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

Location: online

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

Secretariat: IB1

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.

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: 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.

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.

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.

Date: Monday 23 February 2026 13:00-15:00 GMT

Location: online

Co-Chairs: Gavin Starks (IB1); Hannah Gilbert (British Business Bank)

Secretariat: IB1

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/

Date: 10 February 2026 10:00-11:0 GMT

Location: online

Chair: Frank Wales

Secretariat: IB1

Meeting Aims:

1. Summarise Sandbox learnings
2. Feedback from members on Perseus-ready integration
3. Discuss change management best practice
4. Present draft certificate revocation specification
5. Explore workshop topics in 2026

Summary:

It was agreed that:

• Lessons from sandbox integrations would continue to inform incremental improvements to documentation, tooling, and processes.
• Future change proposals would aim to present technical changes more concretely, including clearer linkage between definitive specifications, and registry entries.

It was noted that:

• Four categories of issues had emerged from recent sandbox integrations:
  • Certificate authentication challenges, including confusion around directory usage and certificate expiry on services.
  • Conceptual understanding gaps, particularly around the FAPI 2 security model and Perseus’ role as an enabler of connections rather than a data provider.
  • Areas where documentation required clarification, including subdomain queries, CAP-to-EDP selection, and OAuth flow setup.
  • Technical usability issues with the directory service, including sandbox labelling and endpoint behaviour.
• A range of documentation and support improvements had been implemented in response, including workflow diagrams, role-specific setup guides (CAP and EDP) , a CLI testing tool for EDPs, and a directory usage guide with screenshots.

It was discussed that:

• IB1 recommends a Certificate Revocation List (CRL) approach over OCSP for certificate withdrawal, on the basis of simplicity, lower operational complexity and improved privacy characteristics; we are accepting review and feedback on this until February 27 (see actions)
• Git-based workflows were seen as helpful for proposing and reviewing technical changes (such as API updates), but not sufficient on their own to describe multi-environment availability or long-term governance state.
• Future change proposals could benefit from clearer presentation of “before and after” states, including diffs against OpenAPI specifications, supported by explanatory documents.

Next meeting: Tuesday 28 April 2026 10:00-11:00 GMT

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

These are confidential to the Advisory Group Members.

Date: 9 February 2026 10:00-11:30 GMT

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 primary focus for the year ahead is on concrete customer use cases and case studies.
• Individual follow‑ups will be undertaken with Members to map internal stakeholders and decision‑making processes.
• Each Member will prioritise identification of at least one potential ‘lighthouse’ customer.
• Further work will document and consult on the proposed market‑based emissions methodology, including supporting FAQs.

It was noted that:

• 2026 is the key go‑to‑market period, translating existing technical capability into demonstrable customer value.
• Constructive early conversations have taken place with the Financial Conduct Authority regarding Perseus’ positioning with Smart Data/Open Finance initiatives.
• to broaden scope beyond lending to include savings, asset finance, and other financial products, the phrase “access to finance” has evolved to “financial incentives”
• £5–10bn potential addressable  market is seen as ‘directionally credible’ and indicates substantial value opportunities for all stakeholders.

It was discussed that:

• From an SME perspective, particularly micro‑businesses, sustainability and net zero language has limited traction
• SMEs prioritise cost reductions, operational efficiency, and resilience, with emissions reduction often viewed as a secondary benefit. Perseus’ position as embedded sustainable finance is tactically aligned with this. 
• A key opportunity to increase TAM is ‘taking incentives directly to where the SMEs are’ (i.e. in their accounting and analysis applications) 
• Large financial institutions face material internal constraints, with implementation timelines often measured in years rather than months
• Technology is not the primary blocker; the key gap lies in the business case and incentive structures and this will inform our go‑to‑market approach, and clarity of financial value.

Next meeting: Monday 20 April 2026 10:00-11:30 GMT

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

These are confidential to the Advisory Group Members.

Date: 5 February 2026 10:00-10:45 GMT

Location: online

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

Secretariat: IB1

Meeting Aims:

1. Understand the Perseus 2026 Roadmap
2. Feedback from the AGM
3. Sign off a 2026 comms plan

Summary:

It was agreed that:

• 2026 comms will pivot more strongly to detailed, high‑quality case studies as a central tool to build trust and drive membership, rather than relying primarily on generic messaging or high‑level testimonials.
• The co-chair will share existing best‑practice case‑study and member‑spotlight formats she has developed (at Tide) with the IB1 team to inform Perseus templates.

It was noted that:

• The Perseus AGM was positively received
• The core comms outcomes for 2026 remain: Building trust and confidence in Perseus and making a consistent, compelling case for new and renewed memberships
• The communications plan for 2026 was presented and agreed
• High‑quality, detailed case studies are better suited than broad messaging to demonstrate ease of integration, tangible benefits, and business value.

