Photo: Alban Tarlet (Accenture), Gavin Starks (IB1), Tom Rogers (Accenture), Ned Chappell (IB1)

The partnership comes during a critical evolution of the UK energy sector, as organisations look to harness the value of data sharing to support innovation, improve interoperability and unlock new services. 

Together, IB1 and Accenture will explore opportunities across data governance, data sharing, AI assurance and sustainability verification, building on existing relationships and opening up new areas for collaboration.

Accenture brings their deep client relationships and delivery capability, while IB1 brings its market-neutral convening, established cross-sector network spanning finance, energy and water, and live operational trust services. 

Tom Rogers, Managing Director, Energy Networks at Accenture UK&I said “Data and AI are crucial for delivering affordable clean power in the UK and for unlocking economic growth. We are really excited to work with IB1 on this important mission.”

Alban Tarlet, Managing Director, Utilities at Accenture UK&I said “Utilities must deliver more capital investment, with greater resilience, under closer scrutiny than ever. That is only possible if the right data reaches the right people at the right time. Working with IB1, we can help organisations embed data sharing as an operational capability “.

Gavin Starks, IB1 CEO, added, “IB1’s role has been, and continues to be, helping everyone agree common components businesses can implement across policy, legal, technical, definitions and communications. Working with leading consultancies will deliver interoperability at scale, reducing risk and enabling innovation. The arrival of AI accelerates this work.”

The collaboration reflects a shared mission to ensure that decisions being made today about data sharing, interoperability and the future of digital infrastructure will have a lasting impact on the UK energy market, and beyond. 

About Accenture

Accenture is a global professional services company specialising in information technology, management consulting, and digital transformation, helping leading businesses, governments and other organisations build. https://www.accenture.com

Meeting Aims:

1. To introduce all participants 
2. To establish ways of working and expectations
3. To introduce and discuss work to date on the I&C Flex use case
4. To establish the agenda for the next meeting alongside the areas for prioritisation for the next six months

Summary:

It was agreed that:

• members would send suggestions for additional stakeholders and end users through Icebreaker One before making direct approaches, to avoid duplicating outreach.
• members could add future use-case ideas to the shared log and provide further comments when the minutes were circulated.

It was noted that:

• discovery research has engaged more than 80 people across 51 organisations, but direct engagement with industrial and commercial (I&C) end users remains difficult.
• the proposed problem statement was that I&C businesses lack the trusted data needed to build robust business cases for flexibility participation. The two proposed use cases were accelerating access to diverse, cost-effective finance for flexibility-enabling technologies, and better evidencing the carbon impact of flexibility actions for ESG and corporate decarbonisation purposes.
• a decision on the UKRI Consumer-Led Flexibility Fund application is expected by 28 October 2026, however, the programme will continue in some form regardless of the outcome.
• a concern was raised that the project could lose its data-sharing focus if it tried to address every barrier to I&C participation.
• the group planned to meet quarterly, with the next meeting expected 21st January 2027.

It was discussed that:

• the draft problem statement prompted questions about whether the required data does not yet exist, or exists but is not reaching I&C businesses.
• the business case for flexibility could consider:
  • the value of assets across different markets and the disruption involved in installing them;
  • whether available revenue forecasts extend far enough to support investment decisions, although the appropriate forecast horizon remains open.
• further direct engagement with I&C end users could help establish what data they need. The commercial sector and geographically distributed businesses were identified as underserved.
• case studies were suggested to help I&C customers understand opportunities and potential revenue. Relevant ESG-reporting work and existing data-sharing standards were raised separately as possible areas to explore.

Next meeting: Thursday 21 January 2027

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

These are confidential to the Advisory Group Members.

