As digitalisation and data initiatives across the energy sector gather pace, there is a growing imperative to ensure that activities are coordinated. Before deciding who should perform this coordination role, it is important to establish what the role needs to do and why.

To support this conversation, we have undertaken a delivery body-neutral analysis of a future digital coordination entity. Our analysis identifies the responsibilities, functions and capabilities required to deliver effective coordination with the findings underpinning our concept note, which sets out a proposed model for a sector-owned coordination entity.

Our aim is to support decision-makers by identifying the key considerations that should be addressed before decisions are made on institutional design and ownership. By focusing on the functions, capabilities and delivery model of a future coordination entity, this analysis is intended to inform sector deliberation, future public consultation, and the institutional arrangements needed to deliver effective digital coordination for the benefit of the climate, consumers and economic growth.

Read the concept note here

Emily Judson

Emily Judson, Head of Energy at Icebreaker One presented an analysis of the format, function and capabilities of a future digital coordination entity for the energy sector at our Open Energy Steering Group meeting.

Defining the role

Digitalisation is a broad and complex area of sector transformation. At present, large sector initiatives – such as the Data Sharing Infrastructure (DSI) and Consumer Consent Solution (CCS) – are driving significant change focused primarily on data and data sharing. The recent Digitalisation Vision also sets out new responsibilities for data domain coordinators, with NESO, RECCo and Elexon assigned new intended roles. 

We suggest that this focus on data must be clearly reflected in the initial scope of the coordinator role, allowing effort and resources to focus on the area where coordination is most urgently needed.

Our analysis also highlights that clear rights, responsibilities and accountability, alongside stronger feedback loops between delivery, oversight and decision-making, must be established to support effective coordination.

Essential functions

The coordinating body would perform seven core functions as identified by DESNZ and Ofgem (Digitalisation Vision, 2026):

1. Own and coordinate the digitalisation architecture
2. Assure digitalisation delivery & architecture against strategic documents
3. Manage governance processes for industry coordination
4. Provide strategic recommendations to government and the regulator
5. Ensure interoperability and alignment with other sectors
6. Coordinate and align data domains
7. Identify, manage and mitigate risks

We recommend that the scope of these functions could be expanded to incorporate the following:

• Coordination of technical and legal interoperability requirements for federated trust frameworks – in energy, across sectors, and potentially internationally; 
• Coordination of rights and liabilities in digital architecture and delivery;
• Monitoring, reporting and verification (MRV) of digitalisation delivery against key success criteria – which must include decarbonisation and consumer outcomes;
• Supporting sector knowledge-sharing and upskilling; and 
• Conducting a periodic horizon-scan function to support responsiveness to digital landscape shifts. 

Three core capabilities

Our analysis identified three core capabilities required to empower an effective coordination entity:

• Secretariat: Required to manage processes, facilitate collaboration, and ensure transparency and accountability across participants.
• Monitoring and Evaluation: Provides monitoring of delivery and robust evaluation of outcomes; this capability supplies the evidence needed for scrutiny, learning and ongoing accountability.
• Enforcement Coordination: Coordinates delivery between existing institutions, manages interfaces with regulators and government, and ensures that agreed processes are implemented consistently. 

Each capability above has the potential to create conflicts of interest depending on where it sits. Institutional design and governance are critical considerations and our analysis suggests that independence of the coordinator should be prioritised.

Delivery body format

Following the research and analysis outlined above, we examined what possible delivery body formats could effectively serve the functions and capabilities required to underpin successful digital coordination for the energy sector.

From these options, we see the functions and capabilities of the coordination entity best delivered via an independent mission-locked non profit company. It would be limited by guarantee and run through joint Directorship, with voting seats for the core delivery bodies and further seats spanning representative areas of the wider sector. DESNZ and Ofgem would participate as observers, reflecting the coordinator’s role in facilitating coordination and delivery rather than setting strategic direction.

This approach offers several advantages:

• The entity holds no existing market role, reducing the potential for conflict of interest
• It is vendor and software-agnostic
• A socio-technical, multi-stakeholder make-up enables thorough consideration of different angles of the data landscape
• The body can move quickly, offering a flexible and agile approach that a fast-changing landscape requires.

Evaluating delivery body types

Our analysis explored a range of delivery models, including coordination via: an existing Ofgem regulated organisation – either embedded in digital programme delivery or separate from this; an existing organisation with relevant expertise but not (currently) regulated by Ofgem; and a new purpose-built entity.