It was discussed that:

• Perseus’ vision and mission will evolve in 2026, with suggestion by one member that this ought to be amended to also highlight benefits
• New case‑study formats could include a multi‑part journey following one CAP across the year
• Physical/in‑person or live formats (e.g. roundtables, workshops) can generate richer engagement and large amounts of reusable digital content

Next meeting: Thursday 26 March 2026 10:00-10:45 GMT

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

These are confidential to the Advisory Group Members.

Carbon Commons (CC) is a new collaboration to improve supply chain carbon accounting. 

Today’s carbon accounting methods often rely on inconsistent and incomplete data, which can result in fragmented, incomparable, and often unrealistic emissions estimates across complex supply chains. CC will help create a transparent, unified, usable, and fit-for-purpose approach towards a harmonised methodology, and principles for calculating hybridised emissions factors. 

Role

The CC Steering Group, provides independent governance, oversight and direction by convening non-commercial stakeholders to guide and validate priorities and outputs. It will ensure delivery of fit-for-purpose reporting that is practical, realistic, robust, comparable, and complete. 

Date: 26 January 2026 10:00-12:00 GMT

Location: online

Co-Chairs: Gavin Starks (Icebreaker One) and Duncan Oswald (Sage, interim co-chair pre-launch)

Secretariat: IB1

Meeting Aims: 

1. Explain Carbon Commons and its governance processes
2. Discuss targets and launch ideas
3. Agree on Membership proposal and reach out to prospective members

Minutes:

• It was agreed that:
  • the governance model and membership terms be adopted
  • the vision, mission, and values be adopted, subject to the addition of ‘five principles’

• It was noted that:
  • for-profit organisations cannot sit on the Steering Group (n.b.  DO will step down as interim co‑chair and there will be a selection process for the new co-chair)
  • CC is positioned to aid harmonisation and compliance, not as a competing standard. The SG will determine its scope – e.g. data set(s), defining criteria for CC-compliant factors and methods, enabling comparability across products, companies and sectors.
  • the SG will approve a definition of ‘fit-for-purpose’ for CC
  • the role of technical and academic expertise is essential in safeguarding methodological quality 
  • governance is key to enable adoption and reduce risk
  • carbon accounting is increasingly important in procurement, taxation, cross-border adjustment mechanisms (CBAM), and financial decisions, but the data quality is not fit for purpose or system complete
  • product‑level emissions factors are an initial priority area for impact and alignment

• It was discussed that:
  • there is a need to coordinate with government and parallel initiatives (e.g. WRI, UK Government) to ensure incremental development and avoid duplication of effort
  • clear communication and storytelling are critical: CC participants must be able to understand and explain what it is and what it is not (e.g. via product-level use cases) in plain language, for practitioners, SMEs and related stakeholders

Next meeting: March 2026 [date to be confirmed]

Formal records, including attendees, are maintained by the secretariat.  These are confidential to the Steering Group Members.

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

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

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

George Sandilands, Vice President, Sage Earth

From financing green to embedded sustainable finance

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

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

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

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

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

Hannah Gilbert, Director of Sustainability, British Business Bank

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:

18. Please provide any feedback on the proposal to refine the definition of scope 2, to emphasize its role within an attributional value chain GHG inventory and clarify that scope 2 must only include emissions from electricity generation processes that are physically connected to the reporter’s value chain, excluding any emissions from unrelated sources?

This response is on behalf of the Perseus programme’s member organisations. Perseus aims to unlock access to finance that reduces emissions, by automating sustainability reporting for every SME business in the UK. Perseus operationalises one granular use case focusing on the sharing of 30-minute electricity consumption data, which is combined with corresponding 30-minute local grid carbon intensity readings to calculate assurable monthly GHG emissions (See Perseus’ emissions calculations: https://registry.core.sandbox.trust.ib1.org/scheme/perseus/process/emissions-calculations/2025-10-23). The consumption data is sourced from SMEs with either a) a single business premise and a single, unshared smart meter, or b) an account with Perseus member Energy Data Provider that can provide half-hourly electricity consumption data. 

We welcome the GHG Protocol’s efforts to update the Scope 2 guidance. As the grid decarbonises, the current annual, market-wide accounting framework is increasingly insufficient for capturing the reality and complexity of electricity consumption. Perseus is currently UK focused and requires 30-minute electricity consumption and local grid carbon intensity granularity, however, we encourage the protocol to globally require reporting organisations to use the best possible available data. 

The proposal to restrict sourcing to the same “deliverable market boundary” rightly addresses the disconnect where companies claim emission reductions from grids they do not physically use. However, boundaries must be pragmatically defined.

Perseus member companies note that restricting procurement to narrow pricing zones could strangle market liquidity and prevent companies from supporting high-impact projects in adjacent, interconnected grids where decarbonisation is necessary. The final standard should explicitly allow for procurement across recognised interconnected power pools (e.g., EU-wide) rather than strictly enforcing narrow pricing zones.

