We recently caught up with Matteo Deidda, Global Net Zero Lead at Tide, in the same week that UNEP released its latest report warning that the world is on course to overshoot the 1.5°C target.

It set the context for our conversation and reinforced a point that came up throughout: the need for climate action and adaptation isn’t going away. If anything, it is becoming more embedded in the way businesses think about risk, opportunity and long-term resilience.

“Corporate advocacy towards net zero has certainly changed in recent years, but I don’t think action has diminished.”

For Matteo, sustainability has increasingly become part of the fabric of businesses, moving into their risk portfolios, processes and commercial opportunities.

“I often look at sustainability as the plumbing. The plumbing in a house isn’t always visible, but it is integral. It’s the plumbing that stays.” 

Sustainability needs to be seen as part of the underlying infrastructure of a business. For more on this: explore our thinking on Perseus as infrastructure

5.5 million different challenges 

Matteo has worked in corporate sustainability for the last 15 years, starting out as an energy manager before moving into broader sustainability roles. For the past seven years, he has focused more heavily on the finance sector, which he sees as a key unlock for sustainability, particularly because of its reach into the SME market.

Through working with SMEs, Matteo has understood that we can’t approach SMEs as one bucket with the same needs and goals:

“There are over 5.5 million SMEs in the UK, with a large proportion of these being microbusinesses. That’s 5.5 million businesses with 5.5 million different challenges. It’s important that we don’t think that we know best for SMEs because it’s not a one size fits all problem.”  

Meeting SMEs where they are

SMEs are particularly exposed to climate-related disruption and price shocks. (Read our blog on gas price shocks and Perseus.) But helping SMEs isn’t simply about giving them more information, it means meeting businesses where they are and understanding what they actually need.

For many smaller businesses, understanding the complexities of net zero, sustainability and decarbonisation, and what this means for their business, requires time and resources that they simply don’t have.

“Even if their value system aligns with sustainability, which in many cases it does, they just don’t have the time and resources to  act on it. Fundamentally, what drives them is value, and that value comes in different forms: customer acquisition, reducing cost, improving cash flow and more.”

This is where practical action and climate adaptation measures can play a central role, as these can directly lead to lower costs, increased resilience, more energy efficient buildings and more reliable access to energy.

“I think in the future we will talk more about adaptation and what that means for people and business. Heat pumps, solar panels, getting help to switch to a better energy supplier, improving building energy performance, all these things are part of the adaptation we need.”

Perseus: a framework for change 

Finance isn’t the end goal for every SME; many simply aren’t at that stage. Their priorities might be understanding their data better or negotiating a better contract with an energy supplier. What Perseus offers is the shared data infrastructure that can underpin all of this. 

But what Matteo truly admires about Perseus, and the work of every member involved, is its power to create material change, as it aims to unlock sustainability reporting for every UK SME. 

“Perseus has managed to build a framework for change and innovation by keeping the right people at the table. There is still a lot of work to do, but it has already delivered visibility in the political, economic and business environment in the UK.” 

About Tide

Tide is an all-in-one business management platform designed to save small and medium-sized enterprises (SMEs) time and money on their day-to-day operations. Today, Tide supports over 2 million members across the UK, India, Germany, and France as it continues its expansion toward becoming the world’s premier business management platform.

The tl;dr is it’s looking at a slimmer strategic report: most of the current non-financial disclosure requirements would go, replaced by a shorter set of baseline narrative disclosures, and topics such as environmental impact would only need to be reported where they are financially material.

This matters to anyone who relies on comparable sustainability data: investors, lenders, insurers, supply-chain teams and the SMEs that sit at the end of supply chains. It matters to Perseus as its purpose is to make the data behind emissions reporting easy to share and easy to trust. So, is this good or bad for Perseus? On balance we think this could have a positive impact on Perseus.

