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.

Date: 14 May 2026 10:00-11:30 BST

Location: Online

Co-Chairs: Charlotte Hillenbrand (IB1), Katy Woodward (United Utilities) and Josh Evans (Pennon Group) 

Secretariat: Icebreaker One 

Meeting Aims:

1. Create a clear set of recommendations for the SG members in regards to the upcoming outcomes
2. Endorse Q3 outcomes
3. Review and comment on the new website outline

Summary:

It was agreed that:

• A website testing group should be set up, with interested members invited to register by email.
• The outcomes for the two pillars would be presented as a high level summary to Steering Group:
  • Use Cases and Datasets this quarter will focus on aligning data standards for priority use cases, so members are ready for adoption and data publishing while keeping delivery as far as possible within Stream’s control.
  • Ecosystem this quarter will focus on strengthening Stream’s visibility and stakeholder engagement, including a refreshed web presence, to support the transition toward an independent entity.

It was noted that:

• Several Q2 outcomes have been deferred because they depend on external projects outside Stream’s control, including:
  • CReDO has clarified the scope but funding confirmation is still outstanding
  • CaSTCo – a response on next steps is still pending
• APR is making strong progress in Q2
• The data portal would remain on ESRI for now, while the website front end would be rebuilt separately.

It was discussed that:

• There is a tension between Stream’s convening role, which depends on external partners, and the need to set outcomes that are within Stream’s control.
• Future outcomes may need to focus more on readiness and responsiveness, rather than on external milestones.
• Website content and navigation should better show Stream’s value, services, products, governance, and impact.
• The distinction between active use cases and retrospective case studies was useful and should be reflected clearly on the website.

Next meeting: Thursday 25 June 2026 10:00-11:30 BST

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

These are confidential to the Advisory Group Members.

Date: Tuesday 19 May 2026 10:00-11:30 BST

Location: Online

Co-Chairs: Lucy Chambers (IB1); Katy Woodward (United Utilities)

Secretariat: Icebreaker One 

Meeting Aims

1. Understand the Open Data/EIR situation and agree how to work with EIR teams. 
2. Create a clear set of recommendations for the SG members in regards to the upcoming outcomes

Summary:

• It was agreed that:
  • The outcomes for the two pillars would be presented as a high level summary to Steering Group: 
    • Data Sharing Governance will focus on establishing a sector adopted, standardised data sharing governance framework and the implementation of it for one use case
    • Technology will focus on delivering the design phase of CWQM development and redesigning and deploying Stream’s new website.
• It was noted that:
  • Work relating to citizen science data with CaSTCo was reported as deferred due to delays on the project side.
  • Environmental Information Regulations (EIR) requests were perceived to be increasing across water companies.
  • The top EIR request themes for 2025 were reported as water quality and chemicals, wastewater and pollution events, assets and infrastructure, water resources, and requests relating to particular places, assets or incidents.
  • There was concern that Stream data may be generating additional requests, despite the intention that published data should reduce handling effort.
  • AI-generated requests may be contributing to increased request volume and complexity.
  • Users may have varying levels of data literacy, affecting their ability to interpret published datasets.
• It was discussed that:
  • A survey or engagement approach should be developed with EIR teams to understand whether requests are increasing, whether Stream is affecting volumes, and what support would help those teams.
  • Any survey should likely be short, standardized, and possibly complemented by face-to-face conversations.
  • Useful metrics could include request volumes, request handling times, whether requests were closed more quickly using Stream data, and whether requests were prompted by existing Stream datasets.
  • A more standardised industry approach to EIR requests may be worth exploring, while recognising that responses would still be managed by individual companies.

Next meeting: Tuesday 30 June 2026 10:00-11:30 BST

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

These are confidential to the Advisory Group Members.