19. Please provide any feedback on the proposal to clarify the LBM definition to reflect scope 2 emissions from generation physically delivered at the times and locations of consumption, with imports included in LBM emission factor calculations where applicable? 

As Perseus uses location-based method emissions calculations, we will only comment on LBM changes. 

The proposal to refine the Location-Based Method by prioritising a hierarchy of “Local” and “Hourly” data over national annual averages is scientifically sound. It correctly identifies that grid carbon intensity varies significantly by time and place. The administrative burden of the proposals may affect different business structures in quite different ways, potentially introducing new costs to distributed business with sites that are geographically dispersed. We suggest that the potential for an element of aggregation is considered. For example, this could mirror the ESOS model where a relevant proportion of the portfolio is surveyed and information is then extrapolated to the rest of the portfolio.

So what’s the difference?

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

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

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

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

Why harmonisation matters: lessons from TNFD

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

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

The benefits of harmonisation

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

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

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

Why harmonisation fits IB1’s approach

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

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

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

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

So when does standardisation have a part to play? 

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

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

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

1. Confirm positions on Greening Finance in 2026
2. Get operational updates
3. Sentiment check on the proposed Executive Summary

Summary:

It was agreed that:

• The shift from financing green to greening finance continues to be the correct framing for 2026 as it broadens the scope beyond green-linked loans to all relevant financial products and services, and better aligns with shifts in language such as productivity, resilience, efficiency and cost reduction.

It was noted that:

• Tony Greenham was thanked for his significant contribution to Perseus as 2025 co-chair.
• Hannah Gilbert, Director of Sustainability at the British Business Bank will take over from Tony Greenham as co-chair for 2026. Hannah brings a strong background in trust-based data sharing from her open banking fintech experience.
• Several financial institutions are moving away from using the term green finance due to policy and market uncertainty.
• The proliferation of third-party emissions datasets carries a risk of poor-quality SME estimates, reinforcing the importance of assurable data.
• The DOC considers project management, financial position and risk controls as satisfactory.
• AG1 segmentation work will both identify data-ready, higher-emitting sectors whilst ensuring that all SMEs are considered, and that language should be aligned with business outcomes and industrial strategy priorities.
• AG2 confirmed that the sandbox is operational, the national risk assessment is complete, and gas-data methodology has been approved. Work continues toward production readiness.
• AG3 & AG5 activity has been minimal as no major legal or policy barriers have been identified. Alignment work with regulators continues.
• AG4 communications will focus on the greening-finance narrative and the upcoming report launch.
• Priorities for 2026 include scheme-as-a-service onboarding, development of FSP case studies, integration of gas data, and progress on consumer consent solutions.

It was discussed that:

• Nature-related factors (e.g. biodiversity, water, land use) are becoming increasingly significant for investors and are viewed as drivers of resilience.
• Scope expansion and interaction with parallel initiatives (e.g. Project Orion) should continue to be monitored.

Date: 4 November 2025 10:00-10:45 BST

Location: online

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

Secretariat: IB1

Meeting Aims

1. Agree plan for Perseus report launch and AGM

Summary:

It was noted that:

• This marks a transition from financing green activities to greening finance more broadly — embedding sustainability directly into mainstream financial systems and products rather than treating it as a niche.

It was further noted that:

• Banks are exploring new incentives such as offering higher interest rates on savings or current accounts for SMEs demonstrably working towards net zero, creating a new category of incentive-based finance.

It was discussed that:

• Financial service providers are increasingly recognising the wider potential of Perseus to support both debt and credit finance, and that alignment with the Smart Data Act is encouraging banks to think differently about smart data in finance.
• Terms such as “net zero” and “sustainability” remain politically sensitive, and the narrative should emphasise practical solutions and market transformation rather than ideology.
• The narrative must balance macro and micro perspectives — connecting the large-scale market transformation enabled by Perseus with clear, practical benefits for individual SMEs.
• For many SMEs, accessing finance is not emerging as a primary concern for engaging with sustainability initiatives; rather, their interest lies in ease and simplicity, and saving time. It was noted that positioning Perseus as something that removes friction — automating data sharing, reducing paperwork, and making participation effortless — will resonate more strongly.
• The upcoming Perseus report and AGM communications should position Perseus as enabling a market-wide transformation of the financial system, supported by the visible progress of members and partners.

It was agreed that:

• The communications narrative should evolve to reflect this broader ambition while keeping language pragmatic, low-cost, and focused on productivity, efficiency, and the unlocking of private-sector finance.
• Both levels of storytelling will be needed: macro to convey ambition and system impact; micro to make outcomes tangible and relatable to businesses and partners.
• 2026 AG4 meetings would continue to be on a monthly basis but with ‘permission to cancel’ when prudent.