On June 17, we’re hosting a use case accelerator workshop, exploring the user needs, market barriers, and data landscape shaping a new data sharing Scheme designed to scale Industrial & Commercial (I&C) flexibility across the energy sector.

The event features a networking lunch, short presentations, facilitated breakout sessions and Q&A discussions with participants invited to:

• Critically test the initial use case definition produced by Icebreaker One
• Explore user needs of different actors across use case (e.g. business case, value case, data needs)
• Define key roles and responsibilities within the use case
• Explore the data landscape surrounding I&C flexibility and the data needs of Scheme users
• Facilitate connections and network building

Attendees will leave with:

• A clearer understanding of the Scheme’s purpose, scope, and direction
• Practical insight into how their organisation can shape and participate in the Scheme
• Access to a growing network of stakeholders driving innovation in I&C flexibility

Outputs will be used to shape the agenda for Scheme advisory groups (Q3 2026 launch) and define the scope of an initial Pilot (early 2027 launch).

Participation from I&C energy consumers, I&C trade bodies, energy networks, energy suppliers, flexibility service providers, aggregators, and innovators are particularly welcomed.

A shared data scheme to accelerate I&C Flexibility

Open Energy is facilitating the collaborative development of a data sharing Scheme to accelerate Industrial and Commercial (I&C) participation in consumer led flexibility. It responds to a clear, under-served market need for I&C actors to be able to easily and securely exchange data between authorised parties for the purpose of assessing, planning, and implementing flexibility.

The potential benefits are significant; helping businesses unlock new value, supporting a more flexible and resilient energy system, and contributing to the UK’s Clean Power 2030 ambitions.

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.

Date: Thursday 7 May 2026 14:30-16:00 BST

Location: In person & online

Co-Chairs: Sara Vaughan & Gavin Starks

Secretariat: IB1

Meeting Aims: 

1. Events updates: feedback from webinar and details on next events
2. Discuss coordination of sector digitalisation
3. Update on roadmap quarterly milestones

Summary:

• It was agreed that:
  • The next Steering Group meeting will take place on 2 July 2026, and it will serve as the next working forum for the SPV discussions.
• It was noted that:
  • There has been progress since February 2026 on the industrial and commercial flexibility use case, including the delivery of a well-attended webinar.
  • The webinar covered the market need for a data-sharing scheme, the wider smart data landscape, and the challenges and opportunities for industrial and commercial participants.
  • A call was put out for two advisory groups: User needs and impact and technical implementation.
  • The wider context is rapidly evolving, with significant policy, regulatory and market developments shaping the environment for data sharing and digitalisation.
    • These include the joint Ofgem-DESNZ digitalisation vision, the March 2026 Smart Data Strategy, work on reformed national pricing, and the outcomes of the Ofgem review.
  • Architecture work is under way, with NESO leading development of an emerging baseline view in collaboration with domain coordinators, but that this is not yet a settled or complete architecture.
  • The Open Banking model was referenced as a possible example of how an SPV structure might work.
• It was discussed that:
  • There is a risk of fragmentation and lack of alignment across multiple parallel initiatives if governance, standards, consent and data access approaches are not adequately coordinated.
  • The proposed digitalisation coordination function is an important but still developing part of the landscape, and as a result its role, authority and practical operation remain uncertain.
  • There is a central question around whether Open Energy should operate in future through an independent nonprofit SPV structure, though no conclusion was reached.
  • If Open Energy were to play a future role, it is important to define where it could add value. Potential areas of value could include standards coordination, stewardship of shared semantic approaches, neutral convening between industry and regulators, Trust Framework implementation without holding data, and cross-sector coordination.

Next meeting: Thursday 2 July 2026 14:30-16:00 BST

Formal records, including attendees, are maintained by the secretariat. 

These are confidential to the Steering Group Members.

“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

Please note that throughout this response, 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 evidence response:

1. What energy problem do you want to solve? 

There is a wide range of energy use cases identified and highlighted in IB1’s response to DESNZ’s Developing an energy smart data scheme: call for evidence (question 14). There are core principles IB1 recommends embedding. 

Smart Data becomes effective for use in AI and in decision making 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. 

Regardless of use case, codify a requirement to contribute to net zero

As mentioned in IB1 response to Ofgem’s AI in the energy sector guidance consultation, we acknowledge and appreciate Ofgem’s commitment to encouraging innovation while helping the UK to meet its net zero target and other associated targets. As mentioned in the IB1’s May 2024 AI consultation response, IB1 recommends that the developing AI governance landscape codifies a requirement for AI use in the energy sector to demonstrably contribute to the UK’s net zero targets and for this requirement to be open to monitoring and audit. Without codification of this principle there is a risk that AI systems are established to optimise non-environmental goals, while creating negative environmental impacts. 

IB1 acknowledges the risk of AI systems generating increases in energy and water demand. Both the impacts and the demand profile of AI use should be subject to scrutiny and appropriately governed to ensure they contribute meaningfully to the UK’s net zero targets.

2. What kind of data is needed? 

All identified IB1 use cases, detailing the value, kind, potential users, and scale of the required data, are outlined here: https://ib1.org/energy/reports/ 

3. What work is needed to create or enable a useable dataset, including making sure it can be easily combined with other datasets? 

IB1 observes that this list concentrates on technical barriers to data use, but fails to highlight legal, licensing and commercial considerations. It is very possible that cost, usage and IP conditions will hamper otherwise technically possible uses of the data. We recommend early surfacing of this information to mitigate five risks: 

1. Regulatory and compliance complexity: Data licensing must align with compliance rules around grid data, market data, and critical infrastructure. It is important to ensure data inputs to AI systems, and the outputs of the AI, remain compliant.
2. Third-party data dependencies AI models in energy often rely on weather feeds, satellite imagery, market pricing, and sensor data from multiple vendors. Each source carries its own licensing terms around permitted use, commercial exploitation, and AI training rights. Identifying these dependencies early prevents data supply chain disruptions during development, or worse, after deployment.
3. Intellectual property and model ownership: Who owns the AI model trained on licensed data? Many data providers now include clauses that restrict or claim rights over derivative works, including trained models.
4. Onward data publishing and monetisation: Energy sector companies typically want to share or sell AI-derived insights. Licensing terms set upstream can block valuable downstream opportunities. 
5. Long-term data access and continuity risk: Many foreseeable AI systems in the energy sector (e.g. predictive maintenance, load forecasting) need consistent, long-term data access. Identifying long-term data rights is critical to operational resilience.

Governance to enable usable datasets which can be combined with other datasets 

As mentioned in IB1 response to Ofgem’s AI in the energy sector guidance consultation IB1 encourages cross-sector collaboration and learning wherever possible. We recommend engaging with cross sector (i.e. water, transportation, local authorities, etc) and working with citizen advocacy groups to learn from best practices, ensure guidance is consistent for cross sector use cases (hydrogen, electric vehicles, electrifying public transport, etc), and understands the impact of AI guidance on different socio-economic stakeholder groups.

As described in IB1’s AI positioning statement, IB1 supports a hybrid governance model, combining robust oversight with decentralised data sharing, including smart contracts and digital identity solutions

AI must be designed to mitigate bias and discrimination, ensuring fair access to economic opportunities, financial services, and public resources. We support governance which is co-designed through processes which are adequately representative of different stakeholders or stakeholder groups, ensuring that the approach is collective rather than ‘done to’ from the top down.

To mitigate risks and enable data sharing at scale for AI use, the industry must consider more than just the dataset. For an identified use case, it needs to collectively determine:

• User needs & impact: commercial priorities, business cases, and prospective new products and services to be unlocked.
• Technical infrastructure: shared ontologies, APIs, schemas and standards to support data exchange. 
• Licensing & legal: data sharing agreements, modes of redress and liability frameworks.
• Engagement & communications: common language, stakeholder engagement and recruitment.
• Policy: alignment with corporate policy and industry regulations.

At IB1 we do this through a robust governance process and Icebreaking to drive groups of organisations to make the critical decisions required to exchange data with one another.