Date: Monday 18 May 2026 13:00-15:00 BST

Location: online and in person

Co-Chairs: Gavin Starks (IB1); Adam Jackson (Innovate Finance)

Secretariat: IB1

Meeting Aims 

1. Review the emergent use cases and Perseus as a proof point
2. Agree on the go to market plan and addressable market
3. How to engage FCA to turn greenwashing regulation into an opportunity
4. Ensure our communications are consistent and reflect an agreed collective position

Summary:

• It was agreed that:
  • Perseus should continue its focus on ‘doing one thing well’ in 2026: delivering 5 SME case studies by the end of 2026.
  • The Q3 meeting (July 27th) will act as a key checkpoint ahead of the November meeting to assess whether year-end case study delivery is on track.
  • ‘Perseus for Domestic’ should be explored in a contained way so it does not distract from the core SME focus.
  • SG members should increase communications activity on Perseus, with IB1 providing tailored support, with priority outreach to identified members.
• It was noted that:
  • The Perseus member ecosystem now includes sufficient scope and reach to support an addressable market of over 1M UK SMEs.
  • At least one FSP is actively developing a higher-rate savings product tied to verified carbon intensity reductions: this is an example of live commercial product development within the membership.
  • Early FCA conversations are positive. IB1 has submitted a briefing note and will continue to engage.
  • Additional DOC members with governance or data expertise are requested.
• It was discussed that:
  • Perseus could be extended into domestic property use cases, particularly aligned to warm homes, retrofit and open property data. This could provide a timely collaboration between the Open Property Data Association, Open Banking Limited, and Perseus.
  • A blurred line exists between domestic and business energy use for home-based and hybrid-working SMEs, and there will be sensitivities around data sharing.
  • Perseus supports different strategic and communications priorities, including energy security and affordability, resilience, transition planning, adaptation and cost-reduction.
  • The incentives for SMEs will vary based on their circumstances (e.g. cheaper finance, preserved access to capital, lower reporting burden, and combinations of these).

Next meeting: Monday 27 July 2026 13:00-15:00 BST

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

These are confidential to the Steering Group Members.

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.

Date: 11 May 2026 11:00-11:45 BST

Location: online

Secretariat: IB1

Meeting Aims:

1. Orientate for 2026
2. Agree workshops
3. Review market based carbon accounting concept

Summary:

It was agreed that:

• The Perseus team will circulate endorsable statements reflecting the positive intent and direction discussed, for communication to members and escalation to the steering group.

It was noted that:

• The commercial workshop produced positive outcomes, with EDPs willing to work on commercial terms, CAPs ready to scale and integrate, and FSPs continuing to see an active market.
• There are specific areas where regulatory and government engagement could help reduce friction in the current landscape that Perseus can assist with.
• Progress has been made on identifying lighthouse SME customer case studies, with both FSPs and CAPs

It was discussed that:

• Narrow, targeted case studies are needed first to generate proof points before broader scaling across the community.
• Typical delivery timelines are around two to three months for relatively straightforward use cases and around six months for more advanced ones.
• Water could be a possible next area of focus, with the view that it may be more accessible than agriculture in the near term, while agriculture remains important but highly complex.
• Exploration of extending a version of Perseus to the domestic market should be taken forward to a briefing note stage.
• Future opportunities included broader application into reporting, Scope 3, credit ratings, insurance, asset management, pensions, and risk modelling, though these were framed as longer-term possibilities rather than immediate priorities and that a roadmap should be developed for them.

Next meeting: Monday 29 June 2026 10:00-11:30 BST

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

These are confidential to the Advisory 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

Date: 28 April 2026 10:00-10:45 BST

Location: online

Chair: Frank Wales

Secretariat: IB1

Meeting Aims:

1. Update on onboarding flows
2. Discuss coding agents in relation to onboarding
3. Discuss automated compliance monitoring

Summary:

It was agreed that:

• Participants to send example queries and desired time ranges so the sandbox can be configured to return realistic test data.
• IB1 technical team to investigate synthetic data resembling real consumption patterns, alongside a deterministic dataset for automated emissions testing.
• Coding agent practitioners within participant organisations to be identified for further input on tooling and workflow.

It was noted that:

• Complete demo CAP flow is now available in the example app, with step-by-step guides for both CAP and EDP implementations.
• Single-step directory enrollment in progress; full API access to the directory planned.
• The sandbox EDP currently returns only ~3 days of February data, insufficient for monthly, quarterly, and annual reporting cycles and pure random synthetic data triggers anomaly detection and is not viable for testing.
• A heartbeat service is already included in the Perseus spec to check endpoint liveness and certificate validity.
• No SLA is currently in place for the sandbox; this is expected to change in production.