Meeting Aims: 

1. Update members on SPV and milestone progress made since the last meeting
2. Deeper discussions and alignment on key SPV priority areas raised in the last SG

Summary:

• It was agreed that:
  • the next SG should be postponed until the anticipated consultations on the Digitalisation Coordination Function and Architectural Reference Framework have been released.
• It was noted that:
  • further consultation activity on the Digitalisation Coordination Function and the Architectural Reference Framework is is anticipated later in 2026, scheduled to be November/December.
  • the Smart Data Repository is continuing to be developed, with work on licence conditions by Ofgem and a review of security identified as key areas of work.
  • the SPV is a proposed, rather than agreed, route to provide an independent, cross-sector coordination model while retaining Data Domain Coordinator representation and expertise in governance.
  • the future coordination model remains under development.
  • it would be useful to test a number of the aspects that had been discussed through individual one to one engagement with SG members, preceded by a “pulse survey” as a simple way to gauge views.
• It was discussed that:
  • the Digitalisation Coordinator would need to balance deep domain expertise with credible independence, including management of both actual and perceived conflicts of interest.
  • there may be a need for cross-sector and cross-domain coordination where data journeys, trust frameworks, and associated legal, identity and security requirements extend beyond individual energy data domains.
  • clear roles, remit boundaries, decision rights, escalation routes and dispute-resolution processes are needed between Data Domain Coordinators and the future Digitalisation Coordination Function, to avoid duplicated activity.
  • behavioural safeguards, including ring-fencing and ethical walls, were raised as possible ways to manage conflicts. The discussion did not conclude whether these would provide sufficient independence without a separate legal structure.
  • a cross-cutting, use-case-led approach could help address data needs that are not clearly covered by the current domain model.
  • Trust frameworks may need to support alignment across sectors while reflecting differences in data sensitivity, security and access requirements.
  • the SPV’s funding, governance, implementation approach and pace of establishment require further consideration.
  • the value case for coordination should consider both costs and benefits, recognising that the benefits of data governance can be difficult to quantify directly.

Next meeting: TBC

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

These are confidential to the Steering Group Members.

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

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

Thank you for considering our submission.

Consultation response:

The Icebreaker One (IB1) NOVA principles – Networked, Open, Verifiable Architecture – guide our approach to data governance and associated responsibilities within the energy data landscape. This approach recognises that trusted data sharing requires more than technical infrastructure: it requires coordinated governance, clear rights and responsibilities, interoperable systems, and transparent, adaptive rules. This is particularly relevant to energy, where data is distributed across many organisations and across sector/vector boundaries, and where unlocking flexibility and investment depends on trusted interactions between many market participants with different characteristics. NOVA guides us to consider architecture supporting trusted, permissioned and auditable data flows in a manner that reduces friction, supports open participation, and encourages scalable reuse of data and data-sharing infrastructure. It provides the foundation for aligning technical, legal, policy and commercial requirements needed to turn fragmented energy data into a trusted, usable and investable resource within a thriving wider digital ecosystem.

Question 1: Do the data types in scope for each domain provide a complete representation of each domain?

The proposed approach and associated groupings have internal consistency. We agree that data requirements will evolve as the energy system and new use cases develop. The framework should ensure it retains sufficient flexibility to amend and expand domain scopes over time. A Digitalisation Coordinator could identify and address potential blind spots and cross-domain dependencies that may not appear when domains are defined primarily by data origination. 

We note that the current approach to data domains does not always consider data journeys, dependencies and how data is used in practice, including beyond the boundaries of the traditional energy system. This creates blind spots to energy-relevant data that exert critical influences on the practical running of the sector, particularly: 1) economic and market data, 2) demographic and behavioural data, 3) weather, climate and environmental data, 4) carbon reduction and net zero data, and 5) security data. It is difficult to provide a comprehensive set of suggestions as to how data under these categories are incorporated, as they likely extend beyond current domain categories as well as influencing the four existing domains. Categories such as carbon, weather and security data, for example, implicate all domains. 

Gaps in specific domains are addressed under Q3.

Question 2: Which domain is best placed to coordinate meter asset data, considering the use cases the data supports, governance arrangements and cross-domain interoperability? Please explain your reasoning.

We align with the position that there is significant potential for crossover between consumer and metering domains around meter asset data and note that this is reflected clearly when use cases or data journeys are considered. Whichever Domain Coordinators are assigned to lead, communication and alignment between associated domains will be essential. We suggest that this may be a role that the Digitalisation Coordinator is positioned to oversee as, in addition to this particular issue, it is likely that all domains will evolve over time and other remit boundaries are likely to come into question. The Digitalisation Coordinator could apply a consistent approach to identifying and managing where this occurs. One significant consideration when assigning the lead coordinator is the question of rights over the data. 