Each presents different strengths and trade-offs. Existing organisations could offer sector knowledge and established relationships, but may face actual or perceived conflicts of interest. This is particularly salient if they are actively involved in the delivery of sector data programmes and/or have prior interests related to other aspects of their market position. Assigning new enforcement powers to an organisation with an existing market position may add further complexity to its other role(s). A new organisation could provide greater independence and flexibility, but could take longer to establish and embed within the sector.

Rather than recommending a preferred delivery body, this analysis provides a framework for assessing these options against the capabilities required for successful coordination. 

Get involved

We welcome feedback as this discussion develops, to join the conversation, contact energy@ib1.org or sign up to Open Energy membership here

Please note that all outputs, including this report are © Icebreaker One Ltd. 
The copyright of this content will be considered for release under a Creative Commons Attribution (CC-BY) open license based on the materiality of the outcomes at IB1’s sole discretion.

Meeting Aims: 

1. Present the proposal: what good looks like for a digital coordination entity
2. Collectively discuss a responsible body for the coordination entity
3. Seek guidance on whether to present this proposal as from Open Energy or a new independent vehicle

Summary:

• It was agreed that:
  • As the group had previously highlighted, a digital coordination layer is essential to fill the governance gap between strategic oversight and technical delivery.
  • AG1 requires a co‑chair – members should nominate themselves or colleagues.
  • IB1 will produce a synthesis paper capturing the discussion on digital coordination entity options, including SPV model.
• It was noted that:
  • Scope definition must come before deciding the organisational form of the coordination entity. Multiple members emphasised that the role, remit and success criteria for the role must be clear before choosing a responsible body.
  • The domain coordinators (NESO, RECCo, Elexon) have been working closely together but it was acknowledged that the transparency of this work is currently limited, and greater visibility would be helpful.
  • Security considerations are not expressly called out in the digitalisation coordination function slide and must be incorporated.
  • Furthermore, decarbonisation alone is not a sufficient mission framing; consumer value, affordability, and security of supply should also be considered.
  • Getting the balance of independence vs domain knowledge is critical for any future coordination entity to address conflicts and ensure practical understanding.
  • Independence might be able to be achieved through behavioural measures, such as business separation within an organisation, rather than different entities.
  • Cross‑sector learnings (open banking, open property, smart data) provide valuable patterns for governance, trust frameworks, and scheme design.
  • Ofgem/DESNZ are expected to consult on the digitalisation coordination function by the end of 2026.
  • The I&C flexibility use case discovery phase and event on 17th June concluded positively, revealing clear user needs and gaps.
  • Quarterly goals work is progressing and will continue with Q3 focus on preparation for the AGM and progressing AG1/AG2 ramp up.
  • Open Energy’s analytical approach is welcomed, provided it helps frame consultation questions rather than prematurely prescribing an answer.
• It was discussed that:
  • A “good” digital coordination entity should include:
    • Secretariat capability;
    • Monitoring & evaluation;
    • Enforcement (complex, likely shared with Ofgem/DESNZ).
  • Representation and observer roles should be considered, including:
    • Security organisations;
    • Supply chain actors;
    • Flexibility service providers.
  • There is a need for a tighter feedback loop between coordination, delivery bodies, and standards.
  • Interoperability is essential, both within the energy sector and cross‑sector, and avoiding “reinventing the wheel”.
  • There could be turbulence in the market if multiple organisations put themselves forward to host the coordination function.
  • Funding models and trust frameworks are required for any coordinating layer to operate effectively.
  • Decisive decision‑making is becoming urgent, given market movement and upcoming regulatory consultations.

Next meeting: Tuesday 8 September 2026 14:00-15:30 BST

Last week, our Open Energy accelerator workshop, held at Arup’s London office, brought together network operators, flexibility service providers, regulators, government representatives and energy users to explore a new data sharing Scheme designed to scale Industrial & Commercial (I&C) flexibility across the energy sector.

The objective was to test the use case, understand user needs and explore the data landscape surrounding flexibility markets. A key theme emerged throughout the day: while data is fundamental to scaling flexibility, participation will ultimately depend on whether we can create the right incentives, build trust and clearly communicate the value to different audiences.

This reinforced an insight from our previous webinar that scaling flexibility is far from a one-size-fits-all challenge.

The incentive problem

It’s often assumed that financial incentives alone will drive participation, but our discussions revealed a much broader picture. For some organisations, flexibility supports ESG objectives and carbon reduction commitments. For others, it contributes to energy resilience, operational security or reducing pressure on an increasingly constrained energy system. In a UK market facing volatile prices and some of the highest energy costs in Europe, the motivations for participating vary significantly.

