co-design the rules and harmonise the standards needed to unlock I&C flexibility at scale.

‘What is absolutely key to enabling more I&C participation in flexibility markets is data. We need to ensure trusted data sharing that benefits the energy system and the customers who are participating… Open Energy has been working in this area for a number of years and, through the Perseus Scheme, Icebreaker One has already demonstrated proof of concept.’ Sara Vaughan, Co-chair of Open Energy

To find out more about the Industrial & Commercial Flexibility use case, or to join Open Energy, please get in touch with us at openenergy@ib1.org

Since the end of February, energy price volatility has been seen across multiple fuels, including oil and gas. And, while this volatility is being felt across the board, SMEs – which represent 99.85% of total business population and £2.8Tn in turnover – are being disproportionately exposed, particularly to sharp rises in gas prices.

For many SMEs, energy costs represent a meaningful share of operating expenses, particularly in sectors such as accommodation, retail, and food production. This leaves them more exposed to sudden price volatility, especially when access to tools and finance might be limited.

As costs rise, margins tighten and cash flow becomes less predictable, leading to increased uncertainty for both SMEs and lenders. For financial service providers – with over £68bn in SME lending portfolios – this shapes how risk is assessed and how capital is allocated.

At the same time, SMEs remain difficult to assess due to limited and inconsistent data. Rising uncertainty could push banks to tighten credit conditions across their portfolios, resulting in a feedback loop where SMEs face higher costs and reduced access to finance, while lenders carry greater uncertainty and risk.

Perseus provides a more complete view of energy costs

By expanding to include gas data, Perseus directly addresses this problem. In March 2026, the Perseus scheme began incorporating gas data, supporting calculations of Greenhouse Gas Protocol Scope 1 (direct) emissions alongside the Scope 2 (indirect) electricity emissions.

Moving beyond electricity to provide a more complete view of SME energy consumption and emissions gives SMEs better control over their energy exposure, while enabling banks to assess risk, verify impact, and finance the transition with greater confidence.

With this expansion, Perseus is estimated to have potential reach of over 1 million UK SMEs and cover over 70% of use cases, reflecting the scale of energy data across organisations.

For more on Perseus gas emissions methodology: https://ib1.org/perseus/emissions-calculations/ 

For SMEs, this means:

• reduced time, cost, and complexity of reporting
• a more complete and credible picture of energy use and emissions
• better access to finance and incentives
• potential for lower cost of borrowing

For banks and lenders, it enables:

• more accurate assessment of SME energy exposure
• improved risk pricing and credit decisions
• comparable, standardised data across portfolios
• the ability to develop targeted financing products linked to energy performance

Renewables over reliance

Reliance on fossil fuels remains a key driver of energy market volatility. It’s not an imagined scenario either, with Reuters recently reporting that wind output in Q1 2026 increased significantly year-on-year, helping to drive a ~16% drop in gas-fired generation. This cushioned the UK from the impacts of the gas price spike and contributed to relatively lower wholesale power prices versus some European peers. 

As more low-cost renewable electricity comes online, reliance on gas, and exposure to its volatility, can be reduced. This means the shift towards a cleaner renewable energy future is more than an environmental move but a financial one too, creating new opportunities for both SMEs and Financial Service Providers. 

While renewables can reduce our reliance on gas, flexibility determines how much of that value can actually be captured. For more on the impact I&C Flexibility can have on renewables take-up and the wider energy market, read our latest blog.

In the electricity market, this enables demand to respond to supply, a crucial shift as sectors move towards electrification and as electricity production shifts to cheaper, cleaner, but more intermittent, renewable sources.

Flexibility forms up a core part of the government’s Clean Power 2030 Action Plan and is explored in depth in the Clean Flexibility Roadmap. It also delivers clear value, from reducing system costs for networks to unlocking new revenue streams and resilience for energy users. But, realising its full potential and accelerating the transition to Net Zero requires market-wide adoption.

Benefits of I&C flexibility

For grid operators, enabling flexibility can deliver:

• Reduced generation curtailment
• Reduced need for expensive grid-scale energy storage projects
• Reduced costs for grid capacity upgrades
• Alignment with Ofgem’s forthcoming RIIO-ED3 price control

For I&C Consumers, benefits include:

• Lower energy costs
• New revenue streams
• Reduced expenditure on grid connection upgrades
• Increased resilience for key consumers, such as hospitals, in times of grid stress

Data is the common thread

And yet, I&C flexibility isn’t one-size-fits-all. It encompasses a spectrum of approaches from direct demand response (where consumption is increased or decreased for a set period) to more sophisticated coordination of co-located technologies like solar, battery storage, heat pumps, and EV fleets.

What connects these approaches is data. Granular, trusted data sharing enables I&C sites to assess what options are feasible and maximise the benefits of participating in flexibility markets. Electricity networks also need real-time, high-quality data to plan and operate their networks, and to balance supply and demand. Without this, take-up of I&C flexibility will not reach its full potential, or will be costly to implement.

Sharing large amounts of data between diverse groups or organisations can lead to challenges including:

• Varying data formats, standards and semantics
• Separate representations of network assets and constraints
• Different data publication schedules
• Non-interoperable licensing and permissioning frameworks
• Issues with machine-readability
• Commercial and security sensitivities
• A lack of easy consumer data portability
• Fragmented data on existing I&C flexibility participation and performance

For I&C consumers, these barriers make it harder to identify viable flexibility opportunities and build robust business cases. This increases cost and complexity, often diverting time and investment elsewhere.

Unlocking flexibility at the speed and scale required to decarbonise the grid will therefore require a fundamental shift in how data is shared.

A data sharing scheme to accelerate I&C flexibility

The market needs a way for I&C actors to securely and easily share data with authorised parties to assess, plan and deliver flexibility at scale. Open Energy’s mission is to collaboratively define and develop a data sharing Scheme to support this, recognising that delivery is a co-ordination challenge, requiring collaboration to solve.