What the government is proposing

The consultation covers a lot of ground, but most relevant to sustainability data includes:

• Removing explicit strategic report requirements on environmental matters, employees and diversity, social responsibility, community engagement, human rights, and anti-bribery. Companies would still report on these where they are financially material (ed: one could reasonably suggest that many matters carry financial materiality across the entire economy).
• Testing a single new ‘very large’ company threshold to simplify which companies carry non-financial reporting obligations.
• Asking whether private companies should carry any non-financial reporting obligations at all.
• Letting companies choose where sustainability information sits within the strategic report.
• Considering how the new UK Sustainability Reporting Standards (UK SRS) should be reflected in the Companies Act 2006.

One thing is not changing: existing climate-related financial disclosure requirements stay in place. The government is reviewing them separately, with a conclusion expected by Spring 2027. In parallel, the Financial Conduct Authority (FCA) is consulting on mandatory UK SRS reporting for listed companies.

SME realities are not addressed

The report has a large-company focus and most SMEs sit below its thresholds. However, this does not mean that SMEs are untouched by reporting rules: they feel them second-hand.

ACCA and UK Finance’s recent white paper, Measure what matters, sets out how SMEs respond reactively to sustainability data requests that trickle down supply chains from regulation designed for large organisations and financial services. Requests arrive from multiple customers and lenders in different formats (this directly echoes Perseus’ research).

Half of ACCA’s roundtable participants named lack of standardisation as the biggest obstacle to digital data collection by SMEs, and half named unclear business benefit (a quarter said they do not collect data digitally at all). This further echoes Federation of Small Businesses research that 74% of SMEs simply do not understand the terms Scope 1, 2 and 3.

So, the consultation’s proposals will change what large companies disclose in their annual reports, but they will not change the demand for SME data that flows through supply chains and lending books, and they do nothing to fix the fragmentation that ACCA and FSB highlight. If anything, moving from explicit topic requirements to a ‘materiality judgements’ gives large companies more latitude to ask its suppliers for what it thinks it needs: without shared standards, this could mean more variation, not less.

What does this mean for sustainability data?

We see three potential shifts:

1. a narrowing of ESG transparency. Fewer companies will be required to report on fewer topics and anyone who depends on comparable disclosures, from lenders to supply-chain due diligence teams will see gaps.
2. a decisive shift toward financial materiality. This aligns the UK with the IFRS and ISSB approach and moves it away from the double-materiality model in the EU’s Corporate Sustainability Reporting Directive (CSRD). This could reduce domestic burden but it may also create friction for UK groups operating in EU markets.
3. a risk of a two-tier information landscape. Where mandatory disclosure recedes, voluntary and investor-driven disclosure will fill the gap, but it will do so unevenly and SMEs are likely to carry the cost of that unevenness.

Taken together, these shifts strengthen the case for standards-based, machine-readable reporting rails. If ‘financially material’ is the test, then the data that passes it needs to be discoverable, comparable and assured. If not it will fragment across bespoke company formats, and differing interpretations of reporting frameworks. The ACCA’s recommendations point in the same direction: standardised frameworks and collection methods, open standards developed bottom-up with technology providers, and data collection that accounts for business size and structure, rather than just sector alone.

What does this mean for Perseus?

On balance, we see this as broadly neutral to positive, with some second-order risks to be considered.

The core demand driver for Perseus is unchanged. Banks and financial service providers still need assurable Scope 2 data from their SME customers to produce their own Scope 3 Category 15 (financed emissions) reporting: the consultation leaves climate-related financial disclosure requirements untouched. UK SRS is moving ahead through the FCA, and Perseus is already aligned with the ISSB approach through PCAF and the GHG Protocol. The ACCA paper reinforces this from the lending side with the Prudential Regulation Authority’s SS5/25 expecting banks to identify, measure and monitor climate-related financial risk across their lending, and sustainability data is increasingly part of whether an SME qualifies for green loans, sustainability linked loans or preferential terms.

The shift to financial materiality reinforces the need for Perseus: decision-useful, financially material climate data is exactly what a standards-based data infrastructure delivers and government’s intent to reflect UK SRS in the Companies Act can support, and be supported by, the plumbing Perseus has already built.

