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

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

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

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

Not one-size-fits-all

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

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

Data, the great enabler

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

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

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

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

Join Open energy

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

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

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

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

Location: online

Chair: Frank Wales

Secretariat: IB1

Meeting Aims:

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

Summary:

It was agreed that:

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

It was noted that:

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

It was discussed that:

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

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

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

These are confidential to the Advisory Group Members.

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

Location: online

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

Secretariat: IB1

Meeting Aims 

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

Summary:

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

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

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

These are confidential to the Steering Group Members.

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

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

Call for evidence response:

1. What energy problem do you want to solve? 

There is a wide range of energy use cases identified and highlighted in IB1’s response to DESNZ’s Developing an energy smart data scheme: call for evidence (question 14). There are core principles IB1 recommends embedding. 

Smart Data becomes effective for use in AI and in decision making when it is connected

In terms of prioritisation of sector, use cases requiring cross-sector interoperability and cohesion offer the greatest immediate ability to create impact, with a manageable degree of complexity involved in rollout. 

Regardless of use case, codify a requirement to contribute to net zero

As mentioned in IB1 response to Ofgem’s AI in the energy sector guidance consultation, we acknowledge and appreciate Ofgem’s commitment to encouraging innovation while helping the UK to meet its net zero target and other associated targets. As mentioned in the IB1’s May 2024 AI consultation response, IB1 recommends that the developing AI governance landscape codifies a requirement for AI use in the energy sector to demonstrably contribute to the UK’s net zero targets and for this requirement to be open to monitoring and audit. Without codification of this principle there is a risk that AI systems are established to optimise non-environmental goals, while creating negative environmental impacts. 

IB1 acknowledges the risk of AI systems generating increases in energy and water demand. Both the impacts and the demand profile of AI use should be subject to scrutiny and appropriately governed to ensure they contribute meaningfully to the UK’s net zero targets.

2. What kind of data is needed? 

All identified IB1 use cases, detailing the value, kind, potential users, and scale of the required data, are outlined here: https://ib1.org/energy/reports/ 

3. What work is needed to create or enable a useable dataset, including making sure it can be easily combined with other datasets? 

IB1 observes that this list concentrates on technical barriers to data use, but fails to highlight legal, licensing and commercial considerations. It is very possible that cost, usage and IP conditions will hamper otherwise technically possible uses of the data. We recommend early surfacing of this information to mitigate five risks: 

1. Regulatory and compliance complexity: Data licensing must align with compliance rules around grid data, market data, and critical infrastructure. It is important to ensure data inputs to AI systems, and the outputs of the AI, remain compliant.
2. Third-party data dependencies AI models in energy often rely on weather feeds, satellite imagery, market pricing, and sensor data from multiple vendors. Each source carries its own licensing terms around permitted use, commercial exploitation, and AI training rights. Identifying these dependencies early prevents data supply chain disruptions during development, or worse, after deployment.
3. Intellectual property and model ownership: Who owns the AI model trained on licensed data? Many data providers now include clauses that restrict or claim rights over derivative works, including trained models.
4. Onward data publishing and monetisation: Energy sector companies typically want to share or sell AI-derived insights. Licensing terms set upstream can block valuable downstream opportunities. 
5. Long-term data access and continuity risk: Many foreseeable AI systems in the energy sector (e.g. predictive maintenance, load forecasting) need consistent, long-term data access. Identifying long-term data rights is critical to operational resilience.

Governance to enable usable datasets which can be combined with other datasets 

As mentioned in IB1 response to Ofgem’s AI in the energy sector guidance consultation IB1 encourages cross-sector collaboration and learning wherever possible. We recommend engaging with cross sector (i.e. water, transportation, local authorities, etc) and working with citizen advocacy groups to learn from best practices, ensure guidance is consistent for cross sector use cases (hydrogen, electric vehicles, electrifying public transport, etc), and understands the impact of AI guidance on different socio-economic stakeholder groups.

As described in IB1’s AI positioning statement, IB1 supports a hybrid governance model, combining robust oversight with decentralised data sharing, including smart contracts and digital identity solutions

AI must be designed to mitigate bias and discrimination, ensuring fair access to economic opportunities, financial services, and public resources. We support governance which is co-designed through processes which are adequately representative of different stakeholders or stakeholder groups, ensuring that the approach is collective rather than ‘done to’ from the top down.