No single organisation can solve this alone, and implementing technical solutions without understanding the needs, constraints, and capabilities of others risks becoming an expensive exercise with unreliable outcomes.

The scheme will align with wider energy and cross sector initiatives such as NESO Data Sharing Infrastructure, RECCo Consumer Consent Solution, Elexon Flexibility Market Asset Register, Market-Wide Half-Hourly Settlement, and Smart Data policy), strengthening the overall data ecosystem and enabling interoperability.

Open Energy brings together energy system and I&C participants to build the data foundations for accelerating flexibility. IB1 acts as a neutral facilitator and data governance expert supported by the Energy Sector Trust Framework, a ready-to-use mechanism for governing the exchange of data in a consistent, trusted, and scalable way, without the need for centralised infrastructure.

How your organisation can benefit

If flexibility impacts your organisation, whether as an opportunity, a challenge, or a dependency, being part of Open Energy gives you a seat at the table, where the future of data sharing is being built. You’ll also help shape how the Energy Sector Trust Framework evolves to meet the specific needs of the flexibility market.

For networks:

• Contribute to, and benefit from, sector-wide alignment on data classification, licensing, and access controls
• Reduce the risk of costly inconsistencies emerging as flexibility markets mature.

For flexibility providers and aggregators:

• Access cleaner, more consistent data pipelines
• Access a governance framework that makes it easier to operate across multiple network areas.

For large energy consumers and trade bodies:

• Gain faster visibility of viable flexibility opportunities and incentives
• Access insights to support adoption and decision-making

Join us & your peers

To find out more about the Industrial & Commercial Flexibility use case, or to join Open Energy, get in touch with us at openenergy@ib1.org

And register for our upcoming webinar: https://events.humanitix.com/oe-i-and-cflex-webinar

The decisions being made now will shape the direction of the energy sector for years to come. Those helping to shape it will be best placed to benefit from the opportunities that follow.

Carbon accounting is complex. The methodologies used to calculate emissions can vary significantly depending on carbon accountant, framework, or data source. And, while inconsistencies exist across all emissions factors, they are particularly problematic when it comes to Scope 3 emissions – the indirect emissions that occur across a company’s supply chain.

Scope 3 emissions typically represent the largest share of a company’s footprint – around 75% of total emissions on average. This, coupled with the voluntary nature of reporting for SMEs, means a significant gap exists in supply chain emissions reporting.

In short: the biggest share of emissions is the least reliable to measure.

There is also a distinct lack of harmonisation in approach. Current methods are often incomplete, inconsistent, and difficult to compare and data is collected in multiple formats, using different methodologies. This culminates in a fragmented landscape that burdens businesses with information that is rarely decision-useful.

Without reliable, comparable data:

• Businesses struggle to identify emissions hotspots and prioritise action
• Banks and corporates lack certainty around their supply chains when making financing decisions
• Governments and regulators face barriers to designing effective policy interventions because the underlying data is inconsistent or incomplete.

The importance of this high-quality carbon data is rapidly increasing too; becoming central to procurement decisions, taxation frameworks, cross-border adjustment mechanisms such as CBAM, and access to sustainable finance. And yet, the current data ecosystem is lagging behind this growing demand.

Transparent, unified and harmonised

CC was created to address this challenge. Instead of another competing standard, it will create a transparent, unified, and fit-for-purpose approach towards a harmonised methodology, and principles for calculating hybridised, system-complete, emissions factors.

If this can be accurately addressed, then the benefits could be far reaching, helping businesses manage supplier risk, tackle incoming regulatory pressures (TCFD, CSRD, CBAM, SECR), and allowing them to respond to stakeholder demands.

For SMEs, the impact could be particularly transformative. Through Perseus we’ve seen how reliable emissions data can help unlock access to sustainable finance. With its focus on Scope 3, CC could help SMEs streamline reporting requests from large customers, and provide a clearer pathway for them to participate in low-carbon supply chains.

Our approach

The solution to improving supply chain carbon accounting hinges on pre-competitive collaboration. CC facilitates this, alongside independent governance and oversight, ensuring outputs are practical, robust, comparable, and fit-for-purpose, while drawing on technical and academic expertise.

Membership

Joining CC offers organisations an opportunity to shape the future of supply chain emissions data. Benefits include:

• Helping shape a harmonised approach to emissions factors that is practical, scalable, and aligned with real-world business needs.
• Gaining early access to outputs (e.g. hybridised emissions factors) for integration into products, services, and reporting solutions.
• Staying ahead of regulatory change and influence alignment with standards, regulators, and policymakers.
• Gaining early insight into developments in carbon reporting, procurement requirements, and international mechanisms such as CBAM.
• Strengthening your organisation’s supply chain resilience and sustainability
• Supporting the creation of reliable, comparable data that enables better risk management and decision-making.

To find out more about membership and fees, reach out via cc@ib1.org

You can read the minutes of our latest Steering Group meeting here: https://ib1.org/2026/02/11/carbon-commons-steering-group-january-2026-minutes/

At the Perseus 2025 AGM it was reported that Perseus is:

• evolving from ‘financing green’ to embedded sustainable finance creating a potential addressable market of £5-10 billion
• adding gas, extending energy coverage from Scope 2 (electricity) to Scope 1
• estimated, via its existing members, to have potential reach of over 1 million UK SMEs and cover over 70% of use cases
• continuing to advance ‘Perseus Ready’ implementations with commercial members
• running a live sandbox (equivalent to production) for use by Carbon Accounting Providers (CAPs) and Energy Data Providers (EDPs) to develop solutions
• working with Perseus members to develop go-to-market capabilities to support hundreds of thousands of SMEs
• exploring integration with Open Banking to enable cross-sector interoperability
• producing XBRL outputs to enable integration with financial reporting systems
• pioneering the development of a voluntary, cross-sector Smart Data scheme, aligned with the UK Data Act and supported by an openly-licensed digital public infrastructure (DPI) architecture for secure data sharing 

“Perseus makes it easier for everyone to do their carbon calculations properly, and comfortably moves us years ahead of the most stringent proposed updates to the GHG Protocol. This is exactly why Sage intends to roll out a Perseus enabled product to make reporting easier for hundreds of thousands of UK SMEs.”