It was discussed that:

• Publishing skills alongside Perseus APIs is likely to significantly lower the barrier to integration when using AI coding tools.
• Agent authentication is an open design question; current thinking favours re-authenticating agents at each workflow stage rather than carrying a persistent token.
• Machine-parseable error messages and a separate agent sandbox were identified as priorities for AI-assisted integration.
• Compliance monitoring and operational/performance monitoring should be treated as distinct activities.
• In a federated peer-to-peer architecture, misbehaviour may only be apparent at points of interaction between peers; consideration needed on whether clients should be able to flag anomalies centrally.
• SMEs are out of scope for the Consumer Consent Solution at launch but expected to be included shortly after; no significant technical blockers identified.

Next meeting: Tuesday 30 June 2026 10:00-11:00 BST

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

These are confidential to the Advisory Group Members.

Date: Tuesday 21 April 2026 10:00-12:00 BST

Location: online

Co-Chairs: Melissa Tallack (NWL); Gavin Starks (IB1)

Secretariat: IB1

Meeting Aims 

1. Confirm confidence in the given ecosystem maps and agree priority outreach
2. Review member feedback on the Data Sharing Working Group documents and discuss next steps
3. Discuss and endorse collaboration with the energy sector

Summary:

• It was agreed that:
  • If members endorse the proposal, Thames Water will formally join Stream as a member, achieving full national coverage across England, Wales and Scotland for the first time, which strengthens its position as it moves towards becoming an independent entity.
• It was noted that:
  • Six priority stakeholder groups have been identified for focused Q2 engagement, with environmental regulators receiving a clear consensus as the top priority.
  • An ecosystem stakeholder map has been developed to direct outreach activity, with a review cadence of at least every six months.
  • Success will be measured through a mix of quantitative metrics (newsletter sign-ups, LinkedIn followers, event attendance) and qualitative outcome indicators (advocacy behaviours, funding facilitation, adoption of Stream as the defacto data infrastructure).
  • Stream is looking to engage with the energy sector on data sharing interoperability, as part of existing cross-sector commitments within the current funding period.
• It was discussed that:
  • The qualitative success metrics for ecosystem engagement, while directionally correct, require further detail at the individual stakeholder level to avoid setting targets for their own sake or driving unintended behaviours.
  • Outreach responsibilities need to be distributed across the Stream membership rather than relying on a single voice.
  • The regulatory reform landscape presents a timely opportunity to establish Stream as the defacto data sharing infrastructure for the water sector.
  • Cross-sector interoperability with energy requires careful management to avoid constraining Stream’s pace of progress, with transparency and communication being key to maintaining alignment without creating dependencies.

Next meeting: Tuesday 2 June 2026 10:00-12:00 BST

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

These are confidential to the Steering Group Members.

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.

Date: 7 April 2026 10:00-11:30 BST

Location: Online

Co-Chairs: Lucy Chambers (IB1); Dan Slidel (Southern Water)

Secretariat: Icebreaker One 

Meeting Aims

1. Create clarity on the framework, infrastructure and processes needed for sharing data.
2. Review use case process and confirm whether there is room for improvement.

Summary:

• It was noted that:
  • NESO is conducting similar work on templated Data Sharing Agreements, for interoperability purposes, Stream should endeavour to collaborate at some point.
  • The Working Group has developed early outputs to support data sharing, including a decision tree and an initial view of required templates and modules.
  • The work has been informed by a legal and risk‑based perspective, recognising varying sensitivity and risk across data sharing scenarios.
  • A revised use case process map was presented, intended to provide clearer expectations, support varied use case entry points, and remain adaptable as understanding matures.
• It was discussed that:
  • Widening participation in the Data Sharing Working Group is essential to diversify inputs.
  • A one‑size‑fits-all approach to data sharing agreements is not appropriate, and that a modular, templated approach may better accommodate different use cases.
  • Decision‑making tools should be usable by non‑legal stakeholders, while enabling appropriate escalation to legal, governance and compliance functions.
  • Reducing friction in data sharing requires attention beyond legal agreements, including identity management, audit and enforcement, data quality, infrastructure security, and organisational buy‑in.
  • Data ownership should sit with business leads, supported by legal oversight rather than led by legal teams alone.
  • There is a need to clarify what should be handled centrally versus individually by member organisations.
  • There’s a need for clearer decision rights and escalation, more effective prioritisation, and explicit consideration of funding, resourcing and capacity constraints within an agile use case process.
  • Members need better visibility of the pipeline and roadmap to understand what is coming, what is committed, and when.
  • The process should include a post‑delivery review to assess whether use cases delivered value and what was learned.