To mitigate risks and enable data sharing at scale for AI use, the industry must consider more than just the dataset. For an identified use case, it needs to collectively determine:

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

At IB1 we do this through a robust governance process and Icebreaking to drive groups of organisations to make the critical decisions required to exchange data with one another.

4. Who would the users of the dataset be? 

All identified IB1 use cases, detailing the value, kind, potential users, and scale of the required data, are outlined here: https://ib1.org/energy/reports/ 

5. What scale does the dataset need to be? 

All identified IB1 use cases, detailing the value, kind, potential users, and scale of the required data, are outlined here: https://ib1.org/energy/reports/ 

6. What would enabling AI use of this dataset unlock? 

All identified IB1 use cases, detailing the value, kind, potential users, and scale of the required data, are outlined here: https://ib1.org/energy/reports/ 

7. What would be the arrangements for ongoing maintenance, governance and curation of the dataset? 

As noted in IB1’s response to Ofgem’s AI in the energy sector guidance consultation: 

IB1 encourages cross-sector collaboration and learning wherever possible. IB1 recommends engaging with cross sector (i.e. water, transportation, local authorities, etc) and working with citizen advocacy groups to learn from best practices, ensure guidance is consistent for cross sector use cases (hydrogen, electric vehicles, electrifying public transport, etc), and understands the impact of AI guidance on different socio-economic stakeholder groups.

AI must be designed to mitigate bias and discrimination, ensuring fair access to economic opportunities, financial services, and public resources. IB1 advocates strongly for AI governance to integrate with developments in data governance, both within the energy sector and in the cross-economic space (e.g. Smart Data Roadmap, approaches to consent or permission). 

IB1 believes it is important for data governance to establish principles, structures, roles and responsibilities, agreed upon by market participants, that enable auditable, accurate and timely data sharing at a market-wide scale. As mentioned in the IB1’s May 2024 AI consultation response, IB1 recommends that the data ecosystem, and integration with the data governance landscape be acknowledged.

IB1 notes that in training a model it is highly likely that training datasets will contain sensitive data (it is also possible to use only anonymised data within a training dataset to retain privacy in the model itself), but it is possible to implement techniques where sensitive data is significantly better protected in the training of the model such as aggregation, pseudo-anonymising personal data. A good example of this that has been accepted by Ofgem as appropriate for maintaining privacy is the creation of datasets in energy that aggregate data down to a few households based on which properties are on different Low Voltage Feeders. If there are clear controls on the training data which datasets can and cannot be used to train AI models, then we can expect the produced AI model to be privacy preserving. If you implement data protections after an AI model has already been trained, it is harder to control. If a model has used training datasets with potentially identifiable data within them, the model may provide outputs using this data and can end up linking datasets together to make it personally identifiable

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

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

Overall Position

We support the introduction of a new licence condition requiring improvement to connections data. However, the proposal would benefit from clearer definitions of sensitive data and a broader scope that includes both open data and shared (sensitive) data. It is important to note that capacity data is relational not static – interoperability between different data providers and datasets is essential.

A transparent user needs-led approach to data assurance would encourage data sharing, support higher data user confidence, and provide more flexibility than fixed requirements on accuracy, completeness and timeliness, for example regarding update schedules and interoperability. Data user needs must be explored and permitted to share improvement incentives to ensure design and use are aligned. It is important that shared data improvement is incentivised before the timeline for full DSI integration as there is demand for this data immediately. 

Consultation question responses:

Theme 1 – Improving visibility and accuracy of connections data 

Q1.1. Do you agree with Proposal 1.1. to introduce a new licence condition for accurate, complete and timely data? 

Yes, we agree with Proposal 1.1 to introduce a new licence condition, however, it should not be limited to open data publication (see question 1.2 below for sensitive data response). All data sharing would benefit from a clear assurance framework, which may draw from established assurance approaches such as Icebreaker One’s generic dataset assurance levels. Data that is not 100% accurate, complete or timely can still be valuable as long as the limitations are made clear. Assurance encourages publication rather than waiting for “perfect” data, which can mean that key datasets are not published due to data quality concerns. Assurance can include accuracy, completeness and timeliness but it enables more nuanced or context-specific signals about data quality, for example interoperability or provenance.

We encourage licensees to engage widely with stakeholders, particularly those outside the energy sector, to develop data assurance signals that meet specific user needs. Open Energy can facilitate this through a structured approach to design, implementation and governance of such standards within the Energy Sector Trust Framework.  