George Sandilands, Vice President, Sage Earth

From financing green to embedded sustainable finance

For much of the last decade, ‘green finance’ has focused on funding individual projects: a retrofit here, a solar installation there. Important, but limited. 

Perseus marks a shift to something far more systemic: it moves beyond financing green to embedding sustainable finance by integrating trusted, verifiable emissions data directly into everyday accounting and financial decision-making.

This evolution means Perseus can be applied across the whole SME market, not just specialist green products. Rather than expecting SMEs to seek out solutions themselves – something most lack the time or expertise to do – Perseus brings trusted insights to where they are (e.g. inside their existing accounting, banking and carbon applications). 

Perseus can support lending, credit and debit products, and even savings accounts, allowing sustainability performance to be reflected wherever financial decisions are made. The impact on SMEs is significant: personalised insights, lower reporting costs, easier access to capital for energy-efficiency upgrades, and new space for financial innovation. By making sustainability data usable at scale, Perseus aims to help turn ‘net zero’ from a niche ambition into a normal feature of how the economy works.

“As a leading smart data initiative, Perseus is developing guardrails for assurable data to support finance and supply chain decisions towards a sustainable economy.”

Hannah Gilbert, Director of Sustainability, British Business Bank

with Rohan Graham, Head of Asset Data, National Grid and Jay Chen, Data Process Administrator, IT&D Data Engineering and Process, NGED

Data sharing is key for reaching our net zero targets; this is something IB1’s strategic partner National Grid Electricity Distribution (NGED) has long recognised. And, as the company looks to cement its position as a digital leader in the energy industry, IB1 remains a key component and catalyst in accelerating its digitalisation journey. 

We caught up with Rohan Graham from National Grid and Jay Chen from NGED, to discuss how interoperability across Distribution Network Operators (DNOs) is fundamental to unlocking the potential of open data in the energy sector.

Building trusted open data

Last year, NGED identified a need to improve how it publishes assured open data. While the DNO had already established an open data portal, it wanted to review both what it was publishing and how it was publishing it. This shift signalled a commitment to providing data that is trusted, consistent and usable across the sector. 

“Our goal is to contribute to the broader movement of publishing interoperable assured open data, explore genuine shared-data use cases, and understand how to make that data available securely through trust frameworks, while considering and aligning to the DSI under development.” Rohan Graham. 

Sector-wide collaboration

NGED sits within a much wider ecosystem of UK DNOs, all of which publish similar datasets. Because these datasets are used across the energy sector, (not just within each DNO’s own business) ensuring their interoperability is essential.

To achieve the level of interoperability required and to build sector-wide collaboration, harmonisation is essential. Once in place, the value of this interoperability is far-reaching: it strengthens trust, encourages the wider use of data across the sector and ultimately accelerates the entire sector’s digital maturity. 

“Over the next 3-5 years, we’ll see the increase of interoperability of data between organisations as well as the increasing use of flexibility services across multiple DNOs.” Jay Chen, NGED. 

Data Action

The Data (Use and Access) Act might also be a catalyst for positive change in the sector. Its focus on the roll-out of smart data schemes is a move in the right direction. But, whether this alone will galvanise the sector toward a more connected, net-zero future remains to be seen.

“It’s definitely a positive move. It’s set up some of the frameworks for how Open Energy can be pushed forward, but really, the Act alone won’t create immediate change. Specific to Open Energy, the real push comes from facilitation by Icebreaker One, a common purpose and active participation from members of the ecosystem.” 

Rohan Graham, National Grid

IB1: The great facilitator 

Through our Open Energy programme, IB1 has helped to establish best practices for publishing open data; focusing on machine readability, standardised metadata and overall consistency; all of which help to facilitate trust across the sector. 

“Working with IB1 has been really valuable in providing awareness, guidance, and direction, mainly from an open data perspective, so far. One of the biggest benefits has been driving the collaboration between the DNOs through steering and working groups. This kind of collaboration is crucial for progressing interoperability and shared best practices”. Rohan Graham.

“Our strategic partnership enables NGED to have a driving seat in shaping the future of decarbonisation through working groups with sector organisations, facilitated by IB1.”

Jay Chen, NGED

What’s next?

Looking ahead, National Grid is set to continue its progress toward a more connected, digital energy system. Central to achieving this vision is the ability to continue identifying datasets that truly move the dial on flexible energy markets and decarbonisation.

“Understanding who needs that data, why they need it, and how to deliver it securely and at scale will be key. The sector needs to  remain focused on publishing what truly drives progress toward net zero – whether that’s open or shared data.” Rohan Graham. 

IB1’s work in Open Energy is creating a connected web of energy data – making it more discoverable, interoperable, and impactful, in the collective mission to reach net zero.

If you’re interested in becoming a Strategic Partner, an Open Energy member, or part of our expert network, you can join us at ib1.org/join or reach out at partners@ib1.org to start a conversation about unlocking data for net zero.

So what’s the difference?

Standardisation is rooted in uniformity and harmonisation in compatibility. Depending on the situation, either can offer advantages to unlocking the effective use of data. To unpack this further: 

Data standardisation is the process of bringing data into a uniform format to ensure consistency and comparability. There is a choice of bases on which standardisation may be applied. In a previous post, we identified 13, ranging from file formats to governance.

Data harmonisation is about making disparate data sets interoperable. It’s crucial when dealing with multiple datasets with varied standards as it brings these diverse data sources together into a coherent, usable whole. 

To illustrate the difference, let’s take the example of car. The way fuel for cars is refined and distributed is standardised: petrol from any supplier is expected to work in any ordinary petrol engine. By contrast, a car’s interior controls are harmonised: every car must have a way to steer, accelerate and brake but there is no single layout for how those controls are arranged.