ACCA’s findings also map closely onto what Perseus is designed to do:

• Standardisation and open standards. Perseus gives banks, SMEs, energy providers and application vendors one common implementation for consumption, tariff and carbon-intensity data, built on PCAF and the GHG Protocol and developed with members rather than imposed on them.
• Feedback loops. ACCA argues that value lies in closing the loop, so SMEs get insight and finance in return for data. Perseus automates the data flow from meter to application to bank so that personalised recommendations and green finance decisions can follow.
• Digital collection. A quarter of ACCA’s respondents do not collect data digitally: Perseus enables SMEs to automate the data flow by sourcing assured energy data direct from the meter/energy data providers.
• Trusted advisers. ACCA recommends reaching SMEs through accountants and membership bodies. Carbon accounting providers who are rolling out Perseus-enabled products can enable reach hundreds of thousands of UK SMEs.

The risks are indirect:

• Removing explicit environmental, community and human-rights reporting weakens the wider ESG-reporting efforts that support voluntary SME adoption and buy-side engagement.
• A new ‘very large’ threshold could shrink the number of reporters and push more of the SME data conversation into more voluntary and commercial territory.
• Perceptions of ‘dilution’ could undermine overall progress.

What will we do next?

The FSP demand that anchors the business case for Perseus remains, and the direction of travel towards more ISSB-style materiality and UK SRS strengthens the case for Perseus as the delivery mechanism. We need to pay attention to any softer signalling around SME and private-company disclosure.

We plan to respond to the consultation with a focus on making the case that reducing reporting burden and improving data quality are the same job, and that trusted, permissioned data sharing is how you achieve both. The ACCA white paper supports that case with a fresh evidence base, and its recommendations on standardisation, open standards and feedback loops are ones we will amplify.

If you work with SME sustainability data and want to contribute to our response, please get in touch at perseus@ib1.org.

Set among the boats and barges of a riverside pierhouse in London, Lloyds, Barclays, NatWest, British Business Bank, Tide, Santander and Unity Trust Bank came together over lunch to share ideas, challenges and opportunities. 

❮ ❯

Three themes stood out from the conversation:

1. “Perseus is like open banking for sustainability.”

Open Banking has already delivered an estimated £8.3bn for the UK economy, with the potential opportunity, once it reaches full maturity, estimated at £43bn per year.

Its success has come from giving consumers greater control over their financial data, enabling better financial management, creating productivity gains for businesses and improving access to finance.

The model at the heart of Open Banking is simple: your financial data stays with your bank, while authorised third parties can access it securely through standardised infrastructure. 

Perseus follows the same principles. 

Sustainability data can remain with the organisation that holds it,  whether that’s a utility, data provider, carbon accounting platform or smart meter provider, while authorised organisations can securely access it when they need to.

You don’t need to move all your data to one platform, and you don’t need to build the infrastructure yourself. Perseus provides the shared infrastructure that enables data to flow between organisations, unlocking new products and services and helping to realise its own £5–10bn opportunity in sustainable finance.

The parallels with Open Banking don’t end there. Perseus and Open Banking share many of the same users and stakeholders, and the project is exploring integration with Open Banking to enable greater cross-sector interoperability.

2. “If you're happy for us to access the data, you can use any Carbon Accounting Provider you choose.”

Open Banking doesn’t require everyone to use the same bank. You can bank with whoever you chose and still access third-party financial services.

Perseus works in the same way. It isn’t about choosing one platform or picking a ‘winner’. It’s about interoperability: allowing customers to use different providers while enabling data to flow securely between them.

Perseus demonstrates the value of an interoperable approach to smart data sharing, connecting energy data providers, carbon accounting platforms and financial service providers through common governance.

3. “Collaboration across the sector is the only viable path.”

Collaboration is the business model.

Icebreaker One’s governance structure is designed to enable that collaboration. It gives members the opportunity to shape how Perseus is built and who it benefits. 

By bringing members together through Advisory Groups, Steering Groups and an independent Delivery Oversight Committee, Perseus creates a collaborative, and precompetitive environment, all crucial elements to help develop the UK’s first cross-sector Smart Data Scheme. 