As domains and ecosystems evolve and become increasingly complex (e.g. due to AI application), the use cases and data journeys, rights and lawful bases for data access, and requirements for cross-domain interoperability should be considered. Identifying long-term data rights is critical to operational resilience. We suggest that the Digitalisation Coordinator may play a role in exploring this space, connecting with actors outside the sector who may use the data, and understanding data journeys / use cases which cross domain boundaries. This position does not mean that we advocate for a coordinator to overstep or take back power from the domains; rather, it is a practical note that such a body provides a useful vehicle for approaching inter-domain concerns such as those illustrated in this consultation.

Question 3: Are there any additional data types that should be included, or data types that could sit in alternative domains than their categorisation in Table 1?

We note several gaps and areas requiring clarity. Reflecting our position in Q1, five categories of data appear to be largely absent from the current model: 1) economic and market data, 2) demographic and behavioural data, 3) weather, climate and environmental data, 4) carbon reduction and net zero data, and 5) security data. We acknowledge that the four domains are framed as a starting point, therefore omissions are anticipated. However, given the importance of categories outlined above to energy system function and policy goals, we would welcome clarity from Ofgem as to the intended approach to integrating these areas in future – either within the existing four domains or in forming supplementary domains, and the associated time span for decisions.

Additional gaps within the current domain structure are outlined below:

Core energy system data: 

• We suggest the core system domain currently lacks acknowledgement of market/economic data pertinent to system operation and decision-making that informs this. While some of this is incorporated in balancing and settlement, the current phrasing risks interpretation as a primarily technical matter. Decisions pertaining to whole-of-market factors such as grid mix, generation patterns, fuel prices, interconnection and international markets are also important and do not yet have a clear home. 

Customer data domain: 

• The differentiations between data pertaining to domestic and non-domestic consumers are not always clear. While definitions may be intentionally inclusive at the current stage, there are differences which will require future clarification.
• Secondly, geographic, behavioural and demographic information – informing asset and energy use patterns, customer interactions, product and service development – is currently missing. While this data may be seen as supplementary to purely energy system functions, it is a key part of the economic landscape of the sector and has practical implications in regulation, for example reflected in Ofgem’s consultation regarding potential innovation exemptions to the Universal Service Obligation. 

Behind-the-meter asset domain: 

• Granular data concerning customer and asset behaviour and forecasting is missing from the behind-the-meter domain, which should be acknowledged under the operational data bullet. We note that providers of this data may sit outside the current regulated sector, however they are implicated in the SSES programme and critical to the achievement of policy goals for digitally-enabled system flexibility, DSO transition (e.g. localised balancing) and grid decarbonisation.

Question 4: Is the purpose of Domain Coordinators clear and sufficiently explained to guide delivery and accountability? If not, where is additional detail required? 

There is sufficient explanation to guide the purpose of the Domain Coordinators at a general level. Areas of technical, engagement,  governance and operational responsibility are clearly identified. We support the suggestion that outputs for each Domain Coordinator – data domain definition, stakeholder map and engagement strategy, and delivery plan – are published openly where possible. We also note that the current content does not explicitly include legal and licensing within technical delivery and accountability, and suggest that this must be specifically named; legal interoperability is a key driver for data liquidity which is often overlooked.

Question 5: Which areas of responsibility should transfer from Domain Coordinators to the future digitalisation coordination function? How could the transition be managed to avoid any duplication or gaps?

As flagged in Q1, we note a number of cross-domain data which currently do not have a clear home. We encourage Ofgem to consider the relationship of these horizontal data ecosystems to the four data domains as well as their relationship to the Digitalisation Coordinator.