Why harmonisation matters: lessons from TNFD

Applying this to our recent work supporting the Taskforce on Nature-related Financial Disclosures (TNFD), we can see why harmonisation is often essential. TNFD asked us to help develop their global data strategy and a set of principles for nature data. Early on, it became clear that nature data could not be reduced to a single standard because it spans water, soil, species, forests, and many other systems, each with its own metrics and methodologies. 

In a fragmented landscape like this, harmonisation serves as the connective tissue. It allows decision-makers to interpret nature-related risks, opportunities, and impacts through a more integrated view.

The benefits of harmonisation

Improved Decision-Making: Harmonised datasets offer a broader, richer, but still integrated view, enabling better-informed choices, particularly when decisions draw from multiple data sources.

Reduced Friction: Organisations can continue using the tools, formats, and definitions that work for them, while still contributing to an interoperable system.

Faster Collaboration: Harmonisation enables a shift from ‘agreeing on one way of doing things’ to ‘doing one thing well’, encouraging a focused, practical use-driven approach that drives alignment.

Why harmonisation fits IB1’s approach

These benefits are what makes harmonisation a natural fit for IB1’s use-case driven approach. In our Open Energy work, as we explore effective data-sharing use cases for the energy sector, we’re facilitating cross-sector collaboration with Distribution Network Operators (DNOs), regulators, and other stakeholders in the sector. Each has its own definitions, terminology, and internal standards. So how do they all agree on a common language? 

The answer is, they don’t, and they don’t need to. Expecting them to adopt one common language is unrealistic, time consuming and unnecessary. This would be a standardisation-first approach. Useful in some contexts, but often slow, costly, and difficult to achieve at scale. Instead, the approach is to pick a real-world use case and harmonise our approach across multiple stakeholders and data sets. Use cases give our working groups a practical focal point, allowing collaboration to form around specific needs. 

“We prefer to harmonise through utilisation and application rather than theorise and wait for a standard to be implemented”

Gavin Starks, CEO, IB1 at the Open Energy webinar. 

So when does standardisation have a part to play? 

Standardisation creates stability and comparability where consistent reporting is essential. For instance, this was the recommended approach in our Impact Investing report for COP28, where we advised organisations to require data-backed, standardised environmental reporting from their supply chains. This is crucial for decarbonisation and for accurate Scope 3 emissions reporting because stakeholders, consumers, investors and employees increasingly expect businesses to provide a full and trustworthy account of their value-chain emissions. 

Data standardisation, in this context, is the right way to go because it establishes a common baseline that ensures everyone is measuring and reporting emissions in the same way, enabling meaningful comparisons, credible disclosure, and targeted action.

Ultimately, harmonisation and standardisation both have roles to play. But, often in our work we encounter multi-stakeholder projects, with disparate data sets that require a harmonised solution. By grounding decisions in real use cases we’re able to find cross-sector solutions to real-world problems.

We are pleased to announce that IB1 will be supporting The Retail Energy Code Company (RECCo) in the design and development of Ofgem’s  policy position to implement a Consumer Consent Solution (CCS). 

The CCS is a secure, digital solution that empowers energy consumers to control who can access their energy data. It enables people to easily grant, manage, review, and revoke consent. This supports transparency, consumer choice, and strong data protection across the retail energy market. 

IB1’s Role

IB1 will provide expert advisory support, assisting in the design of the Trust Framework that underpins the CCS. This framework will be central to ensuring that the service is reliable, transparent, trusted and usable by both consumers and market participants.

We will leverage our extensive experience in designing, developing, and advising on Trust Frameworks, Consent and Permission, and in cross-sector stakeholder engagement to deliver market-scale solutions. 

In particular we will bring learnings from the Perseus project, which enables SMEs to securely share emissions data with banks, calculated from their metered energy consumption, in a permission-based framework.

Sharing data with consumer or business consent is at the core of the smart data economy heralded by the Data (Use and Access) Act 2025. We are delighted to be working on a key initial focus of the Act, and intend for our learnings to be repurposed across sectors to help achieve legal, policy and technical alignment.

The responsible use of LLMs includes understanding their energy use and the net zero implications associated with them. Both LLM model creation and usage are known to use a significant amount of energy and so this guide includes considerations for reducing energy consumption in LLM usage.

Consistent with our commitment to transparency, we have built upon the excellent work of mySociety’s AI Framework to produce a practical guide for internal use. We are publishing it so partners can understand our approach, adapt it for their own contexts, and engage with us where collaboration would be helpful. The guide addresses how to use LLMs responsibly as research tools while maintaining rigorous oversight and expert review.

Written by Paul Johnston

Read our full Guide to Using LLM’s here

Access TNFD’s full report here

What does good nature data look like?

Working across multidisciplinary stakeholder teams, we identified seven key principles for high-quality nature datasets, acknowledging that nature data should be:

• Transparent and reproducible
• Credible
• Accurate and complete
• Relevant and decision-useful
• Accessible and usable
• Legal, ethical, privacy protecting
• Networked and compatible

Our Process

TNFD provided a roadmap of use cases, which we used as a foundation to work from. From this, our user-needs led approach helped define who the data users were as we developed a set of recommendations and principles that could lay the groundwork for nature data that supports financial decision-making.

“The Taskforce is very clear that its focus and contribution is on addressing use cases specific to corporations and financial institutions”

TNFD: A roadmap for upgrading market access to decision-useful nature-related data

Findings from the pilot testing of proposed nature data principles:

After evaluating 40 existing datasets against these principles, we confirmed that none fully met the standards required for global reporting or investment use. This exposed a critical gap for the financial sector: the absence of reliable, comparable, and standardised nature data needed to direct capital toward nature-positive outcomes.

“We tested 40 datasets against robust criteria for decision-useful nature data and found that none of them fully met the principles required for global reporting and investment needs.” Lewis Just, Lead Researcher

Understanding the barriers of nature-based data

A key reason for this gap lies in the complexity of nature data. Unlike carbon, which can be measured through a single metric such as tonnes of CO₂, nature spans many interconnected systems including water, soil, species, forests, and many more. Each uses different metrics, standards, and methods of measurement, making it extremely difficult to compare results across regions, sectors, or reporting frameworks.