The alternative is individual organisations building proprietary approaches and contributing to the creation of a fragmented ecosystem. Instead, Perseus provides shared infrastructure that gives FSPs the opportunity to experiment, innovate and develop new services, while reducing duplicated effort.

Get involved now: if you want to be one of the members shaping the future of Perseus and sustainable finance, join now. 

Overview

The UK is committing £15 billion of public and government-backed finance to decarbonising its homes through the Warm Homes Plan, with the main lending window opening in April 2027.

Lenders, government, and households are, however, generally working from modelled EPC estimates rather than real performance data. Perseus, the UK’s leading cross-sector Smart Data Scheme (convened by IB1), already enables smart meter data to flow through to carbon accounting providers, and on to lenders, with permission. Designed for scale, Perseus has indicated there is a £5-10B addressable market with over one million UK SMEs addressable. P4D could extend the same mechanism to twenty million homes.

We seek expressions of interest to explore convening a coalition that spans market actors including, but not limited to: banks, energy (and related) data providers, proptech, consent and identity infrastructure providers (e.g. RECCo’s Consumer Consent Solution), property data bodies (e.g. Open Property Data Association), carbon accounting providers, retrofit and low carbon technology installers, local authorities, and government departments. The coalition will design and deliver P4D as trusted Smart Data infrastructure for domestic energy transition finance.

The proposed programme is aligned with the UK’s Smart Data Strategy for 2035, the Data (Use and Access) Act 2025, GDPR, and Ofgem’s Consumer Consent Solution, which launches for domestic smart meter data in 2027. OPDA currently also lead the DPMSG delivery workstream for Smart Property Data and their standards already support the use of digital property packs on homebuying transactions.

The challenge

The Warm Homes Plan targets decarbonising the UK’s domestic building stock. The challenge is large and complex, spanning installation of low carbon technologies and smart control systems, building fabric and insulation retrofit, and group interventions such as street-level decarbonisation, district heating, and community energy. While the Warm Homes Plan provides a significant finance intervention, gaps remain. For example, even where households are eligible for direct funding, there are often additional costs which exceed the grant (e.g. plumbing, radiator, and electrical work accompanying a heat pump installation). Additionally, avenues to finance for middle income households and group-scale interventions remain patchy. 

Closing these gaps requires private finance at scale, delivered by multiple lenders competing on better terms, evidenced in business-relevant timeframes. The data infrastructure to support this does not yet exist for the domestic market.

How P4D could work

Perseus has already proven the mechanism for SMEs. P4D could add three components for the domestic market:

1) trusted, assurable consumer data access and consent management; and,

2) a property data layer that links meter data to the building, its characteristics, and its retrofit history.

3) greater consumer transparency, confidence and control when making property transaction, lifecycle, and finance decisions

Building upon the existing Perseus framework, this could create a complete chain from a household’s actual energy performance to a lender’s underwriting decision that is robustly permissioned, assurable, and aligned with the Consumer Consent Solution.

What it could deliver

Lenders would gain a verified underwriting signal, portfolio-level PCAF-aligned reporting, and lower-friction origination through a regulatory-aligned infrastructure.

The Warm Homes Agency and the departments backing the Plan would gain ‘relevant-time’ visibility of carbon impact across funded and unfunded measures, the ability to steer the programme on evidence rather than on lagging survey data, and an auditable link between public investment and outcomes.

Consumers would gain a verified picture of their home performance, simpler access to better-priced finance, control and transparency over their data, and recognition of impact from behavioural change, smart tariff uptake, and privately funded improvements alongside subsidised installations.

Working together, we aim to help align around data ontology models, deliver practical application of existing open API standards, and cross-sector federation of trust, so that consumers can safely share their property, energy, water, and related data for use cases that deliver value to them

How to participate

IB1 operates as a neutral, not-for-profit orchestrator for data sharing. Any Scheme rules are co-designed with participants through its established governance process, and all outputs are published under open, reusable licences. Organisations can engage as design partners shaping the Scheme rules, choices of data standards, as pilot participants in live data flows and consent programmes, or as observers of the evidence outputs and open specifications.