We support the requirement for data to be as close to real time as feasible, subject to security considerations (e.g. more granular data may be subject to additional access controls). Monthly updates should be considered a minimum baseline, not an indicator of best practice. More frequent (e.g. daily) data updates would be helpful to accelerate policy ambitions to speed up the connection queue. In all cases, update schedules should be published transparently as part of the assurance process.

It is vital that this condition has a consistent  approach across distribution and transmission networks to ensure data is as interoperable as possible. Increasing demand from new industrial plants and digital infrastructure reinforces the need for high-quality, frequently updated, relational connections data. Connections data requirements should apply consistently to both:

• Generation connections
• Demand connections (including large industrial loads and data centres)

Q1.2. Do you agree with Proposal 1.2. to split data into open and sensitive categories, and to use the Data Sharing Infrastructure to share sensitive data? 

No. Sensitive data is not a monolithic category, there are existing approaches (e.g. IB1 Data Sensitivity Classes) to sub-categorise which should be used in order to assess data sensitivities and place appropriate access controls/licensing. This will provide DNOs greater guidance from regulators on what should be considered sensitive data. 

DSI data sharing may not be (immediately) suitable for all use cases, it is currently unclear when and how non-regulated actors will be able to access data via the DSI and these actors constitute major customers for connections data (e.g. heavy industry, retail etc). While sensitive data may be exchanged via the DSI in future, improvements must not be put on hold until the solution is ready. Further, determining whether the DSI is used as the primary mechanism to share sensitive data should depend on the outcome of the MVP.  

Q1.3. Do you have any additional comments in relation to the decisions and proposals outlined in this theme? Do you have any additional comments related to any other aspects of this theme you think we should consider? 

Additional comments:

• Network headroom is not static at a single supply point (substation / GSP). Capacity availability is relational and influenced by:
  • Nearby supply points and how power is drawn/combined from different points
  • Connection queues and timelines
  • Reinforcement plans and timelines
  • Local and regional constraints (e.g. DNO/TNO or cross-DNO constraint interactions)
• The licence condition and associated data standards should better capture and communicate these relational dependencies.
• Greater transparency regarding capacity that has been committed but is not yet utilised (and anticipated timescale for use) may support better planning.

Lessons from relevant innovation projects (e.g. work examining relational network constraints) should inform the design of data publication and visualisation tools. In particular, lessons from the Strategic Innovation Fund REACT programme which aimed to  address current planning and future planning for generation siting may be valuable. REACT’s Alpha Phase Data accessibility and interoperability report recommendations:

• Reducing friction: To improve data assurance, reduce friction across data silos and provide forward compatibility with the Virtual Energy System, the REACT project must embrace a ‘Trust Framework’ methodology throughout its work.
• Improving data accessibility: To improve the discoverability of datasets and encourage process innovation, Transmission Owners should publish internal process diagrams that describe the workings of complicated internal processes – such as the Network Connection Request process.
• Improving prediction: To improve long-term planning for Transmission Owners and for other stakeholders, a statistical model of projects should be embraced that tracks a project’s estimated probability of success according to the best available data.
• Embracing innovation: To radically embrace innovation around processes, such as the Network Connection Request process, virtual ‘sandbox’ representations of these processes with representative data should be created. This will enable innovators to safely experiment with innovative solutions without affecting Business as Usual.

As mentioned in IB1’s Response to Ofgem Modifications to RIIO-3 consultation, with the progress of the Data Sharing Infrastructure (DSI) programme, IB1 anticipates ‘Shared Data’ sharing will evolve and will inform the evolution of data best practice (DBP) guidance. In particular, as data sharing scales, the need to standardise and harmonise legal and technical approaches will become more pressing in order not to slow innovation and add unnecessary cost. IB1 recommends that DBP should include guidance around Shared Data within the triage processes and licensing decisions, highlighting the role of Shared Data Schemes to provide definitions that aid interoperability and maximise impact.

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

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

Consultation response:

1. Do you agree with the Workgroup’s initial view that P494 does better facilitate the Applicable BSC Objectives than the current baseline?* Please provide your rationale and, if ‘No’, please provide full details of your Alternative Modification(s) and your rationale as to why it / they better facilitate the Applicable BSC Objectives. 