4. Who would the users of the dataset be? 

All identified IB1 use cases, detailing the value, kind, potential users, and scale of the required data, are outlined here: https://ib1.org/energy/reports/ 

5. What scale does the dataset need to be? 

All identified IB1 use cases, detailing the value, kind, potential users, and scale of the required data, are outlined here: https://ib1.org/energy/reports/ 

6. What would enabling AI use of this dataset unlock? 

All identified IB1 use cases, detailing the value, kind, potential users, and scale of the required data, are outlined here: https://ib1.org/energy/reports/ 

7. What would be the arrangements for ongoing maintenance, governance and curation of the dataset? 

As noted in IB1’s response to Ofgem’s AI in the energy sector guidance consultation: 

IB1 encourages cross-sector collaboration and learning wherever possible. IB1 recommends engaging with cross sector (i.e. water, transportation, local authorities, etc) and working with citizen advocacy groups to learn from best practices, ensure guidance is consistent for cross sector use cases (hydrogen, electric vehicles, electrifying public transport, etc), and understands the impact of AI guidance on different socio-economic stakeholder groups.

AI must be designed to mitigate bias and discrimination, ensuring fair access to economic opportunities, financial services, and public resources. IB1 advocates strongly for AI governance to integrate with developments in data governance, both within the energy sector and in the cross-economic space (e.g. Smart Data Roadmap, approaches to consent or permission). 

IB1 believes it is important for data governance to establish principles, structures, roles and responsibilities, agreed upon by market participants, that enable auditable, accurate and timely data sharing at a market-wide scale. As mentioned in the IB1’s May 2024 AI consultation response, IB1 recommends that the data ecosystem, and integration with the data governance landscape be acknowledged.

IB1 notes that in training a model it is highly likely that training datasets will contain sensitive data (it is also possible to use only anonymised data within a training dataset to retain privacy in the model itself), but it is possible to implement techniques where sensitive data is significantly better protected in the training of the model such as aggregation, pseudo-anonymising personal data. A good example of this that has been accepted by Ofgem as appropriate for maintaining privacy is the creation of datasets in energy that aggregate data down to a few households based on which properties are on different Low Voltage Feeders. If there are clear controls on the training data which datasets can and cannot be used to train AI models, then we can expect the produced AI model to be privacy preserving. If you implement data protections after an AI model has already been trained, it is harder to control. If a model has used training datasets with potentially identifiable data within them, the model may provide outputs using this data and can end up linking datasets together to make it personally identifiable

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. 

Overall Position

We support the introduction of a new licence condition requiring improvement to connections data. However, the proposal would benefit from clearer definitions of sensitive data and a broader scope that includes both open data and shared (sensitive) data. It is important to note that capacity data is relational not static – interoperability between different data providers and datasets is essential.

A transparent user needs-led approach to data assurance would encourage data sharing, support higher data user confidence, and provide more flexibility than fixed requirements on accuracy, completeness and timeliness, for example regarding update schedules and interoperability. Data user needs must be explored and permitted to share improvement incentives to ensure design and use are aligned. It is important that shared data improvement is incentivised before the timeline for full DSI integration as there is demand for this data immediately. 

Consultation question responses:

Theme 1 – Improving visibility and accuracy of connections data 

Q1.1. Do you agree with Proposal 1.1. to introduce a new licence condition for accurate, complete and timely data? 

Yes, we agree with Proposal 1.1 to introduce a new licence condition, however, it should not be limited to open data publication (see question 1.2 below for sensitive data response). All data sharing would benefit from a clear assurance framework, which may draw from established assurance approaches such as Icebreaker One’s generic dataset assurance levels. Data that is not 100% accurate, complete or timely can still be valuable as long as the limitations are made clear. Assurance encourages publication rather than waiting for “perfect” data, which can mean that key datasets are not published due to data quality concerns. Assurance can include accuracy, completeness and timeliness but it enables more nuanced or context-specific signals about data quality, for example interoperability or provenance.

We encourage licensees to engage widely with stakeholders, particularly those outside the energy sector, to develop data assurance signals that meet specific user needs. Open Energy can facilitate this through a structured approach to design, implementation and governance of such standards within the Energy Sector Trust Framework.  

We support the requirement for data to be as close to real time as feasible, subject to security considerations (e.g. more granular data may be subject to additional access controls). Monthly updates should be considered a minimum baseline, not an indicator of best practice. More frequent (e.g. daily) data updates would be helpful to accelerate policy ambitions to speed up the connection queue. In all cases, update schedules should be published transparently as part of the assurance process.

It is vital that this condition has a consistent  approach across distribution and transmission networks to ensure data is as interoperable as possible. Increasing demand from new industrial plants and digital infrastructure reinforces the need for high-quality, frequently updated, relational connections data. Connections data requirements should apply consistently to both:

• Generation connections
• Demand connections (including large industrial loads and data centres)

Q1.2. Do you agree with Proposal 1.2. to split data into open and sensitive categories, and to use the Data Sharing Infrastructure to share sensitive data? 

No. Sensitive data is not a monolithic category, there are existing approaches (e.g. IB1 Data Sensitivity Classes) to sub-categorise which should be used in order to assess data sensitivities and place appropriate access controls/licensing. This will provide DNOs greater guidance from regulators on what should be considered sensitive data. 

DSI data sharing may not be (immediately) suitable for all use cases, it is currently unclear when and how non-regulated actors will be able to access data via the DSI and these actors constitute major customers for connections data (e.g. heavy industry, retail etc). While sensitive data may be exchanged via the DSI in future, improvements must not be put on hold until the solution is ready. Further, determining whether the DSI is used as the primary mechanism to share sensitive data should depend on the outcome of the MVP.  

Q1.3. Do you have any additional comments in relation to the decisions and proposals outlined in this theme? Do you have any additional comments related to any other aspects of this theme you think we should consider? 

Additional comments:

• Network headroom is not static at a single supply point (substation / GSP). Capacity availability is relational and influenced by:
  • Nearby supply points and how power is drawn/combined from different points
  • Connection queues and timelines
  • Reinforcement plans and timelines
  • Local and regional constraints (e.g. DNO/TNO or cross-DNO constraint interactions)
• The licence condition and associated data standards should better capture and communicate these relational dependencies.
• Greater transparency regarding capacity that has been committed but is not yet utilised (and anticipated timescale for use) may support better planning.

Lessons from relevant innovation projects (e.g. work examining relational network constraints) should inform the design of data publication and visualisation tools. In particular, lessons from the Strategic Innovation Fund REACT programme which aimed to  address current planning and future planning for generation siting may be valuable. REACT’s Alpha Phase Data accessibility and interoperability report recommendations:

• Reducing friction: To improve data assurance, reduce friction across data silos and provide forward compatibility with the Virtual Energy System, the REACT project must embrace a ‘Trust Framework’ methodology throughout its work.
• Improving data accessibility: To improve the discoverability of datasets and encourage process innovation, Transmission Owners should publish internal process diagrams that describe the workings of complicated internal processes – such as the Network Connection Request process.
• Improving prediction: To improve long-term planning for Transmission Owners and for other stakeholders, a statistical model of projects should be embraced that tracks a project’s estimated probability of success according to the best available data.
• Embracing innovation: To radically embrace innovation around processes, such as the Network Connection Request process, virtual ‘sandbox’ representations of these processes with representative data should be created. This will enable innovators to safely experiment with innovative solutions without affecting Business as Usual.

As mentioned in IB1’s Response to Ofgem Modifications to RIIO-3 consultation, with the progress of the Data Sharing Infrastructure (DSI) programme, IB1 anticipates ‘Shared Data’ sharing will evolve and will inform the evolution of data best practice (DBP) guidance. In particular, as data sharing scales, the need to standardise and harmonise legal and technical approaches will become more pressing in order not to slow innovation and add unnecessary cost. IB1 recommends that DBP should include guidance around Shared Data within the triage processes and licensing decisions, highlighting the role of Shared Data Schemes to provide definitions that aid interoperability and maximise impact.

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. 

Consultation response:

1. Do you agree with the Workgroup’s initial view that P494 does better facilitate the Applicable BSC Objectives than the current baseline?* Please provide your rationale and, if ‘No’, please provide full details of your Alternative Modification(s) and your rationale as to why it / they better facilitate the Applicable BSC Objectives. 