Next meeting: Tuesday 19 May 2026 10:00-11:30 BST

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

These are confidential to the Advisory Group Members.

Date: 2 April 2026 10:00-11:30 BST

Location: Online

Co-Chairs: Charlotte Hillenbrand (IB1), Katy Woodward (United Utilities) and Josh Evans (Pennon Group) 

Secretariat: Icebreaker One 

Meeting Aims

1. Reviewing the use case template plus endorsement 
2. Review and discuss the ecosystem map 
3. Update members on use case status

Summary

• It was agreed that:
  • The WEC use case needed formal approval from members to take to the Steering Group.
• It was noted that:
  • All outcomes are now published on the Stream website. 
  • The stakeholder map is intended to be a live tool, reviewed and refined over time rather than fixed. 
  • Welsh, Scottish (and potentially Northern Ireland) regulators were identified as missing and should be added to the stakeholder map. 
  • Both Stream team capacity and member capacity were recognised as constraints when sequencing activity (particularly use cases). 
  • It is important that we measure the impact of what we’re doing, looking at outcomes and quantitative targets for the activity level. 
  • Each stakeholder will be assigned to a desired outcome: high levels of advocacy, integration of Stream into their ways of working (such as with DEFRA), facilitate access to sources of funding, and recognise and adopt Stream as the de facto data sharing infrastructure.
  • Independent innovators should be considered in the wider ecosystem map.
• It was discussed that:
  • The priorities of the group might be skewed towards the government/regulatory group, rather than the representative of the wider water industry but this may be influenced by the Water Sector reform over the next two years. 
  • Stream could look to the EU for research and data sharing opportunities.
  • Stream’s role may increasingly be one of coordination, rather than delivery alone.

Next meeting: Thursday 14 May 2026 10:00-11:30 BST

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

These are confidential to the Advisory Group Members.

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.

As Perseus co-chair, members, stakeholders, and the broader community tell me that it is seen as a pioneering initiative, with a significant scale of opportunity (at least £5B+ in embedded sustainable finance), but there are still challenges in communicating what it is, and isn’t, and ‘why now?’.

“Collaborate on the rules, compete in the game.”

The course is set, now it’s time to shape how value is realised

Perseus is now recognised as a flagship exemplar under the UK Data (Use and Access) Act, supported by both the Smart Data Council (in its Smart Data Strategy for 2035) and the Net Zero Council. The regulatory current is moving in this direction, and the Perseus team is both in constructive conversations with regulators and code bodies, and at the table in creating the UK Smart Data guidebook. 

Perseus Members are defining where the rules of embedded sustainable finance are being written. The question isn’t whether this infrastructure gets built, it’s who helps shape it, and who arrives late.

To help better position what Perseus is, here are some of my reflections, based on 300+ conversations.

Getting the data to do the work: SME impact at market scale

SMEs are where the impact is needed (they are half of UK business emissions). For the vast majority, carbon reporting is a burden: manual, confusing, inconsistent, and disconnected from anything that actually helps them run their business better. 

Perseus flips this: with the SME’s permission, their energy data flows automatically into their accounting platform and to their lender. No spreadsheets, no data entry, no consultants: they get a verified emissions baseline, access to sustainable finance products they can’t easily reach, and a credible sustainability story they can use with their own customers and suppliers. 

Perseus meets them where they are, through the tools and relationships they already have, and costs them almost nothing to participate. Reducing friction and cost is the point of good data infrastructure, getting smart data to do the work so the SME gets the benefits, and the market gets the scale. 

Perseus is infrastructure, not a product

Most responses to addressing SME carbon emissions follow a familiar playbook: build an app, sign up users, grow a dataset, and sell reporting services. Some go further and package insights as a commercial proposition. Both hit the same ceiling: they create value for their own customers, but they don’t change the market.

“Carbon reporting can often be seen as a random number generator linked to compliance, not value.”

Data silos are no longer business moats

When data stays siloed and calculations stay inconsistent, every bank, accountant, lender, software provider keeps solving the same problem independently, at their own cost. Multiply that across the whole economy and you have a colossal, systemic waste of time and money: with no true comparability, little trust, and no efficiency of scale. As one senior expert put it, “it’s a random number generator linked to compliance, not value“.