Beyond this, we agree with the areas proposed in 3.13 for consideration of transfer to the Digitalisation Coordinator. We note that other potential areas of handover could include:

• Oversight of cross-domain engagement programmes and approaches to inclusion
• Identification and coordination of cross-domain use case development
• Identification and upward reporting of the emergence of new data domains and/or changes to existing domains (this is potentially part of the suggested horizon scan function)
• Coordinate cross-domain approaches/standards for licensing (as part of technical coordination) and integration thereof with the DSI
• Coordinate the application and interpretation of data rights across domains
• Coordinate Trust Framework interoperability within a federated landscape.

Question 6: Do you have views on the most appropriate regulatory mechanism for overseeing and enforcing the Domain Coordinators role?

Coordinators have significant influence over how data is defined, accessed, exchanged and governed, including through the development and maintenance of standards. All coordinators also lead development of infrastructure, platforms or work programmes supporting data exchange (DSI and CCS primarily, with Elexon’s DIP and future FMAR work of additional note). This creates a concentration of influence integrated across the data ecosystem in each domain. Given the breadth of influence that a Domain Coordinators have, appropriate regulatory oversight and safeguards will be important to ensure that this role is exercised transparently, proportionately and in the interests of the wider energy system – including decarbonisation goals and consumer outcomes. While we understand that Domain Coordinator embeddedness may create efficiencies, we suggest that it strengthens the argument for the Digitalisation Coordinator to hold a higher level of legal and organisational neutrality, as well as the behavioural neutrality expected from Domain Coordinators. We anticipate this will offer the advantage of an additional check/balance supporting regulatory controls.

We recognise – and support – that the data itself will remain decentralised with existing data holders. We suggest that this principle is formally written into oversight programmes for the coordinators, including the Digitalisation Coordinator.

We also recommend that safeguards outlined in the consultation must be complemented by explicit requirements around conflict of interest management, transparency, accountability, and separation of functions. This would help mitigate the risk of a coordinator inadvertently becoming a gatekeeper to data, standards or infrastructure. We suggest that Ofgem draws a clear distinction between where organisations are performing pre-existing market functions and where they are performing Domain Coordination functions – particularly if NESO is to be governed under existing Ofgem Expectations. This could be complemented by KPIs which are designed to evidence collaborative, domain-level improvement in addition to specific organisational deliverables. 

For governance of all Coordinators, we raise for consideration the potential for creation of a new, bounded licence type to support direct regulatory control. There is precedent for the establishment of defined, purpose-specific licences through the creation of the Smart Meter Communication Licence. As sector digitalisation evolves, considering a new purpose-limited type of licence for data and digital functions may hold advantages. However, this is not an area which has been subject to much exploration within existing policy, industry, or academic literature, suggesting that it may take time and resources to explore or establish. 

Question 7: Do you agree with the proposed funding approach for the Domain Coordinators role? If not, what alternative approach should be considered?

We support the proposed approach and nuance between different organisation types taking on Domain Coordinators roles. If investment in particular domains requires additional focus, funding models may need to evolve. Likewise, oversight from Ofgem will be required to ensure that Coordinators provide comparable value for money, even if responsibilities are non-identical. In considering value for money, we encourage Ofgem to measure contributions towards decarbonisation and consumer value in addition to financial metrics.

Question 8: What specific KPIs or success measures for digitalisation progress could be included to measure success of the Domain Coordinators role within each domain?

We broadly agree with the type of KPIs outlined in section 3.19 . However, these are only a baseline approach and we envisage them developing with more clarity as the coordinators take up work in this space. As outlined above, it is critical for KPIs to be tied to measurable progress at the domain level, within reason and relevant to the appropriate context, rather than relying solely on outputs delivered by the coordinating organisation. 

Areas in which KPIs could benefit from more specificity include:

• Ensuring there is an accessible feedback process for logging changes to the domain; for example, notifying the coordinator of new data assets or asset types.
• Publishing the criteria by which data quality is determined and assessed.
• Assessing balance within the engagement sphere to ensure an even spread of perspectives is included; ‘strong and active engagement’ does not necessarily require this to be open or representative.
• A commitment to regular review/challenge of governance arrangements to empower the Coordinators to act with agility.
• KPIs assessing the impact of Coordinator activity on decarbonisation and delivering customer value would be useful for tracking how digital progress interacts with wider sector objectives.