• Yes
• No 
• Neutral / No Comment 
• Other 

Rationale: Elexon is unable to fulfil the potential benefit of making the data available with its current position as Data Processor.

2. Do you agree with the Workgroup that the draft legal text in Attachment B delivers the intention of P494?

• Yes
• No 
• Neutral / No Comment 
• Other 

Rationale: 

• Data Controller is limited to “Relevant BSC Personal Data” which only applies to data about natural persons. This will exclude data protections for company data envisaged in the DUAA. It leaves a lot of heavy lifting to the SDR Rules for non-personal but commercially-sensitive company data.
• SDR Rules not sufficiently developed at this time to assess whether, in combination with the code change, they are sufficient to ensure adequate data protection under the DUAA:
  • Identifying legitimate agents
  • Identifying meter owners not covered by CCS
  • Licensing and access arrangements for commercially-sensitive but non-personal data
• The consultation notes that “The means of determining whether a data set is commercially sensitive or personal data are being explored and are outside of P494”. This leaves a lot of work for the SDR Operations Manual to cover. The SDR is described on p27 of the consultation as containing “list of all APIs and reports published as well as technical details for how SDR users can interact with the SDR”. It will need to have much more detailed governance information. There is a risk that these considerations will “fall between the stools” of the BSC modification and the SDR Operations Manual.

3. Do you agree with the Workgroup’s recommended Implementation Date?

• Yes
• No 
• Neutral / No Comment 
• Other 

4. Do you agree with the Workgroup that there are no other potential Alternative Modifications within the scope of P494 which would better facilitate the Applicable BSC Objectives?

• Yes
• No 
• Neutral / No Comment 
• Other 

5. Do you agree with the Workgroup’s assessment of the impact on the BSC Settlement Risks?

• Yes
• No 
• Neutral / No Comment 
• Other 

6. Will P494 impact your organisation?

* If it will impact, please provide a description of the impact(s) and any activities which you will need to undertake between approval and implementation (including any necessary changes to your systems, documents and processes) and any on-going operational impacts. Where applicable, please state any difference in impacts between the Workgroup’s proposed solutions. 

• High 
• Medium 
• Low
• None 
• Other 

Rationale: There is potential for P494 to affect the Perseus smart meter scheme positively, opening up a wider array of the kind of meter points used by SMEs. 

7. How much will it cost your organisation to implement P494?

* If any, please provide details of these costs, how they arise. Please also state whether it makes any difference to these costs whether implemented as part of or outside of a normal BSC Systems Release. Where applicable, please state any difference in costs between the Workgroup’s proposed solutions and if applicable, between the different roles. 

• High 
• Medium 
• Low
• None 
• Other 

Rationale: P494 does not drive any direct costs

8. What will the ongoing cost of P494 be to your organisation?

* If any, please provide details of these costs, how they arise. Please also state whether it makes any difference to these costs whether P494 is implemented as part of or outside of a normal BSC Systems Release. Where applicable, please state any difference in costs between the Workgroup’s proposed solutions and if applicable, between the different roles. 

• High 
• Medium 
• Low 
• None
• Other 

9. How long (from the point of approval) would you need to implement P494?

* Please provide an explanation of your required lead time, and which activities are the key drivers behind the timescale. Please also state whether it makes any difference to this lead time whether implemented as part of or outside of a normal BSC Systems Release. Where applicable, please state any difference in lead times between the Workgroup’s proposed solutions. 

• 0-6 months 
• 6-12 months 
• >12 months 
• Other

Rationale: P494 does not require any action from us

10. Do you agree with the Workgroup’s assessment of the consumer benefits?

• Yes 
• No 
• Neutral/No comment
• Other

11. Do you agree with the Workgroup’s assessment that P494 does impact the European Electricity Balancing Guideline (EBGL) Article 18 terms and conditions held within the BSC?