Submit your expression of interest or contact partners@ib1.org 

Meeting Aims 

1. Update on the roadmap, AGs and DOC
2. Discuss engagement and tactics for Perseus
3. Plan a 2026 gathering

Summary:

• It was agreed that:
  • Five live case studies remain the year-end delivery target.
  • The Perseus for Domestic briefing note will be circulated
  • Innovation workshops with individual members will be explored as a complement to the top-down engagement approach.
  • AG4 will build a joined-up coalition narrative, including what it means for end customers
• It was noted that:
  • Xero has joined as a new member alongside Intuit and Sage, giving the ecosystem combined reach to over 1 million SMEs.
  • 2026 roadmap milestones are broadly on track, albeit with FSP case studies slow, but progress is being made. Q3 priorities include agreeing interoperability with Open Banking.
  • Palace of Westminster events are planned for the autumn with a sponsor secured: a build-up session in a committee room and a larger terrace event.
  • AG1 highlighted the need to resolve marketing permissions, embed finance where the customer is, and consider energy intensity as a metric.
  • AG2 highlighted sandbox improvements, better synthetic data, member-contributed datasets, and a planned autumn developer meetup focused on AI-assisted integration.
  • AG4 highlighted the need to demonstrate short-term value to members, tailor communications to different organisational priorities, and better articulate non-product value.
  • The DOC highlighted that Perseus’ financial outlook for 2026 has been revised down again, as membership commitments in principle are converting slowly to paid invoices. Prioritisation is ensuring core delivery is on track and the Perseus team is focusing on helping members deliver use cases.
• It was discussed that:
  • Identifying advanced, specific SME users who could champion Perseus use cases, would complement top-down institutional messaging with bottom-up engagement.
  • Messaging should lead with opportunity and optimism. There is scope to interlock with the Climate Hub’s existing “grow, save costs, be resilient” framing.
  • Members imagining the counter-outcome: without Perseus reaching scale, sustainable finance risks will fail to reach mass market.
  • ‘Perseus for Domestic’ could align with the Warm Homes Initiative, this is at a coalition-building and political alignment stage.

Next meeting: Monday 2 November 2026 13:00-15:00 BST

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

These are confidential to the Steering Group Members.

With over 5 million customers worldwide, Xero is a leader in cloud accounting across New Zealand, Australia and the UK, bringing valuable expertise in supporting SMEs through connected digital tools and services.

As part of Perseus, Xero will contribute to a coalition of like-minded industry leaders exploring how trusted, interoperable data-sharing can simplify sustainability reporting for SMEs. With Perseus targeting a £5–10bn opportunity in embedded sustainable finance, the collaboration reflects the wider evolution of Smart Data and Open Finance in the UK and beyond, creating more connected, efficient ways for organisations and individuals to share and use data securely.

“Project Perseus is a practical example of how Smart Data can solve real problems for small businesses. Xero sees value in work that helps create trusted, interoperable approaches to emissions and sustainability data, making reporting simpler and helping build stronger foundations for better access to finance and future Open Finance innovation.”

Stuart Miller
Director, Public Policy & Technology Research, Xero

Meeting Aims:

1. Identify how comms and engagement work can position Perseus as essential to members
2. Identify milestones and comms moments in H2

Summary:

• It was agreed that:
  • IB1 should review member communications with a view to providing more regular, digestible, value-oriented summaries for members.
  • The group should better package engagement value for members, including parliamentary events, reports, and roundtables, so value is not framed only through technical progress.
  • The group should explore convening members to discuss how they maintain internal engagement and what support helps them make the case for Perseus internally.
• It was noted that:
  • The internal case for sustainability initiatives has become harder over the past 3–4 years, with executives sometimes finding reasons not to engage.
  • Members need to see short-term value from Perseus, such as visibility, knowledge, and connection, rather than only a long-term proposition.
  • The value case for Perseus needs to be calibrated to each member organisation’s priorities, which differ across firms.
• It was discussed that:
  • Perseus should position itself as business-critical and “must-have” for members.
  • There is a need for Perseus to equip members to sell the proposition internally with evidence of immediate value and organisation-specific messaging.
  • Perseus could seek to build more external prestige. Co-branding with members’ research, events, and outputs might help.
  • Perseus-convened roundtables with micro-businesses were a practical benefit for many members.