“Perseus meets SMEs where they are, through the tools and relationships they already have, and costs them almost nothing to participate.”

Perseus takes a structurally different route (the same route Open Banking took). The design of Open Banking wasn’t to ‘make a better banking app’, it was that if you agree the rules by which data flows between any bank and any third party, every player in the market benefits simultaneously, and the infrastructure becomes self-reinforcing as more join.

Perseus applies exactly that logic to SME emissions data: not a pipe, not a platform, a Scheme. A Scheme is a shared rulebook that defines how the data flows, it is legally permissioned, technically assured, and provenance-stamped between energy data sources, carbon accountants, and lenders, regardless of which specific providers are involved.

Schemes are designed to ‘do as little as possible’ so that the heavy lifting that they do deliver, can deliver at scale. Perseus is not a database, or a calculator, or a portal. Instead it’s the trust layer that makes everyone else’s products work together, enables solutions to go to where the customer already is, and makes them credible due to the governance wrapped around its design.

“Perseus is not a database, or a calculator, or a portal. It’s the trust layer that makes everyone else’s products work together.”

No single organisation can build what Perseus builds collectively

Any carbon accounting platform can reach its existing customers, any energy data business can find organisations already looking for a data feed, any bank can bring these things together, but none of them can, on their own, shift the behaviour of 5.5 million SMEs and the financial system that serves them.

Perseus can because its Steering Group and commercial membership collectively represent the whole system: the banks, accountants, energy companies, trade associations, and SME platforms that already have the customer relationships. The joint communications that can flow from this coalition don’t just amplify awareness, or make ‘business today’ more efficient, it creates an addressable market that didn’t previously exist. By going far together, they can all reach SMEs who have never considered net zero was for them, through channels they already trust: their bank, their accountant, their software tools, and their trade association. Perseus is creating a route to market no individual organisation can replicate through its own sales effort, and this is estimated to be £5B-£10B by 2030 (see 2025 annual report).

Its benefits can compound in both directions: automating data flows that currently require manual effort, reducing the cost of compliance, reducing friction at every point in the chain and building customer trust not for one product, but at market scale.

“Perseus Members are defining where the rules of embedded sustainable finance are being written. The question isn’t whether this infrastructure gets built, it’s who helps shape it, and who arrives late.”

The value case for a Financial Services Provider (e.g. bank, lender)

There are reasonable objections a bank or lender might raise. Right now, Perseus is a UK SME Scheme, not where the biggest financed emissions numbers sit for most large institutions; they may have existing bilateral data arrangements they’re reluctant to revisit; and in a climate where public sustainability commitments are under scrutiny anything that looks ‘new’ can face internal resistance. 

These are valid questions, but they don’t change the underlying logic.

In impact, most initiatives measure engagement, they rarely measure or report on verifiable impact. Perseus enables continuous, assurable measurement, reporting and verification of impact. By harmonising the approach, the reporting is comparable across organisations.

On scale: the UK SME market is not a rounding error but half of all UK business emissions. Any lender with a material SME book has a financed emissions reporting problem that carries sufficient risk to increase their cost of capital. Perseus addresses this across the whole market at once. Perseus Members have indicated that ‘just’ energy (electricity and gas) addresses over 70% of their use cases, and the programme is designed to expand beyond energy based on Member needs (e.g. water). If we go far together, our collective impact is material and meaningful.

On existing bilateral arrangements: Perseus doesn’t replace them, it improves them through harmonisation of approach, liability and technical provenance. Joining doesn’t unwind existing relationships, rather it gives them an additional trust layer, aligned with the Data Act and endorsed by the Net Zero Council.

On the commitment: Perseus is not a ‘climate pledge’, but an action to deliver the data infrastructure for embedded sustainable finance. Operationally, it’s equivalent to joining any financial data scheme – a technical and commercial decision, not a public statement about net zero ambition. It supports diverse go-to-market impact messaging across cost savings, energy efficiency, energy security, net zero and transition planning. It’s not a campaigning approach, but rather a way to deliver measurable value to the market.

“Any lender with a material SME book has a financed emissions reporting problem that carries sufficient risk to increase their cost of capital.”