• Yes 
• No 
• Neutral/No comment
• Other

12. Do you have any comments on the impact of P494 on the EBGL objectives?

No

13. Which of the following funding options do you prefer for the recovery of SDR costs?

• Costs recovered from Suppliers based on the number of MPANs supplied (option one)
• Costs recovered from Suppliers based on their share of delivered energy volumes (option two)
• Costs recovered from Suppliers using a hybrid approach combining MPAN-based and volume-based charging (option three) 
• Costs recovered through existing BSC arrangements and borne by all BSC Trading Parties (option four) 

Rationale: No comment

14. Do you have any views on when the full review of the cost to SDR Users should occur?

• Yes 
• No 
• Neutral/No comment
• Other

15. Do you agree with the legal basis to establish and operate the SDR?

• Yes 
• No 
• Neutral/No comment
• Other

Rationale: The underlying mechanism of creating the SDR Manager and giving it Processor rights seems sound, but it is lacking detail for non-domestic users as noted in our response to Question 2

16. Do you have any views on what the de minimis aggregation level should be?

• Yes 
• No 
• Neutral/No comment
• Other

Rationale: The proposed choice of 10 MPANs is not presented with a clear evidence based rationale. If there is a more detailed rationale this should be put forward transparently. There is an opportunity to build a more nuanced context-specific decision on the appropriate level of aggregation based on factors such as geographic dispersal and existence of generation and storage capabilities that may provide a “signature” in the data. Also consider differentiating “highly aggregated” data (say 50+ MPANs) that may be widely licensed, and “minimally aggregated” data (5-10 MPANs) that may have more restrictive access and licensing to prevent abuse.

17. Do you have any further comments on P494? 

There is a considerable amount of work to be done in the SDR Operations Manual in order to achieve the goals of the SDR Trust Framework. The following are some key elements left to be defined:

1. ID & Verification for non-CCS access is not defined (and even for CCS requires that to have been established). CCS should eventually cover business meters , and hopefully this will extend to smart and AMR meters. But that may not be until 2028. Businesses are key potential beneficiaries of SDR, for both cost reduction and net-zero impact. A number of the expected SDR Users focus on services intended for business. How will SDR support businesses in the interim? How will the SDR Users be verified, their data usage controlled, and how will they provide evidence for meter data access from businesses?
2. The data sensitivity classes need more definition and clear policies for application
3. The eligibility requirements and decision-making process for executing an Access Agreement and allowing access must be defined, as well as policies/processes for ensuring SDR Users remain eligible
4. Data licensing requirements are not mentioned in the consultation. How will purposes be categorised and policed? What is permitted/not permitted for the various levels of non-open data?
5. Liability and redress are not mentioned in the consultation. What policies and processes will enable data subjects harmed by the SDR to seek redress?

Since SCR covers a wider range of legal bases and potential data users than CCS, we recommend early consideration of how governance elements such as those above may be harmonised with other data sharing initiatives. This may be achieved through identifying opportunities for common definitions around ID&V, data sensitivity, purposes (or classes of purpose), and licences. Icebreaker One and Open Energy have research and experience, drawn from wide stakeholder engagement, that can inform this work.

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

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

Consultation response:

Q1. Do you agree with our case for change and that policy intervention is needed for DNO asset registration? 

Icebreaker One (IB1) is a non-profit working on data sharing and sustainability, convening organisations and governments to design market-scale solutions to make data work harder to deliver Net Zero. IB1 creates and runs programmes to reduce barriers and costs to finding, accessing, using, and sharing data, which will ultimately reduce costs for consumers.

IB1 supports better data on assets, and data sharing between DNOs, suppliers, and other organisations who need to understand headroom capacity and demand. We note there is a need to distinguish clearly between asset type(s) and capacity at the initial phase. In future, better data on asset performance and behaviours would be helpful to ensure this initiative can be most useful – e.g. capacity is not static with flexibility assets in play.

Q2. Do you agree with our priority use cases, and are there any other use cases we should consider? 

We agree with Ofgem’s identified use cases, however, we note that the data end user within the priority (regulated entities) and further use cases may have very different needs and data sharing instruments available. As mentioned in IB1’s response to Ofgem’s Energy digitalisation governance: architectural coordination letter, we propose that an industry-independent coordination body helps coordinate a flexible energy system. Data sharing at scale requires the separation of ‘the data’ from its governance and the technology used to host and transfer it.

We encourage the inclusion of potential ‘further users’ as a part of a governance process from the outset to ensure a solution suits their needs and does not exclude the solution from expanding past the priority use cases. We advocate for starting with a use case with external (non-regulated / less digitally mature) players, then a B2B DNO focussed use case to make subsequent use cases easier and less likely to inadvertently produce blockers. Leaving local authority use cases for “later” risks local planning and investment being disconnected from the physical reality of supply. A key use case to consider is data centre energy demand, which reinforces the need to urgently prioritise local authority use cases. 