The ESG angle is a particularly interesting one, but as Charlotte Roniger, Flex Assure UK points out:

“For flexibility to scale in the I&C sector, ESG frameworks need to catch up. The strongest business case for consumer-led flexibility isn’t always on the balance sheet, sometimes it’s in the sustainability report.”

Even if the business case was centred around balance-sheet considerations, it’s important to be realistic about the financial returns available. Flexibility revenues alone are not always enough to drive widespread participation. If we want to attract more organisations, we need better ways of discovering, engaging and validating participants while clearly articulating the broader value flexibility can deliver. The incentives, in other words, go beyond revenue generation.

Data & Trust

While much of the discussion focused on incentives for participation, it quickly became clear that organisations cannot participate in flexibility markets if they cannot see, understand or trust the opportunities available to them.

For flexibility providers, networks and energy users to coordinate effectively, they need access to high-quality, interoperable data that can be shared securely. Visibility of assets, standardised information and clear governance frameworks all help reduce the friction that currently makes flexibility difficult to discover, assess and scale.

While some of this work is being tackled by sector initiatives already under development – for instance the Flexibility Market Asset Register – the event highlighted ongoing gaps in the data sharing needed to get energy consumers to the starting line of market participation (e.g. opportunity assessment linked to decarbonisation or electrification planning) and to evidence the impacts of trades (e.g. carbon savings).

Communicating value: a hearts and minds challenge

Even with the right data and incentives in place, bringing the right players to the table depends on how effectively we communicate the value of participating in flexibility markets. But, like incentives themselves, this is not a one-size-fits-all challenge.

Scaling flexibility requires us to communicate value differently to different audiences. What resonates with a CFO may be predictable revenue streams or accelerated connections helping a business to expand. What motivates a sustainability team may be progress against ESG goals and carbon reduction targets. For policymakers, the focus may be energy security, decarbonisation and system efficiency.

Understanding these different perspectives is critical. Participation will not come from incentives alone, it will come from building confidence, trust and a shared understanding of the role flexibility can play.

As one participant reflected: “Long-term change isn’t going to come from incentivisation alone. We need to be thinking about cultural change.” This was perhaps the most important takeaway from the workshop. Scaling flexibility is not just a technical challenge; it is a challenge of coordination, trust and engagement, as Simon Evans, Arup stated:

“Delivering flexibility at scale is a socio-technical challenge and is as much, if not more, about trust, governance, and incentives as it is about technology and data.”

Help shape the future of I&C Flexibility

Flexibility already forms a core part of the Government’s Clean Power 2030 Action Plan and has the potential to deliver clear value – from reducing system costs for networks to unlocking new revenue streams and resilience for energy users. But if flexibility is to scale, we need to look beyond technology and market design alone.

Expressions of interest are now open for joining our Open Energy advisory groups. This is an opportunity to help shape the future design of the Scheme as we move towards pilot and implementation.

Sign up now: https://ib1.org/energy0/2026-advisory-groups/

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

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

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

Attendees will leave with:

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

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

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

A shared data scheme to accelerate I&C Flexibility

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

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

Meeting Aims: 

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

Summary:

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

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

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

These are confidential to the Steering Group Members.

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

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

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

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

Not one-size-fits-all

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

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

Data, the great enabler

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

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

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

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

Join Open energy

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

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

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

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

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

Benefits of I&C flexibility

For grid operators, enabling flexibility can deliver:

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

For I&C Consumers, benefits include:

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

Data is the common thread

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

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

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

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

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

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

A data sharing scheme to accelerate I&C flexibility

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

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

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

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

How your organisation can benefit

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

For networks:

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

For flexibility providers and aggregators:

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

For large energy consumers and trade bodies:

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

Join us & your peers

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

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

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

Meeting Aims 

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

Summary:

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

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

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

These are confidential to the Steering Group Members.

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

Please note that throughout this consultation, Icebreaker One (IB1) uses the terms Open, Shared and Closed data as defined here.

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

Executive summary

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

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

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

The Research and Monitoring function should have two responsibilities:

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

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

Response

Where should we focus?

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

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

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

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

How would coordination be achieved?

