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

Ref: https://drcf.org.uk/publications/papers/insightssmartdataframeworks 

Published on 26 March 2026, this report from the Digital Regulation Cooperation Forum (DRCF) provides an international comparative analysis of Smart Data implementation models to inform the UK’s strategic approach under the Data (Use and Access) Act (DUAA) 2025.

Core focus

The report reviews how jurisdictions worldwide have approached consumer data portability and Smart Data ecosystems, drawing lessons to help the UK implement its cross-sectoral Smart Data ambitions. The DUAA 2025 empowers the Secretary of State to create sector-specific Smart Data schemes via secondary legislation, building on the Open Banking precedent. As of May 2025, one in five UK consumers and small businesses were actively using Open Banking services, up from one in seventeen in March 2021.

Three implementation models

The report categorises global Smart Data approaches into three main models:

1. Regulator-mandated 

Government-led, prescriptive legislation (e.g. Australia’s Consumer Data Right, Brazil’s Open Finance). Provides legal certainty and mandated participation, but risks high compliance costs, regulatory rigidity, and potential for stifling innovation. Australia’s experience is cited as a cautionary tale of disproportionate costs relative to uptake.

2. Market-facilitated  

Industry-driven, with regulators in a facilitative role (e.g. US, Japan, Hong Kong). Fosters innovation and commercial flexibility but suffers from inconsistent standards, fragmentation, slower incumbent adoption, and uncertain liability frameworks. The US is experiencing particular instability following legal challenges to its framework, which has been seen as lacking unambiguous positioning.

3. Public infrastructure-led 

Built on foundational national Digital Public Infrastructure such as digital identity and data exchange layers (e.g. Estonia’s X-Road, Singapore’s SGFinDex via Singpass). These solve interoperability and trust-by-design but require major upfront investment and sustained political commitment. Estonia saves an estimated 820+ years of working time annually through X-Road.

A fourth category, Hybrid and Transitioning, covers jurisdictions like India (Account Aggregator / DEPA framework, with over 100 million consents by 2024) and the UAE (transitioning from market-led to a centrally mandated Open Finance framework).

Key themes from the analysis

Governance

A central coordinating body is consistently identified as critical. Without it, sector-by-sector schemes under the DUAA risk creating new data silos rather than eliminating them.

Standards and interoperability

Cross-sector fragmentation is a recurring failure mode. The risk that different UK government departments managing different Smart Data schemes could produce divergent technical standards is highlighted as a significant concern.

Consumer consent journey

Legal compliance alone is insufficient. The quality of the consent user experience is as important as the legal principle. Brazil’s experience shows how broadly drafted consent forms led to data misuse and loss of public trust. India’s AA framework shows high consent numbers but low conversion due to friction. Singapore’s integration with Singpass is held up as a model of frictionless, trustworthy consent.

International alignment

The report recommends aligning with Gaia-X (the EU’s federated data infrastructure framework) to protect the UK’s data adequacy status (renewed until 2031), maintain access to EU digital markets, and reduce compliance burdens for internationally active businesses.

Anti-competitive risks

The report flags the possibility that Smart Data schemes could inadvertently facilitate tacit collusion if they enable easy monitoring of competitor pricing — a novel risk that warrants safeguards by design.

Considerations for the UK

The report proposes five strategic pillars:

1. A central Smart Data governance body to coordinate all schemes, set baseline standards, and prevent fragmentation.
2. Phased, use-case-driven rollout prioritising energy (for Net Zero), finance, and telecoms, learning iteratively before expanding.
3. Sector-tailored implementation models — acknowledging that some sectors suit market-led approaches while others need regulatory mandates, within a unified strategic framework.
4. Interoperability by design, integrating with the UK’s Digital Verification Services (DVS) trust framework (as envisioned in the DUAA) to create a trusted, unified consent architecture.
5. Clear secondary legislation covering liability frameworks, security standards, transparent cost-benefit processes, and safeguards against anti-competitive conduct.