Without harmonisation, financial institutions face a fragmented landscape where nature-related risks are hard to identify or value, and progress toward biodiversity goals is difficult to measure.

IB1’s approach brings structure and clarity to this complexity: developing guiding principles to support better quality, comparable, and decision-ready nature data that can help direct financial flows toward positive environmental outcomes.

Nature loss isn’t just an environmental issue, it’s an economic one

“Reducing nature data barriers is key to enabling effective nature-related reporting and accelerating action to halt and reverse nature loss.” (TNFD)

The impact of nature-related financial risk is widespread and financial institutions currently lack the data needed to measure and manage their nature-related financial risks. For instance, UK Banks could avoid potential losses of 4–5 % of loan-book value if they’re able to anticipate and price risks more accurately. For governments, making nature risk visible could help to avert $2.7 trillion annual GDP loss by 2030.

To unlock the power of nature data and positively shift financial investment, we need better access to high-quality, trustworthy nature data. But access alone isn’t enough, how that data is shared and governed is equally important.

Balancing openness with responsible governance

At first glance, it seems there’s a simple solution: make all nature data open and accessible, right? Unfortunately, it’s not that simple. And, in fact, not all data should be open.

For instance, sharing the precise locations of endangered species could make them more vulnerable to poaching. For example, GPS tracking data intended to help conserve rhinos could be exploited by poachers to locate the animals. Similarly, satellite-derived coral reef maps — created to support conservation — could be misused by developers and industrial fishing fleets to identify and exploit those same ecosystems.

That’s why responsible governance is crucial. Data providers must retain control and ownership over their datasets to prevent misuse and ensure that data serves its intended purpose: protecting and restoring nature.

NOVA (Networked, Open, Verifiable Architecture)

Our NOVA principles were developed to guide us to outcomes that are interoperable, scalable, and aligned with existing standards, ensuring that data can be shared and used responsibly.

Applied through the lens of nature data, this means that sensitive information, such as species locations, is only accessible to those granted explicit permission, safeguarding wildlife while still enabling actionable insights for conservation and investment.

COP30 Brazil

IB1’s principles and recommendations for this project were formed to help TNFD understand what good nature data looks like, so that financial flows can shift towards investments that help, not harm, the planet.

With COP30 in Brazil now underway, the spotlight turns to a country that holds some of the world’s richest biodiversity and largest nature datasets. At its launch event in São Paulo on Thursday, November 6th, TNFD published its recommendations for upgrading the nature data value chain for market participants. This included a blueprint to govern, launch, operate and finance a Nature Data Public Facility (NDPF).

Sara Vaughan, Co-chair of the Open Energy Steering group, framed the start of the session by pointing to a lack of alignment in the sector which might be hindering progress. At the same time, she highlighted what sets Open Energy apart from other initiatives: the involvement from regulators, who are brought into the process to support and provide continued feedback.

This collaborative approach sits at the heart of Open Energy, as it brings the sector together to co-design the rulebook for data sharing and develop Trust Frameworks that unlock the value of energy data.

The data sharing landscape

As we progressed through the webinar, Chris Pointon, Product Manager, Trust Services, reflected on what Open Energy can build upon as it evolves. Themes included wider governance areas such as assurance, common identity services, and shared data infrastructure. Key to exploring these themes are actionable use cases. These give us a tangible grasp on user needs, and allow us to develop solutions that accurately address industry and consumer pain points.

Harmonisation over Standardisation

The focus on workable use cases also made up a large part of discussion in the Q&A segment and helped attendees to understand why harmonisation, not standardisation, is needed to guide the sector forward.

“While data standardisation focuses on uniformity, data harmonisation is about making disparate data sets interoperable”

Michael Glass, Data Governance and Information Manager at SSE posed a critical question:

“DNOs all have different internal definitions and languages that they use. How do they agree on a common language?”

The answer is to pick a use case that is supported by working groups and centre collaboration around it. By starting from real-world use cases, we can reduce cost and friction for everyone.

“That’s how we harmonise. Psychologically and operationally, it’s a much easier approach.” Gavin Starks, CEO, IB1.

The results are in

Towards the end of the webinar we conducted a poll asking our participants questions such as: ‘Which of these barriers affects your confidence’ to better understand whether uncertainty around data licensing, data access, data maturity, legal risk or alignment with the rest of the sector is holding them back.

Uncertainty about alignment with the rest of the sector made up a large portion of the vote, and echoed our previous discussions on the need for harmonisation.

What’s next?

We’re at a critical moment in the UK’s history around data sharing. Government departments now have significant budgets dedicated to designing smart data schemes, signalling real momentum.

But amidst this progress, we need a coordinated effort to ensure we navigate towards the low-cost, low-friction future we’ve all set out to achieve – one where collaboration across the sector shapes the future of trusted energy data sharing in the UK and beyond.

Looking ahead, we’re encouraging continued discussion through upcoming Open Energy Working Groups. The first session will take place on Wednesday 26 November, and will aim to develop a single, DNO-backed approach to align on the language and decisions discussed during the webinar.

Whilst the form is now closed, you can still join by emailing partners@ib1.org

SME decarbonisation depends on better data

Accurate Scope 2 emissions data—the indirect emissions from purchased electricity—sit at the heart of SME decarbonisation and green financing decisions. But most Scope 2 calculations rely on crude annual accounting that masks the reality of how electricity grids actually work.

What’s more, electricity demand and renewable generation don’t align neatly across a calendar year – they shift hour by hour. An SME might be using an energy tariff that’s marketed as “100% renewable” on an annual basis while consuming fossil fuel power during winter evenings when solar isn’t generating. That gap matters for real decarbonisation, and it matters for lenders assessing genuine progress toward Net Zero.

Making clean power visible

Matched Energy is an independent, not-for-profit energy transparency initiative. It analyses publicly available data using a peer-reviewed methodology to calculate how well renewable supply aligns with consumption on a half-hourly basis—the finest granularity supported by UK electricity settlement systems.