• Yes
• No 
• Neutral / No Comment 
• Other 

Rationale: Elexon is unable to fulfil the potential benefit of making the data available with its current position as Data Processor.

2. Do you agree with the Workgroup that the draft legal text in Attachment B delivers the intention of P494?

• Yes
• No 
• Neutral / No Comment 
• Other 

Rationale: 

• Data Controller is limited to “Relevant BSC Personal Data” which only applies to data about natural persons. This will exclude data protections for company data envisaged in the DUAA. It leaves a lot of heavy lifting to the SDR Rules for non-personal but commercially-sensitive company data.
• SDR Rules not sufficiently developed at this time to assess whether, in combination with the code change, they are sufficient to ensure adequate data protection under the DUAA:
  • Identifying legitimate agents
  • Identifying meter owners not covered by CCS
  • Licensing and access arrangements for commercially-sensitive but non-personal data
• The consultation notes that “The means of determining whether a data set is commercially sensitive or personal data are being explored and are outside of P494”. This leaves a lot of work for the SDR Operations Manual to cover. The SDR is described on p27 of the consultation as containing “list of all APIs and reports published as well as technical details for how SDR users can interact with the SDR”. It will need to have much more detailed governance information. There is a risk that these considerations will “fall between the stools” of the BSC modification and the SDR Operations Manual.

3. Do you agree with the Workgroup’s recommended Implementation Date?

• Yes
• No 
• Neutral / No Comment 
• Other 

4. Do you agree with the Workgroup that there are no other potential Alternative Modifications within the scope of P494 which would better facilitate the Applicable BSC Objectives?

• Yes
• No 
• Neutral / No Comment 
• Other 

5. Do you agree with the Workgroup’s assessment of the impact on the BSC Settlement Risks?

• Yes
• No 
• Neutral / No Comment 
• Other 

6. Will P494 impact your organisation?

* If it will impact, please provide a description of the impact(s) and any activities which you will need to undertake between approval and implementation (including any necessary changes to your systems, documents and processes) and any on-going operational impacts. Where applicable, please state any difference in impacts between the Workgroup’s proposed solutions. 

• High 
• Medium 
• Low
• None 
• Other 

Rationale: There is potential for P494 to affect the Perseus smart meter scheme positively, opening up a wider array of the kind of meter points used by SMEs. 

7. How much will it cost your organisation to implement P494?

* If any, please provide details of these costs, how they arise. Please also state whether it makes any difference to these costs whether implemented as part of or outside of a normal BSC Systems Release. Where applicable, please state any difference in costs between the Workgroup’s proposed solutions and if applicable, between the different roles. 

• High 
• Medium 
• Low
• None 
• Other 

Rationale: P494 does not drive any direct costs

8. What will the ongoing cost of P494 be to your organisation?

* If any, please provide details of these costs, how they arise. Please also state whether it makes any difference to these costs whether P494 is implemented as part of or outside of a normal BSC Systems Release. Where applicable, please state any difference in costs between the Workgroup’s proposed solutions and if applicable, between the different roles. 

• High 
• Medium 
• Low 
• None
• Other 

9. How long (from the point of approval) would you need to implement P494?

* Please provide an explanation of your required lead time, and which activities are the key drivers behind the timescale. Please also state whether it makes any difference to this lead time whether implemented as part of or outside of a normal BSC Systems Release. Where applicable, please state any difference in lead times between the Workgroup’s proposed solutions. 

• 0-6 months 
• 6-12 months 
• >12 months 
• Other

Rationale: P494 does not require any action from us

10. Do you agree with the Workgroup’s assessment of the consumer benefits?

• Yes 
• No 
• Neutral/No comment
• Other

11. Do you agree with the Workgroup’s assessment that P494 does impact the European Electricity Balancing Guideline (EBGL) Article 18 terms and conditions held within the BSC?

• Yes 
• No 
• Neutral/No comment
• Other

12. Do you have any comments on the impact of P494 on the EBGL objectives?

No

13. Which of the following funding options do you prefer for the recovery of SDR costs?

• Costs recovered from Suppliers based on the number of MPANs supplied (option one)
• Costs recovered from Suppliers based on their share of delivered energy volumes (option two)
• Costs recovered from Suppliers using a hybrid approach combining MPAN-based and volume-based charging (option three) 
• Costs recovered through existing BSC arrangements and borne by all BSC Trading Parties (option four) 

Rationale: No comment

14. Do you have any views on when the full review of the cost to SDR Users should occur?

• Yes 
• No 
• Neutral/No comment
• Other

15. Do you agree with the legal basis to establish and operate the SDR?

• Yes 
• No 
• Neutral/No comment
• Other

Rationale: The underlying mechanism of creating the SDR Manager and giving it Processor rights seems sound, but it is lacking detail for non-domestic users as noted in our response to Question 2

16. Do you have any views on what the de minimis aggregation level should be?

• Yes 
• No 
• Neutral/No comment
• Other

Rationale: The proposed choice of 10 MPANs is not presented with a clear evidence based rationale. If there is a more detailed rationale this should be put forward transparently. There is an opportunity to build a more nuanced context-specific decision on the appropriate level of aggregation based on factors such as geographic dispersal and existence of generation and storage capabilities that may provide a “signature” in the data. Also consider differentiating “highly aggregated” data (say 50+ MPANs) that may be widely licensed, and “minimally aggregated” data (5-10 MPANs) that may have more restrictive access and licensing to prevent abuse.

17. Do you have any further comments on P494? 

There is a considerable amount of work to be done in the SDR Operations Manual in order to achieve the goals of the SDR Trust Framework. The following are some key elements left to be defined:

1. ID & Verification for non-CCS access is not defined (and even for CCS requires that to have been established). CCS should eventually cover business meters , and hopefully this will extend to smart and AMR meters. But that may not be until 2028. Businesses are key potential beneficiaries of SDR, for both cost reduction and net-zero impact. A number of the expected SDR Users focus on services intended for business. How will SDR support businesses in the interim? How will the SDR Users be verified, their data usage controlled, and how will they provide evidence for meter data access from businesses?
2. The data sensitivity classes need more definition and clear policies for application
3. The eligibility requirements and decision-making process for executing an Access Agreement and allowing access must be defined, as well as policies/processes for ensuring SDR Users remain eligible
4. Data licensing requirements are not mentioned in the consultation. How will purposes be categorised and policed? What is permitted/not permitted for the various levels of non-open data?
5. Liability and redress are not mentioned in the consultation. What policies and processes will enable data subjects harmed by the SDR to seek redress?

Since SCR covers a wider range of legal bases and potential data users than CCS, we recommend early consideration of how governance elements such as those above may be harmonised with other data sharing initiatives. This may be achieved through identifying opportunities for common definitions around ID&V, data sensitivity, purposes (or classes of purpose), and licences. Icebreaker One and Open Energy have research and experience, drawn from wide stakeholder engagement, that can inform this work.

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.

Consultation response:

Q1. Do you agree with our case for change and that policy intervention is needed for DNO asset registration? 

Icebreaker One (IB1) is a non-profit working on data sharing and sustainability, convening organisations and governments to design market-scale solutions to make data work harder to deliver Net Zero. IB1 creates and runs programmes to reduce barriers and costs to finding, accessing, using, and sharing data, which will ultimately reduce costs for consumers.

IB1 supports better data on assets, and data sharing between DNOs, suppliers, and other organisations who need to understand headroom capacity and demand. We note there is a need to distinguish clearly between asset type(s) and capacity at the initial phase. In future, better data on asset performance and behaviours would be helpful to ensure this initiative can be most useful – e.g. capacity is not static with flexibility assets in play.

Q2. Do you agree with our priority use cases, and are there any other use cases we should consider? 

We agree with Ofgem’s identified use cases, however, we note that the data end user within the priority (regulated entities) and further use cases may have very different needs and data sharing instruments available. As mentioned in IB1’s response to Ofgem’s Energy digitalisation governance: architectural coordination letter, we propose that an industry-independent coordination body helps coordinate a flexible energy system. Data sharing at scale requires the separation of ‘the data’ from its governance and the technology used to host and transfer it.