IB1 has worked on a few other relevant collaborative use cases in this area, including:

• Getting small scale assets / flex services online (Open Energy Future of heating –  Residential Property Developer use case).
• How data sharing can be used to better understand how to maintain the assets already in place. IB1, SSEN-Transmission, IBM, and Palantir on a Strategic Innovation Fund programme, NIMBUS, which focussed on granular weather data and network innovation to build for sustainability. See the Discovery Phase report and the Alpha Phase report.
• IB1 partnered with SSEN-Transmission, Olsights, Mapstand, SGN, and National Grid on a Strategic Innovation Fund programme REACT to address current planning and future planning for generation siting. See the Discovery Phase report, and the Alpha Phase report. This use case reinforces the need to know other assets on grid to aid grid capacity understanding and future planning.

Q3. Are there any other policy or industry initiatives that we should seek to align with? 

IB1 encourages seeking alignment with:

• Open Energy – run by IB1, has expertise articulating use cases, and designing and quickly implementing shared data schemes with appropriate governance – includes legal agreements, assurance and technical specifications – in collaboration with stakeholders.
• Connections end-to-end review: updated proposals and next steps​ consultation. To what extent are external entities interested in assets as opposed to capabilities?
• Consumer Consent Solution, currently being developed, designed and delivered by RECCo Ltd, as small scale asset data is in scope (unless this programme is using another lawful basis for processing, this would need to be articulated clearly).

Q4. Do you agree with the scope proposed for assets, data, entities, and data stages, should anything else be considered?

As mentioned above, there needs to be a defined governance process for considering and agreeing upon the proposed scope for assets, data, entities, and data stages. 

IB1 would highlight there is a need to identify current data uses, and to be flexible enough to incorporate new ones as they emerge, to establish both the scope and the data quality and completeness requirements for asset information. For example, there is likely to be a difference between the DNOs’ data quality requirements at the lowest end of the asset capacity scale and the data quality requirements for users like councils, planners, microgrid/heat network assessors etc. Additionally if this asset data feeds into the flex market, missing or incorrect installations could lead to financial consequences for asset owners. 

While not in scope for the initial phase of development, our suggestion for future development would be the ability to transfer data on asset profiles/behaviours. This would be incredibly useful to better understand how flexible assets actually behave and their real-life impact, for example on network capacity.

Q5. Do you agree with our enablers and dependencies, and are there any others we should consider? 

IB1 would add on the lawful basis for processing – if not using consent then clarify on what lawful basis the register operates under. It would also help to understand how any data protection risks potentially associated with the register will be managed and governed. It is not currently clear how the lawful basis distinguishes between household and business (including microbusiness/SME) assets. This will interact with the Data (Use and Access) Act for businesses and requires clarification.

Q6. Do you have any suggestions for collecting legacy data, or for integration of other datasets into DNO registers? 

No comment. 

Q7. Do you agree with the advantages and disadvantages for the proposed options, are there others or any wider aspects we should consider? 

Wider aspects to consider on Option 2:

• May require upskilling/investment by DNOs, with an opportunity to subcontract if they are lacking skills in-house. This is a low risk if data standards are agreed through a governance process.
• As mentioned in Question 2, this initiative must be mindful of restricting use cases to regulated entities first which may make it harder for other users in the future. 
• As there is demand by non-regulated users for asset data now, there may be a benefit to spinning up a scheme in the short frame which is ready to integrate with DSI but has governance to engage a wider range of end users at the start. 
• This option has the highest potential to scale as it does not bottleneck in a single database/register, and provide utility for a wide range of use cases. 

Wider aspects to consider on Option 3:

• New databases and portals struggle to scale for a wide array of use cases as infrastructure systems are being digitalised in a decentralised and distributed way
• This option gives liability to a central entity versus distributed liability to DNOs
• May conflict with current DNO autonomy in deciding what data to publish and how to publish it, guided by DBPG. In particular may lead to a lowest-common-denominator approach that disincentivises DNOs from publishing otherwise-useful data that isn’t needed by the central register

Wider aspects to consider on Option 4:

• Operating a flexible market is a significantly different use case from the ones articulated above – expanding existing initiatives may result in a loss of focus on the original challenge it was solving
• Suggest a focus on harmonisation rather than making FMAR even more complex.

Q8. Are there any changes you would make to any of the proposed options to enhance them? 