Next meeting: Thursday 8th October 2026 10:00-10:40 BST

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

These are confidential to the Advisory Group Members.

Meeting Aims:

1. Illustrate the SME journey to a loan 
2. Update members on FCA and Perseus for Domestic discussions
3. Endorse initiative to reduce friction for SMEs to prove their address 

Summary:

It was agreed that:

• Immediate focus remains on real-world SME case studies and proving that banks can implement Perseus with their customers.
• While the business case for Perseus is clear (as per 2024 and 2025 annual reports), the internal investment cases must show material progress from the Perseus Members
• The Secretariat will continue to engage with the FCA, including preparing an updated briefing note on the potential impact of regulatory clarification.
• A working group will be formed to explore ways to streamline SME smart data access.

It was noted that:

• Perseus has been featured in DBT’s Smart Data Strategy. Discussions with DBT are positive and ongoing.
• The FCA has indicated that it can explore the potential of becoming an observer on the Perseus SG.
• From a measurement methodology perspective, there is a need for a minimum-viable, harmonised carbon intensity metric (potentially linked to revenue or EBITDA) that would meet baselining needs, but not compete with existing industry and commercial scoring models.

It was discussed that:

• From a regulatory perspective, a tension has been identified between the potential interpretation of FCA rules and banks’ perceived ability to proactively reach out to customers on climate finance. Members discussed the potential  impacting of this on the perceived size of the addressable market. This discussion helped frame inputs into the briefing note.
• From an impact perspective, smart meter data could support broader customer engagement: nudges, insights, and efficiency recommendations, not just finance offers.
• From an opportunity perspective, there is potential for Perseus (for SMEs) to expand into the domestic market (Perseus for Domestic), potential links with the Warm Homes Plan.

Next meeting: Monday 12 October 2026 10:00-11:30 BST

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

These are confidential to the Advisory Group Members.

Meeting Aims:

1. Discuss member requirements for synthetic data in the Perseus sandbox
2. Evaluate what requirements existing for sandbox testing
3. Introduce and get feedback on the idea of a dev meetup

Summary:

It was agreed that:

• The Perseus team will formalise the existing readiness-check component into something members can use to demonstrate their integration is tested and working, building on roadmap work already under way.
• an autumn session will be organised, potentially in hackathon format, exploring how the sandbox could support AI coding agents and establishing what currently works.
• AG2 will set up a working group to design a structured approach for extending organisation role information held in the Directory, such as what data an energy data provider can supply.

It was noted that:

• The sandbox exists to let members verify their integration, build confidence ahead of live deployment, and test what cannot be tested in isolation, including correct handling of error responses. Out of scope: simulating system failures, load and performance testing, and standard authentication flows already covered elsewhere.
• Several candidate synthetic data sets exist: the Centre for Net Zero’s Faraday V5 (fully synthetic, modelled on real consumption with property and location parameters), the London Datastore (smaller, built to compare tariff changes), and Open Power System Data (domestic and small business consumption, though needing adaptation for Perseus).

It was discussed that:

• Smart data sharing is front of mind for one member, who described the market as blocked and in need of help to move forward.
• The suggestion that progress requires ICO enforcement or new legislation was not considered to be the best solution, as it relies on intervention from outside the market rather than action within it.
• Data protection uncertainty is often used as a reason to avoid progress altogether. Greater assurance on this point could remove a common blocker to engagement.
• There are concerns that RECCo’s purpose-agnostic approach to data sharing sits in tension with GDPR principles on the scope of permission granted.

Next meeting: Tuesday 6 October 2026 10:00-11:00 BST

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

These are confidential to the Advisory Group Members.

Meeting Aims:

1. Discuss proposed SG member communication support
2. Gather AG4 advice and feedback on how to communicate the Perseus legal contract to members

It was agreed that:

• IB1 will revise the legal scheme structure slides to reflect the feedback from the group on the communications framing for the Perseus legal contract discussion.
• The revised version of the deck will be shared as an update at the next meeting rather than returning to this group for further review.
• The July meeting should be moved later in the month, extended to one hour, and positioned as a pre-summer wrap-up, with no meeting to be held in August.