We encourage the inclusion of potential ‘further users’ as a part of a governance process from the outset to ensure a solution suits their needs and does not exclude the solution from expanding past the priority use cases. We advocate for starting with a use case with external (non-regulated / less digitally mature) players, then a B2B DNO focussed use case to make subsequent use cases easier and less likely to inadvertently produce blockers. Leaving local authority use cases for “later” risks local planning and investment being disconnected from the physical reality of supply. A key use case to consider is data centre energy demand, which reinforces the need to urgently prioritise local authority use cases. 

IB1 has worked on a few other relevant collaborative use cases in this area, including:

• Getting small scale assets / flex services online (Open Energy Future of heating –  Residential Property Developer use case).
• How data sharing can be used to better understand how to maintain the assets already in place. IB1, SSEN-Transmission, IBM, and Palantir on a Strategic Innovation Fund programme, NIMBUS, which focussed on granular weather data and network innovation to build for sustainability. See the Discovery Phase report and the Alpha Phase report.
• IB1 partnered with SSEN-Transmission, Olsights, Mapstand, SGN, and National Grid on a Strategic Innovation Fund programme REACT to address current planning and future planning for generation siting. See the Discovery Phase report, and the Alpha Phase report. This use case reinforces the need to know other assets on grid to aid grid capacity understanding and future planning.

Q3. Are there any other policy or industry initiatives that we should seek to align with? 

IB1 encourages seeking alignment with:

• Open Energy – run by IB1, has expertise articulating use cases, and designing and quickly implementing shared data schemes with appropriate governance – includes legal agreements, assurance and technical specifications – in collaboration with stakeholders.
• Connections end-to-end review: updated proposals and next steps​ consultation. To what extent are external entities interested in assets as opposed to capabilities?
• Consumer Consent Solution, currently being developed, designed and delivered by RECCo Ltd, as small scale asset data is in scope (unless this programme is using another lawful basis for processing, this would need to be articulated clearly).

Q4. Do you agree with the scope proposed for assets, data, entities, and data stages, should anything else be considered?

As mentioned above, there needs to be a defined governance process for considering and agreeing upon the proposed scope for assets, data, entities, and data stages. 

IB1 would highlight there is a need to identify current data uses, and to be flexible enough to incorporate new ones as they emerge, to establish both the scope and the data quality and completeness requirements for asset information. For example, there is likely to be a difference between the DNOs’ data quality requirements at the lowest end of the asset capacity scale and the data quality requirements for users like councils, planners, microgrid/heat network assessors etc. Additionally if this asset data feeds into the flex market, missing or incorrect installations could lead to financial consequences for asset owners. 

While not in scope for the initial phase of development, our suggestion for future development would be the ability to transfer data on asset profiles/behaviours. This would be incredibly useful to better understand how flexible assets actually behave and their real-life impact, for example on network capacity.

Q5. Do you agree with our enablers and dependencies, and are there any others we should consider? 

IB1 would add on the lawful basis for processing – if not using consent then clarify on what lawful basis the register operates under. It would also help to understand how any data protection risks potentially associated with the register will be managed and governed. It is not currently clear how the lawful basis distinguishes between household and business (including microbusiness/SME) assets. This will interact with the Data (Use and Access) Act for businesses and requires clarification.

Q6. Do you have any suggestions for collecting legacy data, or for integration of other datasets into DNO registers? 

No comment. 

Q7. Do you agree with the advantages and disadvantages for the proposed options, are there others or any wider aspects we should consider? 

Wider aspects to consider on Option 2:

• May require upskilling/investment by DNOs, with an opportunity to subcontract if they are lacking skills in-house. This is a low risk if data standards are agreed through a governance process.
• As mentioned in Question 2, this initiative must be mindful of restricting use cases to regulated entities first which may make it harder for other users in the future. 
• As there is demand by non-regulated users for asset data now, there may be a benefit to spinning up a scheme in the short frame which is ready to integrate with DSI but has governance to engage a wider range of end users at the start. 
• This option has the highest potential to scale as it does not bottleneck in a single database/register, and provide utility for a wide range of use cases. 

Wider aspects to consider on Option 3:

• New databases and portals struggle to scale for a wide array of use cases as infrastructure systems are being digitalised in a decentralised and distributed way
• This option gives liability to a central entity versus distributed liability to DNOs
• May conflict with current DNO autonomy in deciding what data to publish and how to publish it, guided by DBPG. In particular may lead to a lowest-common-denominator approach that disincentivises DNOs from publishing otherwise-useful data that isn’t needed by the central register

Wider aspects to consider on Option 4:

• Operating a flexible market is a significantly different use case from the ones articulated above – expanding existing initiatives may result in a loss of focus on the original challenge it was solving
• Suggest a focus on harmonisation rather than making FMAR even more complex.

Q8. Are there any changes you would make to any of the proposed options to enhance them? 

IB1 would emphasise the need for a determination on what body would govern the standards for Option 2, and how stakeholder engagement beyond the regulated entities will be managed. There is a need to convene stakeholders within and outside the industry to ensure it is fair and accessible as well as implementable by the data holders. 

Q9. Have we missed or discounted any options that you think are suitable? In particular, for option 4 is there a preferable alternative to FMAR for expansion, and why? 

No Comment. 

Q10. Which option is your preferred option, and why?

IB1 would encourage Option 2, as it is the fastest to market and lowest cost, and can be decoupled from other initiatives, so can run in parallel and at pace. We would suggest this happens through a trial ‘scheme’ developed as and will be DSI integration ready for when DSI is ready to support asset data sharing. 

This option also has the opportunity to have the simplest governance (only DNO liabilities) – although this needs defining – as referenced in Question 8.

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.

Date: Tuesday 17 February 2026 11:00-12:30 GMT

Location: In person & online

Co-Chairs: Sara Vaughan & Gavin Starks

Secretariat: IB1

Meeting Aims 

1. Support for the use case for 2026
2. Support the governance process
3. Connect us with new potential members

Summary:

• It was agreed that:
  • The 2026 roadmap will move from engagement and prioritisation early in the year to implementation activity later in the year.
  • Remaining organisations will be asked to complete outstanding terms of reference signatures, where that is possible.
• It was noted that:
  • An update was given on activities since the last SG, including:
    • Government and Ofgem activity is increasingly focused on ensuring greater visibility of distributed and flexible energy assets.
    • Elexon has gone live with its flexibility market facilitator role, and the new Flexibility Commissioner has been announced.
    • NESO and XOSERVE have announced a strategic partnership on consolidation and sharing of gas data which will help facilitate and streamline whole-system planning.
    • Ofgem published its Forward Workplan for 2026/7.
    • RECCO published the design consultation on its Consumer Consent solution.
    • The intended publication of the DESNZ/Ofgem Digitalisation Vision in Q1 2026 was confirmed.
  • The Smart Data Council has resumed and is developing UK guidance for smart data schemes.
  • The Perseus programme has broad participation and commercial offerings are expected from 2026, with a £5-10bn SME opportunity by 2030.
  • Feedback to the Open Data access controls paper has been positive across the sector.
  • The 2026 priority use cases will focus on UC04 – cross-sector storm response or UC05 – industrial and commercial flexibility.
• It was discussed that:
  • Practical implementation and real use cases may be more persuasive to policymakers than theoretical proposals.
  • A Community Interest Company (CIC) based SPV funding model could support multi-year funding and participation from multiple network operators but, given IB1’s non-profit, public benefit status, there was not a strong case to change to such a model.

Next meeting: Thursday 7 May 2026 14:30-16:00 BST

Formal records, including attendees, are maintained by the secretariat. 

These are confidential to the Steering Group Members.

This is Icebreaker One’s response to Ofgem’s Energy Digitalisation Governance – Architectural Coordination letter.

Please note that throughout this consultation, Icebreaker One (IB1) 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.