Their groundbreaking Clean Power Index published on October 27th, puts vital information in the hands of consumers. The index underscores the need for regulatory reform of the existing opaque rules that allow suppliers to make misleading “100% renewable” marketing claims.

This level of precision transforms Scope 2 accounting from an annual figure into something actionable: SMEs can see when they’re actually getting clean power, and lenders can assess the physical reality behind carbon claims.

Open Energy & Perseus

Open Energy is creating a connected web of energy data while Perseus is automating sustainability reporting for UK SMEs in order to unlock access to green finance. At its core, Perseus makes it easy to share accurate, assurable emissions data that sits behind carbon calculations—enabling better analysis, action and impact.

Through this collaboration half-hourly renewable matching data will be integrated with carbon accounting platforms and other interested parties across the ecosystem. It will enable SMEs and their stakeholders to access more granular, assurable data about electricity consumption and its true carbon intensity.

By connecting Matched Energy’s temporal analysis to Perseus’s data infrastructure, we’re creating pathways for carbon accountants, lenders, and corporate energy buyers to make better-informed decisions based on the physical reality of the grid.

“The result of this collaboration is more reliable emissions reporting, better decarbonisation decisions, and stronger foundations for green finance. The data infrastructure already exists—what’s needed is the connection between the systems that hold it. Open Energy is building that connection and we’re pleased to have Matched Energy as part of that effort”. Gavin Starks, CEO, IB1

Wellcome has now published the workshop summary report, Realising the potential of a National Data Library, which highlights key insights and recommendations from participants.

Our contribution to the report drew on our use-case–driven approach to delivering data infrastructure for net zero. This perspective was reflected in the final publication:

“Defining a strong vision for the NDL is necessary not only for intended users and the public but also to inform its design. “A clear vision is a necessary design constraint” for the NDL, state Hardinges and colleagues. They recommend documenting the vision as a “clear, tightly-bound problem statement. This will help bridge the chasm between a high-level political vision and technical execution.” Similarities can be drawn from the development of Open Banking in the UK, where the public were consulted about the problem they wanted addressed with their banking before the financial data innovation was designed.”

Realising the potential of a national data library: The Wellcome Trust

Read the full report here

In December last year, Perseus entered its pilot stage which was launched to gather feedback on the technical, legal and user experience aspects of Perseus. As part of the Pilot, the Development Bank of Wales used Perseus in its due diligence processes for green business loan products.

Today, Perseus has progressed to the launch of the sandbox, which will allow Perseus members to safely and easily experiment with sharing energy consumption data.

How it works

The sandbox uses synthetic energy consumption data, meaning organisations can test and experiment without concerns over personal data. It also provides identical trust services (Registry and Directory) to Perseus in production.  

“Successful integration with the sandbox will make a business ‘Perseus-Ready’ – a sign that they are ready to provide the innovative new services enabled by automated carbon emissions reporting between data providers, businesses, carbon accounting platforms and lenders”.

Chris Pointon, Project Manager, Trust Services.

What does being ‘Perseus-ready’ mean for your business?

For Carbon Accounting Providers:

• First choice for Financial Service Providers seeking market-scale data powered by Perseus.
• First to market with Perseus-enabled products 
• Major visibility to all participating Perseus banks
• On-ramp to real-world case studies, leading to wider sector visibility 
• Prepare your teams, technology and processes to strengthen your competitive advantage
• Opportunity to launch a new revenue stream, and develop new tech capabilities for your business

For Financial Service Providers:

• Test technical processes for ingesting Perseus data 
• Inform product innovation, reporting and compliance
• Build relationships and technical partnerships with potential data partners for new sustainable finance opportunities
• Develop new tech capabilities to build scalable access to sustainability data ecosystem

If your organisation is interested in using the sandbox and becoming ‘Perseus-ready,’ please get in touch via Perseus@ib1.org

Perseus will automate access to assurable SME electricity smart meter data and its carbon intensity at the time and place of use. SMEs will be able to receive emissions reports generated from these data and share them, via reporting solutions, with banks or lenders to unlock green finance.

As described in the 2024 Plan, Perseus members have been working throughout the year to uncover and explore the needs of all stakeholders in the data flow and convert these into concrete actions. These have driven detailed work on legal, technical and user experience design, assurability and process development to enable an operational pilot.

Purpose of the pilot

June marked the end of the six-month pilot phase of Perseus, which was launched to gather feedback on the technical, legal and user experience aspects of Perseus. Part of an iterative process, the pilot focused on reducing friction and enhancing the way Perseus works for SMEs, energy data providers (EDPs), carbon accounting providers (CAPs) and financial service providers (FSPs). 

What did we do?

• Tested the technical, legal and contractual elements of the trust framework.
• Explored whether the onboarding documents were sufficient and useful to organisations joining the Perseus scheme. 
• Checked the assured data flow of electricity consumption and derived emissions between participants.
• Tested the user journey flow, design, product integration and legal agreements with a CAP, an EDP and a FSP. 

How did we do it?

The testing was conducted on a one-to-one basis with participants, and feedback was gathered during calls and/or shared via email.

What did we learn?

Several important lessons emerged:

• SME UX: The overall Perseus user journey could be improved through the addition of simple but effective elements, such as a progress bar, providing the user with support and guidance throughout their Perseus journey. 

• Clarity about who hosts what: Greater clarity is required on which stages of the Perseus journey are hosted by the EDP, the CAP and the FSP and to what extent the host can brand and integrate the Perseus journey stages.     

• Engagement: attempts to engage FSPs during the pilot were not as successful as expected. This was mainly due to key stakeholders’ own constraints, needing to focus on other internal projects and not being able to put their own SME clients forward for user testing. To address this, we reached out to other stakeholders in the wider ecosystem to understand their barriers to participation and engagement and how to overcome these.      

• Onboarding support and guidance: During the pilot we discovered that organisations had more questions when onboarding that we had anticipated. We have since updated the supporting documentation and produced clearer step-by-step guidance, with “readiness” checklists.