Relevance to IB1

The DRCF report findings and recommendations are closely aligned with IB1’s existing work and strategic positioning.  

Central governance and Trust Frameworks

The report’s core recommendation, a ‘central’ body setting common baseline standards and ensuring cross-sectoral interoperability, closely mirrors the architecture IB1 has developed through its Trust Framework and Scheme architecture. The DRCF’s concern about fragmented sectoral schemes producing new data silos is precisely the problem IB1’s governance approach is designed to solve, specifically the interoperability between them.

Energy Smart Data and Perseus 

The report explicitly names energy as a priority sector for Smart Data designation, citing its alignment with Net Zero policy objectives. IB1’s Perseus programme, enabling permissioned energy data access for SME carbon reporting and green finance, is an existing example of the kind of sector-specific, use-case-driven scheme the report advocates.

Consent and liability frameworks

IB1 has developed detailed consent and liability standards across energy, water, finance, supply chains, and other sectors. The DRCF’s finding that the quality of the consent journey is as critical as the legal principle, and that clear liability apportionment is essential for industry confidence, directly reinforces the value of this work.

Interoperability across sectors

The report warns that without strong central coordination, different government departments could develop incompatible standards across schemes. IB1’s cross-sector interoperability work, including its engagement between Open Energy, Perseus and Open Banking, addresses this risk directly.

International standards alignment

The report recommends aligning with international frameworks such as Gaia-X. IB1’s engagement with cross-border data governance and its work across multiple jurisdictions is consistent with this direction.

The DRCF report diagnosis and recommendations map closely with the approach IB1 has built, and provides independent external validation of the strategic importance of IB1’s work.

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.

• twenty interoperable Smart Data schemes by 2035
• £36m of Industrial Strategy investment
• cross-sector Trust Frameworks and data sharing interoperability across the economy

https://www.gov.uk/government/publications/smart-data-strategy

For IB1, this is core to our work – and features the Perseus programme. It underpins how we will help deliver our sustainable economy into a data-enabled digital-first era, building the load-bearing foundations for trust, protecting our data rights, and delivering impact.

Open Banking took a decade to get right: we can now move much, much faster. The opportunity isn’t just ‘switching’, it’s opening up new markets and connecting financial flows to real-world outcomes at scale. The time to engage is now: the schemes being shaped today will define the data infrastructure of the next decade.

The UK has a great team helping to lead this, with Samantha as co-chair, the Department for Business and Trade (Siobhan, Agnieszka, Priya, and a growing support team), and non-govt Smart Data Council members including Henk, Adam, Liz, Charlie, Marie, Chris, Ezechi, Ghela, Helen, Joe, Josh , Louise, Maria, Nicola, Stephen, Jane, Lucy, Sue and many others across industry and government now engaged.

At Icebreaker One it’s what we’ve been building with IB1 Open Energy Perseus, STREAM and our Data Infrastructure work and we will continue to lead on Open Sustainable Finance.

Consumer-led Industrial and Commercial (I&C) flexibility allows large energy consumers (factories, retailers, office blocks, data centres, hospitals etc.) to adjust their net energy consumption for short periods in response to the needs of the grid, incentivised through flexibility markets.

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

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

Benefits of I&C flexibility

For grid operators, enabling flexibility can deliver:

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

For I&C Consumers, benefits include:

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

Data is the common thread

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

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

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

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

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

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

A data sharing scheme to accelerate I&C flexibility

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

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

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

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

How your organisation can benefit

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

For networks:

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

For flexibility providers and aggregators:

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

For large energy consumers and trade bodies:

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

Join us & your peers

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

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

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

Date: Tuesday 10 March 2026 10:00-12:00 GMT

Location: online

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

Secretariat: IB1

Meeting Aims 

1. Sign off Q2 outcomes and priority use case
2. Align on bids process criteria for incoming bids

Summary:

• It was agreed that:
  • Q2 strategic business priorities include: (endorsed by members after this meeting)
    • defining Stream’s 12‑month ambition and roadmap
    • continuing development of the Change Champion network
    • establishing a clearer process for supporting funding bids
    • progressing the Open Data maturity assessment plan.
  • The first prioritised Water Efficiency use case for this year will be Water Situation Reports.
• It was noted that:
  • Co-ordination will be required with the Environment Agency for the water situation report (as the report is owned by the EA)
  • Growing demand for Stream support on shared data use cases highlights the need for a clearer triage and prioritisation approach.
  • Members and observers felt there were certain items that should be taken into consideration, such as scope clarification (open vs shared data), the importance of FOI/EIR alignment, and maintaining opt‑in/opt‑out flexibility.
  • Energy sector learnings highlight the importance of common pattern libraries and Trust Frameworks to minimise cost and legal complexity.
  • Cross‑sector use cases may present future opportunities and should be considered in long‑term design thinking.
• It was discussed that:
  • The bids process requires refinement, including criteria such as value, repeatability, resource impact, technology implications, and avoiding parallel infrastructures.
  • A scoring matrix for shared data use cases could include economic, social and environmental value, friction reduction, legal complexity, and organisational readiness.
  • A Trust Framework model separating identity assurance from Scheme rules could lower future cost and improve cross‑sector interoperability.
  • Sector legal engagement will be challenging but early use case examples could build confidence and reduce friction.
  • Further knowledge‑sharing and workshops are needed to deepen understanding of Trust Frameworks and scheme governance.

Next meeting: Tuesday 21 April 2026 10:00-12:00 BST

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

These are confidential to the Steering 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.

Date: 24 February 2026 10:00-11:30 GMT

Location: Online

Co-Chairs: Lucy Chambers (IB1); Darren Anderson (NWL)

Secretariat: Icebreaker One 

Meeting Aims

1. Endorse the Q2 outcomes
2. Endorsement for CReDO data standardisation
3. Accelerating the decision towards sharing agreement templates

Summary:

• It was agreed that:
  • There were no significant concerns with the overall approach; however, the primary delivery risk identified was engagement with internal legal teams.
  • There’s value in the development of reusable artefacts and templates to avoid repeated drafting and to help colleagues engage legal teams more effectively.
• It was noted that:
  • A decision was made to continue with Esri on a reduced basis, with the cost totalling £27,000, down from £45,000 in year 1 and 2 of the project.
  • Q2 outcomes were presented for endorsement, including:
    • progressing data sharing agreements (created and signed) and sharing progress on shared data; 
    • technology / data sharing infrastructure best practice to CaSTco extension funding project
  • The next CReDO workshops are on hold, pending a further funding decision.
  • A case study on the Perseus data sharing scheme was presented as an example of how multilateral data-sharing arrangements and governance structures have been implemented elsewhere.
  • The working group outlined its approach to data-sharing agreements, including developing a decision framework and questionnaire to guide organisations on appropriate sharing mechanisms, categorising data by risk level, and creating a modular template agreement that could be adapted by participating organisations.
• It was discussed that:
  • There are risks associated with combining datasets and the need for legal and security considerations to be embedded within the framework.
  • It might be worth convening legal stakeholders together, potentially at the Innovation Festival, to help develop draft agreements and accelerate buy-in across water companies.

Next meeting: Tuesday 7 April 2026 10:00-11:30 BST

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

These are confidential to the Advisory Group Members.

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

Location: In person & online

Co-Chairs: Sara Vaughan & Gavin Starks

Secretariat: IB1

Meeting Aims 

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

Summary:

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

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

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

These are confidential to the Steering Group Members.