Executive summary

This response advocates for a focus on coordination of the energy sector’s data architecture and energy data governance as a fruitful starting point for architectural coordination of digitalisation governance. It emphasises that coordination is an ongoing process with human and technical components. It further works to the principle of minimisation, specifying that coordination activity must work in the leanest feasible manner, delegating to existing sector processes where possible and only acting where there are clear requirements for further intervention. We propose that the coordination challenge should be met via the appointment of an industry–independent coordination body composed of Secretariat, Research, and Monitoring functions. 

We do not propose that the coordinator should have enforcement powers, as these are most readily delivered under the existing regulatory and legislative capabilities of Ofgem and DESNZ. However, both Ofgem and DESNZ must be required to consider options from the coordination body in their determinations. 

The Secretariat should act as an independent facilitator for participatory governance processes which can adapt flexibly to evolving coordination needs and ensure accountability. 

The Research and Monitoring function should have two responsibilities:

1. mapping the domain(s) in which coordination is enacted in order to support effective participatory governance
2. monitoring and reporting on the outcomes of coordination activity to improve transparency and join-up with adjacent policy/regulatory goals (energy and cross-sector). 

We suggest that this function includes coordinating and monitoring the delivery of the sector’s digitalisation roadmap. We suggest that the body would require a small permanent staff to ensure continuity of process, with additional staffing contracted or seconded in on a short term basis for agile response to emergent needs (e.g. particular technical or domain expertise concerning a particular coordination challenge). This lightweight approach will deliver the intended benefits at a reasonable cost to the bill- or taxpayer. 

Response

Where should we focus?

Prior to addressing specific prompt questions, it is important to discuss the boundaries of the digital space and its component parts. Digitalisation is an umbrella term which can be used to refer to a wide range of different processes, technologies, activities, actors, and frameworks. Accordingly, the term is prone to some mystification as well as the drawing of false equivalences between digitalisation and technology. While we agree with Ofgem’s statement that there is an emergent need for coordination in energy sector digitalisation, we emphasise the importance of defining the boundaries of what exactly, within the wider digital space, is the target for this activity.

As discussed in IB1’s response to DBT’s Invest 2035: industrial strategy consultation, and in alignment with the National Data Strategy, the bedrock of digitalisation lies in data. In parallel, a significant proportion of industry digital activities to date involve laying the foundations for how data is governed, shared, and used within the energy sector. Accordingly, we strongly suggest that Ofgem’s architectural considerations at the present time focus on the coordination of the sector’s data architecture and associated energy data governance rather than other elements of the digital transition. Coordination in other digital arenas may well be required in future and we support future consultation accordingly. However, we do not believe that it represents value for money, nor effective prioritisation against net zero, to focus on these areas at the current time.

It is also important to draw a clear line between the valuable work currently progressing in large but focused sector-wide initiatives, such as the Data Sharing Infrastructure (DSI) or Consumer Consent Solution programmes, with the overall task of coordinating sectoral data governance. At its heart, data is not a technology, an ontology, or a standard. Rather, data is highly contextual — defined by a framework of rights-based governance, shaping how it can be gathered, shared and used, by whom, and for what purpose(s). 

Many ongoing data sharing initiatives in the sector (currently in their definition, prototype, or pilot phases) are advancing technology-led projects. These technical developments augment the sector’s capacity to collect, transport, and process data which is valuable. However, we have raised concerns in several forums that these projects risk developing in a manner which results in disjointed data governance. Coordination in the data governance arena would ensure that technology buildout will be clearly linked to user needs, meet appropriate levels of security, and promote legal interoperability supporting clear and confident data use. Without coordinating energy data governance, we risk building an environment where data exchange is improved on a technical level, but the real world use of the data remains subject to the same limitations that have been established by the research literature. 

How would coordination be achieved?

Coordination is an ongoing process between people and organisations, which will contend with ‘live’ and sensitive factors such as vested interests as well as wider factors such as the economic climate. We would anticipate a common digital architecture coordination function extending beyond a document, to capture the scale and nature of the coordination problem. The “function” of architectural coordination delivers the value – a document could describe it, but would not enact it. We believe that an independent entity is required to operationalise effective coordination. We also advocate that this should be achieved through as thin a layer of activity as possible, in order to present the best value for money and time. 

Additionally, we emphasise that our engagement with industry via the Open Energy Advisory and Working Groups has highlighted a need to think of coordination not as all organisations within the sector doing things in the same way. Rather, coordination should  focus on harmonisation and interoperability within company contexts of operation and as a common framework which aligns activities and reduces duplication. 

Open Energy

We believe that Open Energy is the only initiative currently operating within the energy sector that holds the independence, governance approach (designed in collaboration with the Institute of Directors), cross-sector experience, technical knowledge and flexible capacity to address architectural coordination of energy data governance. 

Open Energy, the competition-winning programme developed under the UKRI Modernising Energy Data Access initiative, identified and articulated the need to make it straightforward to find, access and share energy data. Open Energy was funded by £1.3m public money through three phases and is currently funded by commercial members. 

Open Energy is coordinated by the public-benefit nonprofit body, IB1, and has been specifically developed for this purpose using a combination of radically transparent methods of open working, extensive consultation with stakeholders, and the input of specific domain expertise from energy industry, academic, cybersecurity and Smart Data specialists.

Successful governance initiatives, including Open Banking, have taken the model of having an independent, non-sectoral incumbent body take on an architectural coordination role. Additionally a key recommendation from the 2021 Energy Digitalisation Taskforce Report summarises:

It is recommended that an independent, commercially disinterested body is established by Government to develop and/or incubate Public Interest Digital Assets on behalf of the sector. The Body should be given a mandate and funding to develop and deploy assets (either directly or via partners), directed by a stakeholder panel interested in the current and future needs of the energy sector. The benefit of this is that it would report to government but operate to the side of it.

As part of discussions following this letter, we appeal to Ofgem and DESNZ to enter into dialogue with Open Energy and its membership to discuss how Open Energy might be appropriately strengthened (e.g. participation or enforcement mandates) or configured (e.g. as a special purpose vehicle) to enable it to meet the required coordination function.

Our focus on governance is driven by the view that making data work harder for net zero isn’t a technology challenge. Rather than a deficit of data or technologies to manage it, it’s a deficit of effective processes for groups of organisations to come together, cooperate on and set the terms of data sharing that’s really holding us back.

In our work, governance is an ongoing process. The execution of this process produces decisions that enable data sharing to take place. In practice, this involves establishing principles, defining clear roles and responsibilities, and agreeing priorities and tasks. It also involves collaborating to create artefacts to express and enforce these decisions, such as legal agreements and technical standards.

We have a particular approach to organising data governance at IB1. We use a tiered system of Steering, Advisory and Working Groups to bring organisations together. These groups work together to agree and adopt:

• User needs & impact: commercial priorities, business cases, and prospective new products and services.
• Technical infrastructure: shared ontologies, APIs, schemas and standards to support data exchange. 
• Licensing & legal: data sharing agreements, modes of redress and liability frameworks.
• Engagement & communications: common language, stakeholder engagement and recruitment.
• Policy: alignment with corporate policy and industry regulations.

Participation in this process can be either voluntary (initiated by the market), or mandatory (demanded by regulators).

Using this collaborative process within the Open Energy programme, IB1 has designed, implemented and operates the Open Energy data search engine, the Energy Sector Trust Framework (ESTF), and within it, the Assured Open Data scheme. The ESTF is supported by IB1-developed open source Trust Services, including common technical specifications, a registry providing human- and machine-readable data sharing rules, a public directory of members and a secure portal for members to manage their information and issue digital identity certificates. These atomic, reusable services also power the cross-sector Perseus scheme that automates emissions reporting based on smart meter consumption data for UK SMEs. 

Our approach is inspired and practically informed by the UK’s Open Banking ecosystem, which enables data to be shared in new ways across banks and other financial services. It now has 15 million users and is projected to sustain a $12bn market of data-driven products and services. This change has been achieved not by building a big, centralised database of customer banking data, but by governing who should access it and how it should flow. 

Key questions:

1. Where is there a need for architectural coordination across the sector to unlock the full value of energy system digitalisation? 