It was noted that:

• Progress had been made in refining the approach to SG member engagement, including a shift from a one-size-fits-all approach to a more bespoke model of support for target organisations.
• The priority SG member targets remain the Federation of Small Businesses, British Chambers of Commerce, and Institute of Directors, reflecting their broad reach across UK business audiences.
• The legal contract communications material is intended to support more than one audience, including legal teams and wider senior or operational stakeholders within member organizations.
• The current visual presentation of the legal contract content appeared process-heavy and may be difficult for non-technical audiences to navigate.

It was discussed that:

• Efforts to mobilise SG members to use their voice to endorse and credentialise Perseus were underway, including the intention to produce tailored one-page briefs and build stronger relationships with communications teams over the summer.
• While legal review is an important part of the process, the broader value proposition for organisations lies in the opportunity to influence rules, implementation, and future scheme development.
• Communications materials should lead more clearly with the “why” and intended outcome, with clearer explanation of component parts and less reliance on process-led diagrams.
• Whether communications could be strengthened through references to existing precedents such as open banking, smart data schemes, and wider government direction of travel.

Next meeting: Thursday July 9th 2026 10:00-11:00 BST

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

These are confidential to the Advisory Group Members.

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.

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.

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.

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

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.

Meeting Aims 

1. Agree on updated vision and mission
2. Understand 2026 roadmap
3. Update on DOC and AG
4. Commit to amplifying case studies
5. Identify funding sources

Summary:

• It was agreed that:
  • Case studies are the critical success metric for 2026. The ambition is to secure at least five examples that demonstrate real-world application.
  • Alignment with the Net Zero Council and the Smart Data Council agenda should continue, positioning Perseus as an exemplar of Smart Data implementation and Net Zero innovation.
• It was noted that:
  • The 2025 AGM reflected strong engagement from key stakeholders and financial service providers (including incumbents NatWest, Barclays and Lloyds and challenger banks).
  • Language has evolved to “embedded sustainable finance”, with continued emphasis on SME impact.
  • Sandbox learnings (AG2) identified and resolved integration challenges (e.g. with certificate authentication, improved documentation and clarity of roles, setup guides, tooling and specifications have been developed in response).
  • Legal updates (AG3) incorporate gas into permission text, clarify CAP-initiated (two-click) and FSP-initiated (single-click) consent journeys; Scheme agreement documentation has been consolidated; changes remain compliant with prior external legal advice.
  • Annual renewals remain the current funding model, with forecast renewals on track but cashflow risk recognised and multi-annual renewals should be considered.
  • The relationship with B4NZ (formerly ‘Bankers for Net Zero’) was recognised as having been supportive in the formation of the programme, and there is no ongoing relationship with that initiative.
  • Adam Jackson has accepted the role of DOC Chair.
• It was discussed that:
  • The proposed new vision, “Embedded sustainable finance for SMEs”, provides a clear and memorable direction of travel. Further refinement of mission language will be considered to ensure terminology resonates with SMEs.
  • The SME focus remains strategically valuable for maintaining clarity and discipline. Discussion included whether anchoring exclusively on SMEs may constrain broader use cases and it was noted that related initiatives (e.g. ib1.org/Orion and ib1.org/carbon-commons) had been created as channels to help develop ideas without distracting from Perseus’ core mission.
  • Case study development faces practical barriers: delays often arise from internal processes and time constraints, rather than inherent SME reluctance. It was noted that the majority SMEs day-to-day concerns are focussed on cash, not sustainability, and that Perseus’ strategy to reduce both cost and friction for SMEs (including ‘taking solutions to where the SME already are’) was the correct approach.

Next meeting: Monday 18 May 2026 13:00-15:00 BST

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

These are confidential to the Steering Group Members.

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

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

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

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

Without reliable, comparable data:

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

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

Transparent, unified and harmonised

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

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

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

Our approach

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

Membership

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

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

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

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