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

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

Open Energy

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

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

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

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

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

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

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

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

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

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

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

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

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

Key questions:

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

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

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

Secretariat:

• Participatory processes: An independent facilitator is needed to support the involvement of a range of participants (directly or via a representative structure) which can adapt flexibly according to coordination needs. This requires:
  • Strong governance processes – e.g. covering participant selection, means of input, minuting, reporting, and decision-making
    • Ability to offer tailored mechanisms where required – e.g. working groups to focus on specific parts of the sector, or task and finish style groups to support elements of digitalisation strategy delivery.
  • Independent Secretariat function with experienced administrators to execute governance processes and communicate expectations of timescales, plans, key decisions etc.
  • Where required, the provision of independent chairing or facilitation services
  • Dispute resolution process, linked to existing sector mechanisms and to participatory governance processes.
  • Participant accountability mechanisms (linked to enforcement – see below).
• Enforcement: we suggest that enforcement activity occurs under the umbrella of either Ofgem or DESNZ. This may include:
  • Ability to compel involvement in participatory processes (at least at some defined level) of regulated entities to ensure fair and balanced process
  • Ability to invite external stakeholders as and when required, in a transparent manner (e.g. pinned to a published methodology for a certain use case / decision / piece of research).
  • Ability to action change
• Accountability: any coordinating entity must be accountable to its stakeholders. We suggest this is supported by the following:
  • Openness policies enabling scrutiny (e.g. of methodologies, processes, minutes, reports)
  • Where required (for security purposes), clear rules defining how scrutiny will be undertaken among closed audiences
  • Defined process for dispute resolution integrated with existing sector mechanisms
  • Clear processes for change management
  • Defined avenues for external involvement in participatory processes
• Other:
  • We strongly suggest that the Secretariat is empowered to communicate across sectors in order to best learn and harmonise with digital and data sharing initiatives that cross sector boundaries.

Research and monitoring:

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

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

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

Secretariat component

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

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

Research and monitoring component

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

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

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

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

Potential benefits of architectural coordination include:

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

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

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

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

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

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

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

Consultation response:

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

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

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

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

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

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

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

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

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

Building trusted open data

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

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

Sector-wide collaboration

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

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

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

Data Action

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

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

Rohan Graham, National Grid

IB1: The great facilitator 

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

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

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

Jay Chen, NGED

What’s next?

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

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

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

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

A draft of this position paper was circulated ahead of a licensee working group meeting held on November 26, 2025. Following input from the workshop, this updated draft is being circulated for further feedback from wider energy data stakeholders. 

Open Energy members hope that all RIIO-2 licensees, and the users of their data, will benefit from a clearly-articulated position on Open Data classification and access control. They would particularly welcome feedback from licensees who use third-party data platforms.

The Google version of the position paper is open to comments. Alternatively, interested parties may download a Word version. 

Please send comments or feedback to openenergy@ib1.org before February 2, 2026.

Key points from the position paper

RIIO-2 licensees that are members of Open Energy will:

• Adopt and enact an updated Assured Open Data definition that includes purposes for registration:

• D1.5.3 Anonymous downloads of open data is strongly preferred, but where the dataset requires compulsory registration before download:
  • D1.5.3.1 Registration is only conditional on completion of a lightweight challenge necessary for technical measures to minimise spam and bot abuse, such as verifying receipt of an email
  • D1.5.3.2 Acceptance of registration is automatic and immediate
  • D1.5.3.3 Registration may only be denied or withdrawn for misuse
  • D1.5.3.4 The registration process does not introduce any barriers to automated downloads or API access. Access to data is identical in all respects to a simple HTTP download of a published URL or API, except for the addition of a static credential or token that does not need renewing
  • D1.5.3.5 Require additional opt-in consent to use registration data for any further purpose. Data access must not be made conditional on obtaining any additional consents (e.g. use of registration data for analytics)
  • D1.5.3.6 If registration is only available via a third party platform (Data Controller), the third party must also comply with conditions D1.5.3.1 – D 1.5.3.5
  • D1.5.3.7 Third parties must transparently provide privacy policies and terms and conditions to the user if/where these differ from those of the Data Publisher.

• Apply the definition to metadata and data, meaning either or both may require registration
• Classify data requiring this form of registration as Open
• Licence data requiring this form of registration with either CC-BY-4.0 or OGLv3
• Implement information on registration forms/access gating screens making clear the purpose of this form of registration to end users and work with other licensees to align this language
• As required for compliance with UK GDPR, ensure privacy policies correctly reflect the use and protection of registration data, the length of time the data will be held, the situations where it would be disclosed
• Ensure terms of service for data portals do not contradict the Open Data licence being asserted for datasets on the portals
• Provide information in the registration process and/or the dataset listings that clearly separates Open Data “lightweight” registration from Shared Data registration requirements where registration may be used for other purposes, including limitations on access or use of the data
• Use registration as an opportunity, on a strictly opt-in basis, to provide additional benefits to users such as subscription to dataset update notifications or notifications of training opportunities

Meeting Aims 

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

Summary:

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

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.

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

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

The data sharing landscape

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

Harmonisation over Standardisation

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

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

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

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

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

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

The results are in

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

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

What’s next?