As outlined above, we advocate that data governance, including the governance of data sharing, represents the clearest priority for coordination activity in the current moment. Needs are likely to change over time, so this must be regularly re-assessed in light of the wider sectoral environment (e.g. digital maturity, progress towards net zero, contextual policy challenges, economic environment etc). Additionally, we urge Ofgem to approach coordination through the lens of cross-sector interoperability and harmonisation, rather than a “one size fits all” standardisation. 

There is a need for coordination of data governance in the following arenas:

Secretariat:

• Participatory processes: An independent facilitator is needed to support the involvement of a range of participants (directly or via a representative structure) which can adapt flexibly according to coordination needs. 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 parts of the sector, or task and finish style groups to support elements of digitalisation strategy delivery.
  • Independent Secretariat function with 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 process, linked to existing sector mechanisms and to participatory governance processes.
  • Participant accountability mechanisms (linked to enforcement – see below).
• Enforcement: we suggest that enforcement activity occurs under the umbrella of either Ofgem or DESNZ. This may include:
  • Ability to compel involvement in participatory processes (at least at some defined level) of regulated entities to ensure fair and balanced process
  • Ability to invite external stakeholders as and when required, in a transparent manner (e.g. pinned to a published methodology for a certain use case / decision / piece of research).
  • Ability to action change
• Accountability: 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
• Other:
  • We strongly suggest that the Secretariat is empowered to communicate across sectors in order to best learn and harmonise with digital and data sharing initiatives that cross sector boundaries.

Research and monitoring:

• Mapping: light touch, but regularly re-visited, research and documentation to understand current and emergent actors, activities, points of interaction/crossover/competition, and gap analysis – this will also help draw the boundaries around the remit of current coordination priorities and future considerations. This must:
  • Include cross-sector activities
  • Include cross-scalar activities (e.g. map devolved authorities, local etc as well as national initiatives)
  • Include identification of priority use cases / sets of use cases, particularly which require addressing via pre-competitive activity.
  • Highlighting areas where government or regulatory input may be required to meet policy goals.
  • De-mystify parts of the digital transition into clear component elements (both socio-economic and technical) with defined terminology
• Monitoring: 
  • Devising, implementing and openly publishing Monitoring, Evaluation and Learning (MEL) methodologies and reports in accordance with a transparent schedule – including ways to ensure digitalisation supports other policy goals (e.g. Net Zero, Warm Homes Plan, Flexibility development etc) and increases transparency in an area of rapid sector growth.
  • Coordinating the delivery of the sector’s digitalisation roadmap to ensure that effort is not duplicated and complexity is minimised. While we welcome NESO’s work to address sector-wide digitalisation planning, we suggest that this function should be devolved to an independent body in order to appropriately hold all actors to account. 

2. What are the constituent elements of architectural coordination of digitalisation in the energy sector?

We have interpreted this question to refer to how architectural coordination could be operationalised through a coordinating body. We suggest that the body is composed of an experienced Secretariat, which is vital to good governance processes. It must also have a small research and MEL team as outlined below. Additional elements should be flexible and responsive to the developing ecosystem. Accordingly, it may be beneficial for the body to be able to second in expert staff on a temporary basis. Across the board it is vital for the coordination body to be independent.

Secretariat component

A Secretariat coordinates and supports group meetings to ensure the programme is making effective and timely decisions and is aligned with strategic objectives. Secretariat  administrative support includes: meeting arrangements, pre-read and agenda dissemination, note-taking and drafting of formal minutes. Maintenance of an effective, experienced Secretariat requires an appropriate budget for ongoing roles.

As outlined in question 1, the Secretariat component would support participatory processes, enforcement, and accountability functions. It is vital that the Secretariat retains independence from other sector bodies in order to navigate conflicts of interest and build trust among participants.

Research and monitoring component

An effective research and monitoring function requires the maintenance of a small team with expertise in research methods, knowledge transfer, and reporting. We suggest that primary research should be participatory, bringing in experts to minimise cost and duplication. The research element of this component may require a small flexible fund to support short term targeted projects (e.g. mapping stakeholders who must be consulted when developing a specific area of pre-competitive activity). The monitoring element requires access to participation from sector authorities to define the target and frequency of monitoring activity and dialogue with the wider sector, and appropriate experts, to identify or devise appropriate methodologies. It is essential for this component to have the ability to freely publish monitoring results, with sensitivity to factors such as security when defining the appropriate level of openness. This component should provide a forum for feedback from scrutiny as and when required.

We again emphasise the importance of independence in this arena as there may be cases where the component sheds light on poor performance or emergent issues. This requires an independent entity to perform; it cannot be nested in an existing body without risking conflict of interest.

3. What value could a common digital architecture document for the energy sector provide?

Coordination is an ongoing process between people and organisations, which will contend with ‘live’ and sensitive factors such as vested interests as well as wider factors such as the economic climate. We would anticipate a common digital architecture coordination function extending beyond a document, to capture the scale and nature of the coordination problem. The “function” of architectural coordination delivers the value – a document could describe it, but would not enact it. We believe that an independent entity is required to operationalise effective coordination

Potential benefits of architectural coordination include:

• Avoiding duplication — e.g. multiple Trust Framework providers that potentially aren’t interoperable
• Learning from other sectors — lacking clear deadlines and costs. The Pensions Dashboard Programme has an estimated cost of £289m, with no released date of when the dashboard will be made available to the public
• Saving money and reducing time-to-value by providing market participants with repeatable processes and building on well-understood standards 
• Prioritisation of key use cases
• Avoid the time and financial costs of a lack of coordination, especially on urgent causes such as net zero

4. What function may be needed to deliver architectural coordination and how would it interact with functions/organisations that are delivering digital public infrastructure (DSI/NESO, Consumer Consent Solution/RECCo, Smart Metering Network/DCC, FMAR and SDR/Elexon) 

• Ability to liaise and harmonise across sectors — e.g. Smart Data schemes, DSIT, Smart Data Council
• Cross-sector thinking is required to achieve the size of impact that the Industrial Strategy and The Clean Power Plan have outlined
• Must be a non-profit dedicated to the public good to avoid distorting the market and discouraging commercial members
• A function should be judged against the criteria of:
  • How light-touch and small it can be in order to deliver the needed effect
  • How much value is gained by stakeholders from their participation

5. Is coordination an ongoing task (including monitoring), or a temporary task to deliver the elements needed (from q2)? 

We strongly encourage that coordination must be an ongoing task, including monitoring, and acknowledge that it will adapt and change as energy digitalisation evolves. Governance must be designed to assess and adapt to changes. 

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.

Consultation response:

Regarding paragraph 3.36 in the Statutory Consultation on the RIIO-3 Licence Drafting modifications – reasons and effects document:

Generally IB1 supports a common Digitalisation Re-opener to encourage digitalisation by allowing network companies to seek funding for data and digital related projects with a broader scope than just IT hardware or software upgrades and to align with RIIO-ED2.

IB1 supports digitalisation as key for energy sector decarbonisation, and required for the investment in flex services and the coordination between sectors who rely on energy to meet their decarbonisation targets (water, transportation, built environment, industry).

IB1 supports sector-wide convening and governance to ensure digitalisation happens in a coordinated manner and can enable ‘whole system solutions,’ as promoted in RIIO-ED2 and realise the subsequent cost savings. IB1 supports Ofgem to continue to promote and finance whole system digitalisation coordination in RIIO-ED3.

As there are many ongoing data sharing and data governance initiatives e.g. consumer consent solution, flexibility services, Data Sharing Infrastructure (DSI), which are currently in progress at different stages of development (definition, prototype, or pilot). Ofgem should not expect these programmes and underlying challenges the projects aim to solve to be resolved by the end of RIIO-ED3 (2031). Data sharing and data governance needs and subsequent solutions will evolve over time as we continue to electrify and connect the UK’s grid. As mentioned above, Ofgem needs to ensure ongoing governance and sector collaboration on data and digitalisation – reinforcement of this would be welcomed in addition to specific plans to expand/evolve data governance initiatives.