Question 9: Do you agree with the proposed governance decision-making, reporting and oversight arrangements for Domain Coordinators? Are these clear and proportionate? If not, what should be changed?

On decision-making:

• Evidencing engagement is an important part of these requirements. Reflecting our comments in Q12-14, there are certain gaps in the engagement model which require attention prior to relying on engagement as a source of validation.
• We support the proposed position to work with existing code, license or governance arrangements where possible. We query how the Domain Coordinators will interact with these mechanisms where remits exceed the definition of the data domain – for example, where using existing avenues may engage stakeholders or surface use cases that extend beyond one individual domain. Defining the approach to these instances will also be relevant for defining the role and remit of the future Digitalisation Coordinator.
• We encourage openly published meeting minutes and decisions wherever possible, alongside quarterly reporting to named stakeholders. The quarterly reporting may be in more depth or surface higher sensitivity information. 
• Decisions referred to the Digitalisation Board under 4.5 may implicate the Digitalisation Coordinator in future.

On quarterly reporting:

• We encourage open publication of reports wherever possible, with clear rules as to where information is redacted or edited for public consumption if it is sensitive. Consistent application of these rules is helpful for supporting a coherent approach to transparency and disclosure in a multi-actor system.

Upward reporting and decision-making:

• We agree that the role of the Digitisation Delivery Group (DDG) and relationship to Domain Coordinators is clear and appropriate. 
• References to the future role of the Digitalisation Coordinator providing a preparatory and advisory function match our expectations of the role and its utility in providing a space and resource for balanced consideration of materials for advisory purposes.

Question 10: Do you agree with the proposed technical requirements of Domain Coordinators, including data standards, data quality, domain definition and access to data? If not, which responsibilities should be amended and how?

We agree with the proposed technical requirements of the Domain Coordinators. However, we believe that a distinction should be made between the function of setting requirements and supporting outcomes, and that of detailed management arrangements within individual organisations, with the latter remaining out of scope for the Domain Coordinators. An outcomes-based approach would allow organisations to set requirements without prescribing the detailed arrangements that implement requirements. This would provide organisations with the flexibility to determine the most appropriate arrangements for their individual circumstances, while maintaining clear focus on achieving intended outcomes. 

Data Access

We support the proposed responsibility for Domain Coordinators to establish standardised access processes, with the additional expectation that the DSI should provide the mechanisms of access control when possible. We recommend that the guidance makes clear that Domain Coordinators are responsible for the identity verification, credentialing and licensing policies that are necessary to enact data access controls within their domain, with coordination across domains to ensure interoperability and streamline processes for data users.

Data Standards

The development and maintenance of a data standards catalogue should be represented through the DSI. We also encourage the use of open standards within the data standards catalogue rather than limiting the approach to standards that already exist. This should be accompanied by the overarching coordination function to promote interoperability between standards across the wider ecosystem. Without this cross-domain perspective, there is risk that Domain Coordinators develop standards that only work effectively within individual domains and not across domains.

Data Quality

We support the principle that the Domain Coordinators should establish expectations around data quality, but metrics and requirements should be informed by actual use cases. These quality metrics are context dependent and datasets that are fit for one purpose may not be adequate for another. We also note that many use cases are cross-domain, providing value for the overarching coordination function to examine quality across domains.

Digital Infrastructure Requirements

Requirements for digital infrastructure should similarly be developed through engagement and informed by use cases, supporting cross-domain interoperability. Additionally, while we understand the transfer of 5.24 and 5.25 responsibilities to the Digitalisation Coordinator function once established, domain-specific issues will likely need input from Domain Coordinators. 

Identification and Development of Use Cases

We agree that identifying use cases should be a critical component of the Domain Coordinator role. This responsibility should be transparent, including the logging and publication of identified use cases where appropriate. This provides visibility of the evidence base informing priorities and technical requirements. The methodology for developing and prioritising use cases should be based on genuine use cases and user needs rather than just dataset availability. This distinction avoids designing a system around only existing data rather than the outcomes that data is intended to enable. The Digitalisation Coordinator will likely have an important role in identifying and supporting use cases that extend across domain boundaries, supporting a more interoperable data ecosystem. 