Date: 19 February 2026 10:00-11:30 GMT

Location: Online

Co-Chairs: Charlotte Hillenbrand (IB1), Alex Hughes (Portsmouth Water), Andy Johnston (Scottish Water) 

Secretariat: Icebreaker One 

Meeting Aims

1. Review the feasibility of the Q2 outcomes 
2. Prioritise Q2 use cases

Summary

• It was agreed that:
  • Breakout group outputs indicate that initial focus is expected to fall on Water Situation Reports and Smart Metering use cases.
  • Recruitment for the next Change Champion cohort will begin in Q2, adopting the new six month model.
• It was noted that:
  • Alignment on Stream’s long‑term ambition to 2030 will require a clearer narrative and a shared understanding of data‑maturity expectations.
  • There is a need for earlier visibility of future expectations, including DEFRA’s emerging monitoring direction, and Stream could provide a coordinated route for this.
  • Q2 planning includes further development of CReDO, water‑efficiency workshops, and refreshed ecosystem communications
    • Use case and dataset activities will require higher member engagement than ecosystem‑level work.
• It was discussed that:
  • Water Situation Reports present a clear opportunity to move from PDF‑based reporting to consistent, reusable datasets aligned with EA‑sourced information.
  • Smart Metering requires alignment on core data items and consideration of processing‑scale challenges, reflecting varied rollout maturity across companies.
  • DWMP, WRMP and WINEP remain important but carry higher complexity due to predefined reporting formats and the need to reconcile published plans with underlying datasets.
  • Members emphasised ensuring new datasets are interoperable and sensitive to internal organisational capacity and timelines.

Next meeting: Thursday 2 April 2026 10:00-11:30 GMT

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

These are confidential to the Advisory 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

Co-chaired by Icebreaker One and NWL, the group’s primary function is to help provide leadership and market signalling. Oversight of, and endorsement from, this group will establish a lasting set of robust governance measures to ensure data is shared safely and with the correct regulations.

Date: 27 January 2026 10:00-12:00 GMT

Location: online

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

Meeting Aims: 

• Members provide direction to Stream on priorities emerging from company 1-1s
• Clear ambition and alignment on the vision for Stream

Summary:

Minutes:

• It was noted that:
  • Operational updates for 2026 are progressing, including intranet launch and minor operating model refinements
  • Ofwat completed meetings with all water companies, noting that strong progress has been enabled by Stream and identifying sector‑wide themes including internal data portals, maturity assessment use, value measurement, and transparency of roadmaps.
  • Upcoming regulatory changes from DEFRA’s white paper and wider government initiatives (Smart Data Council, National Data Library, NESO/RECO developments) will have material impact on future data flows and interoperability requirements.
  • There was broad support for the ODI maturity model as a shared baseline. Members felt it provides practical benchmarking, comparability and a lighter process than previous audits.

• It was agreed that:
  • Stream will prioritise work on the four sector themes presented by Ofwat (in order of priority):
    • Standardised maturity assessment (e.g. using the ODI Open Data Maturity Assessment for Open Data).
    • Alignment on company data portals and approaches to internal/external data publishing.
    • Value measurement framework for open/shared data.
    • Greater transparency of company roadmaps.
  • Members will reflect on the long‑term direction of Stream as a Data Institution, to inform future governance and strategic decisions.

• It was discussed that:
  • The transition from Stream today to a Data Institution requires a clearer narrative for members, ensuring a clear understanding of the different layers of governance, operational maturity, and interoperability with the wider ecosystem.
  • Stream must be capable of connecting with wider UK data sharing initiatives, both within the water sector and cross-sector.
  • Its socio‑technical approach was seen as a strength versus more tech‑heavy models elsewhere.
  • Strong consensus that use cases should continue driving design decisions.
    • Use cases like continuous water quality monitoring will test how far Stream should move beyond raw data to provide analytics/visualisation and a guided interpretation.
  • There is a need for early visibility of future expectations (e.g., open monitoring) to avoid inefficiencies seen in recent reporting requirements. Stream could act as a coordinated route into regulators.

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. 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.

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.