• Cloud providers: Members whose servers are hosted by cloud providers had difficulty using private server certificates. We have now modified the technical requirements to enable them to use the same public certificate authorities as they would for any website or web service.

• Liability and data retention: Members’ legal and compliance teams were comfortable joining the pilot because both the pilot agreement and associated data retention requirements were limited to the term of the pilot. This will inform timeframe considerations for production.

• Green Lending Market: An observation from testing the pilot is that the green lending market is not as active as we anticipated for SMEs seeking green loans. However, we anticipate this will evolve as the market develops and more incentives are introduced.

• Trust and clarity: The clarity of definition that the scheme provided proved vital in helping different actors understand their roles and responsibilities.

• Case studies: A lack of engagement equaled a lack of real-life Perseus case studies from participants. As a result, IB1 increased its efforts to conduct stakeholder interviews, focusing on how stakeholders perceive their role and value within Perseus, and how IB1 can support them in becoming early adopters that other organisations can learn from.

• Support and discussion channels: Support channels proved to be a challenge with some organisations finding it hard to use Slack. To provide more opportunities for focussed discussion, we introduced more targeted and frequent working group sessions, with shorter advisory group meetings tasked with decision-making rather than detailed discussion.

• Language: Insight from the pilot emphasised that the language used to describe Perseus needs to be kept simple and appeal to different users. There is a responsibility to encourage SMEs to adopt green finance to help the financial sector deliver net zero and to support CAPs in easily calculating assurable emissions data.

Next steps

Perseus has now progressed to the ‘sandbox’ stage of the project; which officially launched on Monday 29th September. The Sandbox provides identical trust services (Registry and Directory) to Perseus in production, and includes a reference EDP that provides synthetic smart meter consumption data. It can safely be used for development and testing. 

Learnings from the pilot phase have been incorporated into the onboarding documentation. Perseus members are receiving one-to-one support and guidance through the sandbox and are encouraged to showcase their case studies.

The 2025 Perseus Report will be launched at the end of this year and will provide more detail on the Pilot, Sandbox and launch phases.

We spoke with Pierre Tabet, Founder and CEO of Voltview, about how the company began, the growing role of smart data schemes like Perseus, and Voltview’s contribution as part of the Perseus technical advisory group. We also explored how banks, eager for more accurate data to strengthen their ESG reporting, are likely to see Perseus as a critical enabler.

Ross: How did Voltview begin? 

Pierre: So, I started Voltview just over two years ago. I’d always been interested in the energy sector, having previously worked as a back-end engineer for an energy management company. When I moved back to the UK, I knew I wanted to stay in that field.

At the time, I began speaking to business owners who were unknowingly in the middle of the energy crisis. Many were still on fixed contracts, but when their renewals came up, their bills more than doubled. Hospitality businesses were hit especially hard because of their high energy consumption. For example, one fish and chip shop I spoke with saw annual bills jump from around £10,000 to £35,000. That kind of increase can threaten the viability of a business.

We saw huge pressure on SMEs, and I realised that’s where Voltview should focus. Early on, I had conversations with Smart DCC, who pointed me towards a government grant for smart tariff comparison in the non-domestic sector. Now, we just missed out on getting that grant, but we were still interested in the space. And from there we pivoted slightly.

Rather than just offering comparisons, we wanted to combine switching with retrofits, so businesses could save on tariffs and reduce consumption. Think of it like Booking.com: when you book a flight, they also suggest hotels, car hire, or insurance. But in energy switching, businesses never get offered solutions like heat pumps, EVs, or electrification measures, even though the data used for switching could easily support those recommendations. With reforms like market-wide half-hourly settlement, that data is more valuable than ever. It felt wasteful for switching to end with just a new tariff, when it could instead trigger bigger energy and cost-saving changes.

Ross: This makes a lot of sense to me. Especially now, what with rising energy costs. It reminds me of Open banking and how it opened up consumer choice. How do you ensure the data accuracy and transparency when you’ve got these tariff comparisons? 

Pierre: Open banking is a great comparison as it allows you to share financial data with authorised third parties, who then provide tailored services. As I’m sure you know, the government now wants to replicate that model in energy, having passed the Data Use and Access Act. 

This is especially relevant in the commercial sector- currently about 80% of UK commercial buildings aren’t compliant with the EPC B rating required by 2030. Non-compliance could mean fines. To address this, businesses need access not just to energy data but also building data, credit scores, financial history, everything required to prioritise and fund retrofits.

What’s really cool now is, a lot of the administrative work which took up a lot of energy consultants’ time, can now be done with AI, so that they’re only working on sort of the high value work.

Ross: That’s really interesting. How exactly can EPC data be linked to financial impact? Is there a link to green mortgages here, in a similar vein to SME emissions data being linked to green finance with Perseus? 

Pierre: Absolutely. Perseus is a great example and we’ve been lucky to contribute on the technical side. It provides a trusted way to share Scope 2 emissions data with banks, who in turn reward businesses with lower interest rates.

The bigger picture here is increasing electrification. In the UK, only about a quarter of energy use is electricity, compared to roughly half in Norway. To close that gap, we need incentives  like cheaper capital for retrofits, particularly for SMEs. Many owners are busy running their businesses, so making retrofits easy is critical to driving uptake.

Ross: And so you’ve got EPC data, half-hourly meter data, and financial data – how hard is it to bring all that together on one platform?

Pierre: It is challenging. Only about 60% of UK business meters are smart compared with roughly 95%+ in some European countries, so many firms are effectively flying blind. The first hurdle is getting half-hourly data; the second is aligning it with building and financial data. We start with specific use cases and design the simplest possible customer journey around them.

Ross: Very cool. And as you mentioned, the Data Use and Access Act should hopefully accelerate this work and smart data schemes like Perseus. I also saw on your website that your clients save 17% on energy bills. Can you share an example of this?