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

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

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

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

SME decarbonisation depends on better data

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

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

Making clean power visible

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

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

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

Open Energy & Perseus

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

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

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

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

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

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

Consultation response:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

So what is a smart meter?

A smart meter is a device that records and transmits your utility usage directly to your supplier, while also giving you insights into your own consumption. Most people are familiar with these household energy smart meters but much less so with water smart meters, which differ significantly in their design, purpose, and implementation. 

Not all smart meters are created equal

Smart water meters record a household’s water use and automatically send this information to the water company. According to Anglian Water, they can help customers detect leaks early, monitor their consumption, and receive alerts if their bill is unusually high. And, by encouraging more efficient water use, smart water meters play a valuable role in helping the UK move toward its net zero goals.

However, compared to energy smart meters, water smart meters typically offer less granular data and limited historical records – factors that can reduce their overall impact. You can explore the key differences between the two systems in the table at the bottom of this page.

Why does the Water Sector matter for net zero?

The water sector is an energy intensive one. In fact, the movement and treatment of water is said to create around 3 million tonnes of greenhouse gas emissions each year. This is because every time someone uses water, whether it’s turning on a tap, flushing a toilet, or doing laundry, energy is used to pump and treat drinking water, distribute it through the network, collect and treat wastewater. 

The more water we use, the more energy is needed, which leads to higher carbon emissions. And, we’re seeing a rising demand and consumption of water in the UK, with seven regions in England on track to become severely water stressed by 2030. If we are to reach our net zero targets, curbing our water consumption and preventing water wastage, should be top of the agenda. 

What can we learn from energy smart meters? 

While the water sector faces its own unique challenges, it can draw valuable lessons from the energy sector’s experience with smart meters. The rollout of energy smart meters is further advanced but has not been without difficulties – ranging from incomplete deployment to inconsistent functionality. Both the successes and the setbacks in this journey could provide the water sector with a useful blueprint to follow.

These lessons also hint at a larger problem that the technology itself isn’t enough. To fully unlock their benefits (whether in energy or water) we need a way to make smart meter data more accessible, usable, and secure.

That’s where smart data schemes come in. And, propelled by the recent passing of the Data (Use and Access) Act, smart data schemes could unlock the value of smart meters, paving the way for a much smarter energy system. 

But what exactly is a smart data scheme?

A smart data scheme is a framework that enables secure, customer-authorised data sharing between organisations. It supports Smart Data, which is “the process of sharing customer data, upon a customer’s request, with authorised third parties in a secure way. The term ‘Smart Data’ is often used interchangeably with ‘open X’, where X is banking, finance or any other sector”. (Department for Energy Security & Net Zero)

A prime example of a smart data scheme, already in action, is Open Energy. You can think of Open Energy as a smart data scheme, like Open Banking, but for the energy sector. It allows consumers and innovators to securely access and share energy data – unlocking better services, smarter tariffs, and encouraging more sustainable behaviour. 

To learn more about our work in Open Energy follow this link: https://ib1.org/energy/uk/ 

What’s the connection between smart meters and smart data schemes?

To put it simply: smart meters are the source of the data but smart data schemes are the key to creating meaningful impact with this data. 

“These meters create datasets that could accelerate energy efficiency and help encourage sustainable behaviours, but the data is currently challenging to access. With the ability to see exactly how much energy they use and when, consumers can optimise their habits and take advantage of smart tariffs that incentivise energy use during off-peak periods. This creates immediate financial benefits for households and drives the adoption of “smart” energy systems across the country. 

A Smart Data framework leveraging Smart Meter data could amplify these benefits by accelerating the use of flexible energy tariffs and technologies. Empowering consumers with real-time energy insights ensures that the transition to clean power is not just a policy objective but a grassroots movement supported by informed citizens.” Startup Coalition and TBI project – Smart Data Report.

Smart Data in action

A live example of a cross-sector smart data scheme is our Perseus project, which connects half-hourly smart meter data – with permission from SMEs – to the financial sector. This helps to unlock green financing from banks to accelerate SME decarbonisation efforts. In other words, it links real economy data to the financial economy through a smart data scheme. 

“Our work in Open Energy has led, directly, to initiatives like Perseus which is taking smart meter data, with permission from SMEs into the financial sector. It is Data Act ‘ready’ and I believe is the first national cross-sector Smart Data Scheme in the country” Gavin Starks, CEO, IB1. 

If you’re interested in being part of a smart data scheme, whether its Open Energy and Perseus, then please get in touch via: icebreaking@ib1.org 

Similarities and differences between household energy and water smart meter systems