With the progress of the Data Sharing Infrastructure (DSI) programme, IB1 anticipates ‘Shared Data’ sharing will evolve and will inform the evolution of data best practice (DBP) guidance. In particular, as data sharing scales, the need to standardise and harmonise legal and technical approaches will become more pressing in order not to slow innovation and add unnecessary cost. IB1 recommends that DBP should include guidance around Shared Data within the triage processes and licensing decisions, highlighting the role of Shared Data Schemes to provide definitions that aid interoperability and maximise impact.

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.

Consultation response:

Do you agree with the proposed implementation approach? Yes.

Rationale: We appreciate that there is a governance in place to discuss and approve the proposed implementation. We would welcome further transparency on the outcomes of applications to access data via this method and suggest that a summary of cases are made openly available after a 6-12 month trial period. Ongoing avenues for scrutiny remain important.

Please provide any further comments you may have.

As we are looking holistically at the smart meter data landscape, we will continue to work with the SEC and engage as it develops on a case by case basis and impacts wider use cases.

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.

Date: 25 November 2025 11:00-12:30 GMT

Location: Online

Co-Chairs: Sara Vaughan & Gavin Starks

Secretariat: IB1

Meeting Aims 

1. Understand the reactions to the Architecture coordinator open letter
2. Update on Open Energy activities and webinar

Summary:

• It was noted that:
  • A number of the Q4 goals are complete or in progress, and the IB1 team are working to realign those remaining to create a new plan for Q1 and Q2, which will be shared with members in January 2026.
  • There was good engagement and attendance at the webinar in October, with poll results revealing that uncertainty around sector-wide alignment is a major confidence barrier, with participant discussion reinforcing the need for a coordinated approach.
  • Driven by the Data Use and Access Act, data sharing initiatives are starting to form across the economy.
  • As one of the more mature sectors for data sharing, the energy sector is experiencing concerns over misalignment that will likely play out in other sectors, and it has an opportunity to demonstrate how the co-ordination function should operate.
• It was agreed that:
  • Without further clarity on the venn diagram of roles within the industry, and who should be at the helm, the industry faces a significant financial risk of duplication and over-spending, leading to this transformation costing much more than it needs to; and
  • There is fragmentation across the industry with a lack of coherence around the venn diagram of roles, and who should be coordinating, orchestrating and determining the future developments.
  • Developing a Market Architecture would help to shape the governing process along with who the relevant actors are and what their contributions should be, providing clarity to the industry.
  • This does not have to be a single body, it could be a community of actors working together within some sort of governing body. A not-for-profit could be used to bring this together.
• It was noted that:
  • There are competing views on the value of a use case-based approach. However, many members feel that use cases are essential to be able to work on achievable priorities within the industry and make informed decisions about data protection and security.
  • It’s important to take note of the work that RECCo is undertaking, particularly what trust framework RECCo provides and how that is then used by the broader market. This highlights the decisions that need to be made and where there is a requirement for a coordinating function.
  • The question of ‘who is the final arbiter?’ that was posed during the last meeting, is yet to be resolved.
• It was discussed that:
  • While NESO holds the interim DSI role until 2028, it would be challenging for them, at least until then and possibly beyond without a change in the skills and capability of the organisation, to take up the role of a single, accountable organisation for digital co-ordination of the sector – although, in principle, this was the sort of role they should be fulfilling.
  • Other industries have placed an independent non-profit at the centre of their data-sharing arrangements, setting a successful precedent for the energy industry to follow.

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.

Date: 30 September 2025 14:30-16:00 BST

Location: In person and online

Co-Chairs: Sara Vaughan & Gavin Starks

Secretariat: IB1

Meeting Aims 

1. Introduction to the Cunliffe Review in preparation for aligning on responses in the next meeting 
2. Conduct vote to endorse setting up Data Standards Water Quality Monitoring 
3. Conduct vote to confirm endorsement by members of the Innovate UK bid 

Summary:

• It was noted that:
  • Elexon is progressing the Smart Meter Data Repository, coordinating with RECCo on its work on consumer consent alignment, with differing timelines expected for delivery.
  • DESNZ and Ofgem are expected to publish a vision document in Q1 2025. A question remains around how much it integrates and is influenced by the ongoing work in Open Energy.
  • The joint SIF bid with Arup, SSE, and NGED aims to develop a core use case that improves LAEP data sharing for high energy demand users, with a methodology to develop data schemes compatible with any trust framework.
• It was discussed that selecting and progressing specific use cases is necessary to test and shape the overall architecture, inform technical and legal standards, and support regulatory alignment, mirroring the iterative approach taken in Open Banking.
• It was discussed that while there is significant activity underway across the sector, there remains a degree of caution as to whether this activity is delivering tangible outcomes. This caution stems from several factors:
  • That current efforts require greater coordination and orchestration across the various market actors and initiatives to ensure alignment and avoid duplication. There is a need for an “orchestration layer”.
  • There is a question around who the delivery agents are, and how delivery can be ensured.
  • There is a need for clearer prioritisation and a stronger demonstration of commercial value.
  • There is a question around who is the master arbiter, who takes the ultimate decisions, e.g. on questions of definition?
• It was noted that the goals for Q4 2025 and Q1 2026 have been set, including:
  • A webinar addressing language challenges that is scheduled on 23rd October from 2-3pm
  • Two SIF bids to be submitted in early Q1 2025: ‘SIF ADA’ and ‘Market Architecture’
• It was discussed that key implementation decisions over the next 6-12 months will significantly shape the future architecture of the UK energy data ecosystem.

Data has a huge role to play in delivering net zero by 2050.

Reliable data is vital for verifying that organisations are meeting their sustainability commitments. Investors depend on it to shift their investments towards greener companies, while innovation in energy production will hinge on the smart use of data.

But despite generating huge quantities of data every day, we’re not making the most of it. Take data about companies’ emissions. It’s languishing in spreadsheets, carbon calculators, smart meters and other siloes. Even when organisations do share their emissions data, it’s generally seen as an exercise in after-the-fact reporting.

Databases of low quality, out-of-date information are not a foundation for developing new products or technologies, or unlocking new markets.

When it comes to net zero, data is everywhere, just not where we need it.

At IB1, we don’t try to bring ‘all the data into one place’, as others attempt. Nor do we host data or seek to provide analysis services using it.

Instead, we [orchestrate] [schemes] of [data governance] that enable groups of organisations to share continuous flows of well-structured, assurable data with one another.

Governance

Our focus on [data governance] is driven by the view that making data work harder for net zero isn’t a technology challenge.

Rather than a deficit of data or technologies to manage it, it’s a deficit of effective processes for groups of organisations to come together, cooperate on and set the terms of data sharing that’s really holding us back.

“Incentives in our organisations and society prompt us to beaver away on our own. Collaboration is the catalyst of innovation, [but] we often struggle to practice it when it comes to overcoming complex challenges and making efforts towards positive social progress”. – Miranda Dixon, Brink

As with other collective action problems, only good governance can align fragmented interests, enable collaboration and facilitate shared investment.

In our work, governance is an ongoing process. The execution of this process produces decisions that enable data sharing to take place. In practice, this involves establishing principles, defining clear roles and responsibilities, and agreeing priorities and tasks. It also involves collaborating to create artefacts to express and enforce these decisions, such as legal agreements and technical standards.

We have a particular approach to organising data governance at IB1. We use a tiered system of Steering, Advisory and Working Groups to bring organisations together. These groups work together to agree and adopt:

• User needs & impact: commercial priorities, business cases, and prospective new products and services.
• Technical infrastructure: shared ontologies, APIs, schemas and standards to support data exchange. 
• Licensing & legal: data sharing agreements, modes of redress and liability frameworks.
• Engagement & communications: common language, stakeholder engagement and recruitment.
• Policy: alignment with corporate policy and industry regulations.

Participation in this process can be either voluntary (initiated by the market), or mandatory (demanded by regulators). 

Our approach is inspired by the UK’s Open Banking ecosystem, which enabled data to be shared in new ways across banks and other financial services. It now has 10 million users and is projected to sustain a $12bn market of data-driven products and services. This change has been achieved not by building a big, centralised database of customer banking data, but by governing who should access it and how it should flow. 