Pierre: Sure. Savings usually come from two areas: matching clients with tariffs that suit their load profiles, and cutting waste. One example was a restaurant kitchen where the ventilation system was switching on at night. The owners had no idea until we flagged it with half-hourly data alerts. Fixing that single issue accounted for about a third of their total savings. So really the savings are already in the data- you just need the right tools to uncover them.

Ross: Let’s dig into Perseus a bit more. How have you found being involved in its development?

Pierre: It’s been a great experience. We’re part of the technical advisory group, which has focused on making Perseus trustworthy, scalable, and incredibly easy for users. Ultimately, it’ll be as simple as ticking one box. In December, when Perseus trialled the process manually, it gave us confidence in how it can work at scale. We’re now about six months away from real-world rollout, and we’re excited to integrate it into our ecosystem.

Ross: And what would that integration look like for Voltview?

Pierre: It might not sit directly on our platform. We may simply guide clients to enable it through their accounting software. The point is that all our customers gain access to cheaper capital for retrofits, regardless of where they switch it on.

Ross: Do you think financial institutions are ready to adopt Perseus and scale up green finance for SMEs?

Pierre: Increasingly yes, the real bottleneck is data quality not intent. Almost half of FTSE 100 companies have had to restate climate metrics every year, mostly due to emissions in their suppliers. Banks and lenders want more reliable data to strengthen their own ESG reporting and sustainability-linked products. Perseus helps by providing verifiable upstream data so there is less estimation, fewer restatements and more confidence to deploy capital.

Ross: Great. To wrap up, what’s next for Voltview?

Pierre: We are nearing the end of the Smart Data Challenge funded by the Department for Business and Trade. The challenge has been to incorporate more cross-sector data into our platform. Our next step is to launch use cases that almost any SME can tap into by sharing their energy, building and financial data. We will announce these later this October as we complete the Smart Data Challenge.

The report explores the opportunities and challenges of sharing data across UK National Infrastructure Systems, with a particular focus on energy, water, and transport. Icebreaker One was proud to contribute to this crucial piece of work, undertaking a landscaping exercise to assess the current state of the art in data sharing in energy, water and transport infrastructure, particularly in regard to the support of research, with a focus on gathering evidence from the private and government sectors.

Read the full report here

You can find our landscape analysis on national infrastructure data sharing with researchers, which contributed to the above report, here

Will Goodhart, started his new role as Executive Director of the Future of Sustainable Data Alliance (FoSDA) towards the end of April this year, following 18 years as Chief Executive at the CFA Society of the UK.

We caught up with Will to hear his perspective on the next phase of sustainable finance – where sustainability is set to become embedded in every financial decision – and to discuss the role of data, the evolving regulatory landscape and what the recent Data Act means for businesses and consumers.  

Ross: Will, you spent nearly two decades at the CFA, much of it focusing on sustainability. What brought you to FoSDA?

Will: For the last 5 to 10 of those years at the CFA, we had a focus on sustainable investing and educating people on how to invest sustainably. So we developed the CFA certificate in ESG investing, now called the CFA Certificate Sustainable Investing. Following this, we developed a certificate in climate and investing and the certificate for impact investing at the beginning of 2024. 

I wanted to apply my experience more directly – helping people use their skills and knowledge to advance sustainable finance. So, joining FoSDA felt like a natural fit because of my understanding of the market, the connections I had and the potential FoSDA has as an organisation. It has an important role to play in empowering financial markets to tackle environmental and social challenges through the provision of high-quality, comprehensive data.

Ross: So, what are the barriers to making the market for sustainable data work?

Will: I think improving the consistency, comprehensiveness, and interoperability of data are key. As well as highlighting the value of data and demonstrating the importance of a competitive market in the provision of sustainable data and sustainable analytics.

Of course, FoSDA is not here to solve everything ourselves, but also to convene stakeholders and support the ecosystem. 

There are still data gaps out there to work on. For example, real estate data can be fragmented across markets. And even with nature and biodiversity data, which has grown significantly thanks to geospatial analysis and AI, we need to ensure the methodologies are transparent and robust.

Ross: That point on nature data is interesting – it feels like a fast-growing but complex space?

Will: Yes, someone recently called nature data a “jungle” and I think that’s a bit extreme but still apt. There’s tremendous innovation and growth in biodiversity and nature-related indicators, but understanding how that data is derived and making sure the market for nature data functions properly is crucial. 

Ross: I think it’s also finding that link to impact as well. 

Will: Yes, one of the problems with that nature and impact is knowing your baseline. Getting a baseline for nature is quite challenging. To know that you’re creating impact, you have to know what the situation was beforehand and then be able to measure it in the same way after to see if there has been any positive impact. 

Ross: Do you think, as sustainability becomes more embedded in finance, that FoSDA’s work will become easier?

Will: We’re entering a new phase where sustainability is becoming part of every financial decision and that naturally creates pushback from those invested in the old ways. But the integration of sustainability indicators into policy, regulation and standard-setting will intensify, because the challenges are no longer in the distance, they are here, now. That makes it critical to ensure regulations are targeted, proportional, and effective. 

Ross: I wanted to get your thoughts on the Data (Use and Access) Act and how this might influence FoSDA’s work?

One positive is that it may change how people think about data – not just as an asset for producers but as something that should benefit consumers more directly. Like with Open Banking, it could open up markets, give consumers more choice, and spark a wider conversation about governance and value sharing.

I think the more that it happens, now that there’s a common framework for it, the more people expect that they should be able to share their data with others in situations where it’s going to be beneficial to them. 

Ross: The Data Act also touches on Artificial Intelligence (AI) and how this is being used to analyse data and automate decision making. What are your thoughts on this?

Will: We see a lot of claims of AI-powered models analysing unstructured data to deliver sustainability insights. And while the technology is exciting, it needs to be used appropriately. Consumers of AI-generated data should question its provenance and understand the processes behind it.

Ross: And finally Will, what’s next for FoSDA?

Will: A key priority is making standardisation and machine-readability fundamental to financial reporting and systems, so data can flow seamlessly and effectively. We’re looking forward to working with others to frame that problem and drive progress.