Question 11: Are any key technical requirements missing, unclear, not proportionate or not deliverable in practice?

Currently, the consultation does not address standardisation of licenses as part of the technical components of delivery. This is a critical element of interoperability as, ultimately, a technically interoperable data landscape can still be limited by legal interoperability challenges that slow or stop dataset combination for the delivery of real use cases. We strongly recommend that license identification and standardisation is included in the technical remit for Domain Coordinators, supported by interaction with the Digitalisation Coordinator to enable license interoperability across domains and translation to license representations within relevant Digital Infrastructure. Where multi-party preemptive licenses are developed, we suggest that the Digitalisation Coordinator takes an oversight role to support consistency of approach throughout the sector and promote cross-sector interoperability.

We separately note that this consultation implies Domain Coordinators will take on an active role in shaping domain agreements – e.g. on standards adoption – that will then be codified into the DSI to accelerate data exchange. Formal technical and governance relationships between data Domain Coordinators and the DSI are yet to be fully established. We suggest that both data Domain Coordinators and the Digitalisation Coordinator establish and transparently document their relationships to digital infrastructure projects. This is particularly important where functions are held by the same body.

Question 12: Do you agree with the proposed engagement requirements of Domain Coordinators, including strategic engagement, technical engagement, and engagement of consumer groups and smaller organisations? If not, which requirements should be amended and how?

We support positioning engagement as a key responsibility for the Domain Coordinators. We also support consideration of engagement including technical, consumer, small organisation, and participant groups. However, certain aspects of the engagement requirements would benefit from additional robustness and prioritisation of context-specific methods to avoid over-reach or fatigue in a landscape with high existing engagement demands.

We note that meaningful engagement must be balanced with the potential for engagement fatigue, which has already been raised within the sector around digital developments. It is particularly significant for small or non-profit organisations with fewer available resources and time; engagement structures must be designed sensitively to avoid unintentional exclusion of these actors. We suggest that a clear plan for inclusion is necessary and that there is benefit to this being openly published. In future, this may be something requiring oversight from the Digitalisation Coordinator to support consistency and promote efficiencies that can reduce risk of engagement fatigue and/or flexible response to periods of high engagement demand. In parallel, we note that good stakeholder engagement practice – e.g. evidenced through IB1’s DAFNI-DINI programme – requires circularity; programmes in which participants understand the value and outcomes of their engagement are perceived more favourably than those which are considered to be more one-sided or extractive.

We also note that engagement approaches outlined do not explicitly name end users as stakeholders that should be included in engagement processes, beyond consumer groups. We suggest using a use case lens for stakeholder mapping and engagement can be constructive for ensuring representation from the full data value chain.

Finally, we suggest that Domain Coordinators may find achieving a balance between existing and supplementary routes an area requiring sensitive handling, particularly to ensure that there are not discrepancies or preferences unintentionally applied to various settings. We encourage Domain Coordinators to consider questions such as:

• Where supplementary engagement groups are constructed, how will these interact with existing forums? Are discussions in either group privileged in any way (e.g. information asymmetry, powerful voices in the room, visibility of what the other group has discussed or decided)?
• How will participants be given appropriate voices and opportunities? 
• How will disagreements be handled and/or reported between groups?
• Are there different weightings given to decisions made within or between groups? How might this interact with existing groups that have set governance and voting structures? 
• How will competing interests and priorities be balanced if discussions are separate?

This response is not to suggest that the above challenges are insurmountable, however they do flag the risk of creating unintentional asymmetries or imbalances that have potential to undermine trust and legitimacy of engagement processes without adequate consideration.

Question 13: Which strategic, technical, consumer group or smaller organisation stakeholders or stakeholder groups should be engaged for each domain?

As noted in Q12, we advocate a use case lens to approach engagement across the data value chain. This can also help reduce engagement fatigue by targeting engagement strategies to the most relevant participants informed by context. Without further context it is difficult to provide a comprehensive response. IB1 is happy to discuss our approach to stakeholder mapping and engagement separately if useful to support this consultation.