Schemes

As well as neglecting governance, attempts to build databases of net zero data fail because they try to be all things to all people.

In a 2024 talk, Building scalable public data sets for scientific innovation, John Wilbanks described how effective data systems generally begin life by addressing a small set of very specific primary uses, before evolving to enable more over time:

“No one has ever built a complex data system by setting out to build a complex data system [from day one]. You build one by answering five questions at a time, using a standards based approach… And then when you’re able to answer twenty, you’ll have a functioning complex data system”.

We agree that specificity is a necessary condition for effective data sharing. We enable groups of organisations to come together around tightly-focused challenges or use cases related to net zero, which we refer to as [schemes].

Our flagship scheme, Perseus, enables small-and-medium sized businesses to share granular emissions data from their smart meter systems with banks and other lenders. By providing lenders with the accurate and assurable data they need, the scheme enables participating businesses to access loans and other finance to help reduce their emissions.

Perseus isn’t trying to cast a net around all sustainability data, or work for every company. It demonstrates how good governance—anchored around a very specific goal —can unlock data from the real economy and put it to use for net zero.

Orchestration

We don’t have a monopoly on this view of data governance. But we think groups of organisations can go further, more quickly with our [orchestration].

We provide and maintain the following Trust Services to enable schemes like Perseus to function:

1. A machine-readable rulebook that codifies how data can be shared within the scheme.
2. An approach for verifying which organisations can take part in the scheme.
3. An open directory of the organisations that have been verified to take part in the scheme.
4. An approach for monitoring and assuring that access to data within the scheme adheres to the agreed rulebook.
5. An open catalogue of the data that is made available within the scheme.

None of the services we provide rely on particular software or a singular technology vendor. What we deploy depends on the needs of the scheme. Data access can be enabled by API, more advanced privacy enhancing technologies… even fax machine. (Although we wouldn’t recommend the latter.) What’s important is that the solution meets our NOVA principles: a Networked, Open, Verifiable Architecture. 

Our non-profit status is another key element of this work. There’s a risk that the direction of data use will be dictated by commercial actors, if schemes are left to the market alone. Our approach at IB1 ensures that no individual or entity can take disproportionate control of net zero data, and that end user needs rather than organisational agendas drive progress.

We’re glad the importance of this orchestrating role is now being recognised. A recent analysis of ‘data spaces’ being built across the European Union found that successful efforts have an independent organisation at the centre:

“It is crucial to have a neutral orchestrator facilitating the exchanges between participants before the operations and governance of a data ecosystem solidifies.

The orchestrator should prioritise use cases, map business value creation, test business models, and set up governance models. During the operation phase, the focus will shift toward onboarding, enforcing the rules, ensuring the governance works as it should, and scaling up”.

Infrastructure for real progress

Making data work harder for net zero ultimately depends on trust, coordination, and infrastructure that works across organisations. 

Ever-bigger, centralised databases won’t get us there. What we urgently need are well-orchestrated schemes of data governance that enable decision grade data to flow.

But making this shift requires resources—and partners.

If you’re working along the same lines, or if you’re looking to fund the infrastructure that underpins real progress on net zero, join us.

Reach out via:  icebreaking@ib1.org

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.

Consultation response:

Icebreaker One (IB1) is a public-benefit non-profit working on data sharing and sustainability, convening organisations and governments to design market-scale solutions to make data work harder to deliver Net Zero. It creates and runs programmes to reduce barriers and costs to finding, accessing, using, and sharing data, which will ultimately reduce costs for consumers. Through the UKRI Modernising Energy Data Access competition, in collaboration with over 400 industry stakeholders, IB1 developed Open Energy which identified and articulated the need to make it straightforward to find, access and share energy data. Given IB1’s focus, we have responded to a number of the questions in the consultation. 

IB1 supports RIIO-ED3’s goals of moving away from gas infrastructure, toward renewables, and a more resilient grid. It is essential to have a joined-up approach and cross-sector thinking to achieve the size of impact outlined in the Industrial Strategy and The Clean Power 2030 Action Plan and unlock the widest range of potential benefits.

OVQ36. Do you agree with our position of not changing the Digitalisation licence condition?

IB1 supports digitalisation as key for energy sector decarbonisation, and required for the investment in flex services and the coordination between sectors who rely on energy to meet their decarbonisation targets (water, transportation, built environment, industry).

IB1 supports sector-wide convening and governance to ensure digitalisation happens in a coordinated manner and can enable ‘whole system solutions,’ as promoted in RIIO-ED2 and realise the subsequent cost savings. IB1 supports Ofgem to continue to promote and finance whole system digitalisation coordination in RIIO-ED3.

As there are many ongoing data sharing and data governance initiatives e.g. consumer consent solution, flexibility services, Data Sharing Infrastructure (DSI), which are currently in progress at different stages of development (definition, prototype, or pilot). Ofgem should not expect these programmes and underlying challenges the projects aim to solve to be resolved by the end of RIIO-ED3 (2031). Data sharing and data governance needs and subsequent solutions will evolve over time as we continue to electrify and connect the UK’s grid. As mentioned above, Ofgem needs to ensure ongoing governance and sector collaboration on data and digitalisation – reinforcement of this would be welcomed in addition to specific plans to expand/evolve data governance initiatives.

With the progress of the Data Sharing Infrastructure (DSI) programme, IB1 anticipates ‘Shared Data’ sharing will evolve and will inform the evolution of data best practice (DBP) guidance. In particular, as data sharing scales, the need to standardise and harmonise legal and technical approaches will become more pressing in order not to slow innovation and add unnecessary cost. IB1 recommends that DBP should include guidance around Shared Data within the triage processes and licensing decisions, highlighting the role of Shared Data Schemes (see OVQ37) to provide definitions that aid interoperability and maximise impact.  

OVQ37. Do you agree with our proposed approach to the DSI licence condition?

IB1 welcomes the energy industry collaborating and agreeing on data sharing. Through IB1’s Open Energy programme, we have co-designed the Energy Sector Trust Framework with sector stakeholders, including DNOs. Members are currently in the process of assuring their open data publication using the Assured Open Data Scheme governed by Open Energy. IB1 will continue to bring Open Energy learnings into the DSI development process. 

We encourage more clarity on what DSI ‘participation’ entails, including anticipated associated costs and funding. As mentioned in IB1’s response to DESNZ energy smart data scheme call for evidence, it is essential that a Trust Framework is viewed holistically – an entity incorporating technical, communications, engagement, legal and ongoing governance arrangements – rather than a technical solution. IB1 would recommend ‘participation’ in DSI is defined as being broader than operating data sharing nodes, including:

• In collaboration with stakeholders within and outside the energy sector:
  • Identifying and developing use cases
  • Designing technically- and legally- interoperable schemes
  • Agreeing, implementing and governing operational policies
  • Keeping in step with emerging trusted data approaches in other sectors of the economy, at home and abroad
• Articulating the amount of technical and non-technical work required for a Trust Framework 
• Articulating the role of consent and permissioning aligned with the 2025 Data (Use and Access) Act.
• Setting out the expected amount of resourcing including external and internal communications, executive support, legal resource, and skilled involvement in data governance and technical implementation

Our experience is based on establishing an energy sector data sharing programme through sector engagement (convening 100s of organisations and 500+ public webinar attendees) and governance processes (80+ Steering and Advisory Groups members) to develop operational services for search and access control. These are are now live and market-facing through the Energy Sector Trust Framework and Schemes, IB1 created, designed and developed Open Energy https://ib1.org/energy/ to provide three services:

1. Community: an expert network of professionals – the IB1 Constellation

2. Governance: co-design of data sharing Schemes using our Icebreaking process

3. Trust Services: An Energy Sector Trust Framework for Scheme implementation, covering Open Data, commercial Shared Data with pre-authorised access controls, and commercial Shared Data where access requires end-user permission/consent. In addition, Trust Services deliver search and assurability services. 

We recommend drawing upon this experience to both clearly and tightly define expectations for the DSI licence condition, and the roles of actors in the ecosystem (e.g. what is within the remit of regulators and code bodies, what could/should be precompetitive and what is open to commercial market competition).