IB1 would emphasise the need for a determination on what body would govern the standards for Option 2, and how stakeholder engagement beyond the regulated entities will be managed. There is a need to convene stakeholders within and outside the industry to ensure it is fair and accessible as well as implementable by the data holders. 

Q9. Have we missed or discounted any options that you think are suitable? In particular, for option 4 is there a preferable alternative to FMAR for expansion, and why? 

No Comment. 

Q10. Which option is your preferred option, and why?

IB1 would encourage Option 2, as it is the fastest to market and lowest cost, and can be decoupled from other initiatives, so can run in parallel and at pace. We would suggest this happens through a trial ‘scheme’ developed as and will be DSI integration ready for when DSI is ready to support asset data sharing. 

This option also has the opportunity to have the simplest governance (only DNO liabilities) – although this needs defining – as referenced in Question 8.

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

Location: Online

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

Secretariat: Icebreaker One 

Meeting Aims

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

Summary:

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

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

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

These are confidential to the Advisory Group Members.

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

Location: Online

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

Secretariat: Icebreaker One 

Meeting Aims

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

Summary

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

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

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

These are confidential to the Advisory Group Members.

Since the end of February, energy price volatility has been seen across multiple fuels, including oil and gas. And, while this volatility is being felt across the board, SMEs – which represent 99.85% of total business population and £2.8Tn in turnover – are being disproportionately exposed, particularly to sharp rises in gas prices.

For many SMEs, energy costs represent a meaningful share of operating expenses, particularly in sectors such as accommodation, retail, and food production. This leaves them more exposed to sudden price volatility, especially when access to tools and finance might be limited.

As costs rise, margins tighten and cash flow becomes less predictable, leading to increased uncertainty for both SMEs and lenders. For financial service providers – with over £68bn in SME lending portfolios – this shapes how risk is assessed and how capital is allocated.

At the same time, SMEs remain difficult to assess due to limited and inconsistent data. Rising uncertainty could push banks to tighten credit conditions across their portfolios, resulting in a feedback loop where SMEs face higher costs and reduced access to finance, while lenders carry greater uncertainty and risk.

Perseus provides a more complete view of energy costs

By expanding to include gas data, Perseus directly addresses this problem. In March 2026, the Perseus scheme began incorporating gas data, supporting calculations of Greenhouse Gas Protocol Scope 1 (direct) emissions alongside the Scope 2 (indirect) electricity emissions.

Moving beyond electricity to provide a more complete view of SME energy consumption and emissions gives SMEs better control over their energy exposure, while enabling banks to assess risk, verify impact, and finance the transition with greater confidence.

With this expansion, Perseus is estimated to have potential reach of over 1 million UK SMEs and cover over 70% of use cases, reflecting the scale of energy data across organisations.

For more on Perseus gas emissions methodology: https://ib1.org/perseus/emissions-calculations/ 

For SMEs, this means:

• reduced time, cost, and complexity of reporting
• a more complete and credible picture of energy use and emissions
• better access to finance and incentives
• potential for lower cost of borrowing

For banks and lenders, it enables:

• more accurate assessment of SME energy exposure
• improved risk pricing and credit decisions
• comparable, standardised data across portfolios
• the ability to develop targeted financing products linked to energy performance

Renewables over reliance

Reliance on fossil fuels remains a key driver of energy market volatility. It’s not an imagined scenario either, with Reuters recently reporting that wind output in Q1 2026 increased significantly year-on-year, helping to drive a ~16% drop in gas-fired generation. This cushioned the UK from the impacts of the gas price spike and contributed to relatively lower wholesale power prices versus some European peers. 

As more low-cost renewable electricity comes online, reliance on gas, and exposure to its volatility, can be reduced. This means the shift towards a cleaner renewable energy future is more than an environmental move but a financial one too, creating new opportunities for both SMEs and Financial Service Providers. 

While renewables can reduce our reliance on gas, flexibility determines how much of that value can actually be captured. For more on the impact I&C Flexibility can have on renewables take-up and the wider energy market, read our latest blog.

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

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

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

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

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

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

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

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

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

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

Perseus is infrastructure, not a product

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

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

Data silos are no longer business moats

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

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

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

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

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

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

No single organisation can build what Perseus builds collectively

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

These are fair points, but miss what Perseus is.

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

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

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

Collaborate on the rules, compete in the game

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

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

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

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

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

To go far, we go together.

Join Perseus today

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.

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.