Question 14: Are any key engagement requirements missing, unclear, not proportionate or not deliverable in practice?

Reflecting Q12, we would welcome further detail and/or guidance provided to Domain Coordinators about how to set up, govern, and communicate between engagement tracks happening separately to pre-established routes.

Question 15: Do you agree with the proposed governance requirements of Domain Coordinators including requirements to participate in governance forums and operational reporting? If not, which responsibilities should be amended?

We support the proposed approach which appears proportional, deliverable and appropriate to the short-medium term. We acknowledge that approaches may require adaptation over time. We suggest that consumer outcomes and decarbonisation are explicitly included in reporting as topics for monitoring and reporting regarding the strategic direction and impact of Domain Coordinator activity. We also recommend that these outcomes are formally included under the heading ‘Track digitalisation progress’ (7.17-7.20). 

Question 16: Are any key governance requirements missing, unclear, not proportionate or not deliverable in practice?

See Q15.

Bid submission: 26 August 2026 | Project start: 1 December 2026

Icebreaker One is leading a bid consortium for UKRI’s Consumer Led Flexibility (CLF) competition, part of the Clean Energy Superpower Mission. Our focus is building the trusted data sharing infrastructure required to make industrial and commercial (I&C) energy flexibility work at scale.

Many businesses are facing pressures around rising energy costs, the need for greater operational resilience, and growing expectations around net zero commitments. This project helps organisations understand where flexibility exists within their operations, how it could unlock access to finance for low-carbon investment, and how flexibility actions can contribute towards emissions reporting and decarbonisation goals.

As a consortium partner, you’ll help shape the infrastructure that could make these opportunities easier to access across the market.

Why join?

Partners will work with the consortium to:

• source and analyse energy data from a target site or business stream
• understand where flexibility capacity genuinely exists within safe operational limits
• explore how that capacity grows as you electrify (EV fleets, heat pumps, solar, batteries)
• investigate what it all means for your emissions reporting.
• shape an innovative smart data Scheme 

Participation is designed to fit around your organisation. Together, we’ll agree on the trial scope whether that’s target sites, single business lines or dummy data rather than live. Automation is the goal, not manual participation.

Why now? 

I&C consumers remain under-represented in flexibility markets, and participation has actually declined since the 2010s. Despite 170MW of I&C flex being added in 2026, the Clean Flexibility Roadmap estimates that another 580MW will be needed by 2030.

Over six months of discovery research with more than 70 stakeholders across 48 organisations we found that the business case for flexibility often doesn’t stack up on market revenues alone, and the data needed to unlock wider value is often fragmented. 

We’ve therefore narrowed our focus to:

1. Access to enabling finance through faster, cheaper routes to funding low carbon tech, flexibility assets and control systems
2. Evidencing carbon impact so flexibility actions can count towards decarbonisation strategies and ESG reporting

We’re particularly interested in multi-site businesses with multiple business lines or complex, varied demand profiles, exactly the type of organisations the current market is least set up to serve. 

Cost recovery and work package ownership are open for discussion in line with UKRI funding rules.

Key dates:

26 August 2026 – Bid submission
28 October 2026 – Applicants notified
1 December 2026 – Project start

Given the submission date, we’d like to hear from interested organisations in the next couple of days. Reach out to gea@icebreakerone.org

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 welcome Ofgem’s focus on strengthening the governance of energy system data but believe this consultation should fundamentally be about improving decision-making rather than selecting a technical solution. Before investing in new infrastructure, there must be a clear, transparent, and consistent process for assessing what data should be open, shared, or closed. Processes must be applicable at the level of individual datasets, however the sector also requires a mechanism for considering publishing decisions at the aggregate level, for example when risks associated with publication multiply at scale. Without this, there is a risk of building technology that does not address the underlying governance challenge. 