On governance and legal overhead: Perseus’ architecture is deliberately modelled on Open Banking. Its legal agreements, certificate infrastructure and KYC processes are designed to align with what regulated financial institutions already do (the path through legal and compliance is not trivial, but it is well-trodden).

Ultimately, the financial providers already in Perseus are sitting in the room where the rules of sustainable finance data infrastructure are being written. It is a choice to be a late adopter of a model that Perseus members helped design, for a membership fee and some internal process. The cost of joining later is accepting the rules written by others.

The value case for a Carbon Accounting Providers (whether financial or carbon management)

A CAP might ask: why do we need Perseus? (we already have integrations with energy data providers, have bank and lender customers, and are building the product that does this).

These are fair points, but miss what Perseus is.

“Perseus is not a database, or a calculator, or a portal. It’s the trust layer that makes everyone else’s products work together.”

Every CAP currently solving this problem is solving it alone: each has negotiated its own data access arrangements, built its own ingestion pipelines, made its own judgements about data quality, and written its own terms. The result is a market where every emissions calculation is done differently, every audit trail looks different, and no two outputs are directly comparable. That’s not a CAP problem to fix, it is a market structure problem, and no single CAP can fix market structure.

This has been the case for decades. Now the baseline calculation needs to become pre-competitive infrastructure (co-designed and delivered by the market) so that CAPs can compete on the value they build on top of it.

Collaborate on the rules, compete in the game

Perseus addresses this by establishing a common trust layer (common legal agreements, provenance standards, assurance levels, harmonised calculations) so that data flowing into any Perseus-connected CAP is verified, traceable, and comparable to data flowing into every other. This doesn’t commoditise the CAP’s product, but rather makes the CAP’s product something an SME or bank can actually rely on, report against, and put in front of an auditor with confidence.

On distribution: joining Perseus is not just a technical integration but access to a network of lenders, trade associations and SME platforms that collectively reach the entire UK SME market. This is a route to market no CAP can replicate through its own commercial efforts. Perseus-connected CAPs are not just selling software but access to a trusted, standards-aligned data flow that their competitors outside the scheme cannot match.

On the competitive question: the CAPs already building Perseus integrations reach hundreds of thousands of UK SMEs today. They are not waiting before positioning themselves within it. Waiting until Perseus is ‘already proven’ before engaging will find the integrations, the relationships, and the market positioning is already occupied.

On effort: Perseus adds a compliance overhead, but this is inversely proportional to scale. The cost of integrating once (which can be done in under a month) with a common framework is substantially lower than maintaining multiple bespoke bilateral arrangements as the market grows. Perseus reduces long-run complexity, it doesn’t add to it.

Spend-based estimates or manually uploaded spreadsheets are no longer fit-for-purpose. Perseus provides the foundations that CAPs can build on top of, creates trust, defensibility, reduces long-term costs, increases market engagement and innovation.

To go far, we go together.

Join Perseus today

Date: 26 March 2026 10:00-10:45 GMT

Location: online

Co-Chairs: Laura Townshend, (IB1); Zarina Banu, (Tide)

Secretariat: IB1

Meeting Aims:

1. Update on case studies
2. Discuss upcoming actions
3. Review Vision statement

It was agreed that:

• British Chambers of Commerce, FSB and IOD should be prioritised as strategic targets to help amplify comms due to their credibility, authority and member reach
• The updated Perseus’ vision and mission statement should be approved

It was noted that:

• Innovate Finance’s Global Summit is in April and panel opportunities on sustainable energy featuring Perseus maybe available
• London Climate Action Week takes place in June and IB1 has a cross-sector meetup planned
• One of the members has two potential SME contacts who might be able to contribute, both PR-ready having presented at the Houses of Parliament

It was discussed that:

• The geopolitical context presents a timely opportunity to amplify Perseus messaging, particularly around energy sovereignty, the government’s consideration of decoupling gas/electric price caps, and the cost of living crisis
• Small businesses are being significantly impacted by energy costs, national insurance increases, minimum wage changes and inflation, making Perseus a relevant operational efficiency solution
• In order to achieve amplification, there is a need to identify the right internal spokespeople within steering group member organisations, not just the steering group representatives themselves

Next meeting: Thursday 28 May 2026 10:00-10:45 BST

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

These are confidential to the Advisory Group Members.