We support the Educational Model as the preferred approach, subject to some adjustments, as it addresses the challenge of improving decision-making without introducing centralised infrastructure that has potential to compound security and resilience risks. We also recommend expanding the assessment criteria to explicitly consider liability, governance, resilience, and interoperability. Responsibility should remain clearly assigned to each data publisher while recognising that some risks require collective assessment. A Trust Framework provides the appropriate mechanism for a collective approach to decision-making, data triage and risk assessment without centralised data infrastructure.

Effective governance should define, articulate, mandate, and enforce a monitoring, reporting, and verification process to ensure published data meets agreed requirements while allowing technical implementation to remain decentralised. This approach avoids creating single points of failure, strengthens system resilience, and maintains interoperability through common standards and assurance mechanisms. The Digitalisation Coordinator should focus on establishing and maintaining governance processes rather than operating centralised technical services.

We strongly recommend the adoption of a transparent, evidence-based approach to risk assessment. The consultation proposes solutions before clearly describing the threats, vulnerabilities, or risk reduction expected from each option. A structured risk assessment with established methodologies, such as the NCSC Framework, should underpin any changes to Open Data policy. Security considerations must also be balanced against the UK’s net zero objectives, recognising that unnecessarily restricting data access may hinder consumer benefits, innovation, system coordination, and decarbonisation without reducing risk. Given that much infrastructure information is already publicly available, decisions should be made based on demonstrable risk reduction rather than assumptions about the benefits of data restriction. 

Consultation question responses:

Question 1: Please provide examples of where data made available under DBP Guidance has allowed your business model to develop either new products and services, or make efficiency savings?

Icebreaker One and partners have used the data extensively in our work to assess and develop use cases enabling data to work harder to support energy system decarbonisation. Data made available under the DBP guidance has supported use cases in areas including, but not limited to:

• EV infrastructure development, including a targeted use case serving households without off-street parking 
• Heat decarbonisation and heat pump roll-out
• Local authority planning and LAEP development
• Cross sector data sharing between energy-water-telecoms for e.g. storm response
• Community energy build out supporting the Local Power Plan

Use cases are especially valuable in considering data security as these provide an opportunity to clearly define the purpose of data access, identify relevant stakeholders, and understand user needs. This approach helps minimise unintended consequences by ensuring that decisions about whether data should be open, shared, or closed are based on clear understanding of who needs the data, for what purposes, and under what conditions. 

Currently, we are using the data to form part of our development work to assess how a data sharing scheme could accelerate Industrial and Commercial (I&C) participation in electricity flexibility. Data included in the landscape assessment supporting the use case includes: network flexibility data (e.g. forecasts, zoning, trades), network constraints/headroom, and connections data (e.g. LCT connections, capacity registers). 

Question 2: Do you agree with the criteria underpinning the Options Analysis as described above? 

The proposed criteria provide a useful basis for the Options Analysis, but we believe they are currently incomplete and, in some cases, do not fully support an objective comparison of the proposed models. We make the following observations on the existing criteria.

Ownership and accountability: We are concerned that the current scoring does not appear to reflect that distributed responsibilities, when supported by common standards and governance, can provide clear and consistent accountability. There is a risk that the scoring methodology unintentionally favours centralised delivery models by assuming that the Digitalisation Coordination Function (DCF) is able to define and operate triage standards and processes internally that cannot be disseminated and carried out by data publishers. The scoring should assess how standardisation and governance can reduce risk irrespective of architecture. They should also flag where risks are present with regards to assigning responsibilities to the DCF as a body whose remit has not yet been defined.

The assessment should also consider how conflicts of ownership and decision-making would be managed in practice. For example, tensions may arise between network operators and a central coordination body where publication decisions differ, particularly if decisions contradict current publication requirements set out by sector governance regimes such as the Codes. Similar complexity exists for smart meter data, where governance may overlap between the Smart Energy Code (SEC), Central Switching Service (CCS/RECCo), UK GDPR, the Data (Use and Access) Act, Data Access and Privacy Framework, and Ofgem’s Data Best Practice Guidance. We therefore recommend that the assessment explicitly considers governance arrangements and conflict resolution mechanisms, in addition to whether any proposed central body (e.g. DCF) would assume the role and responsibilities of Data Controller under UK GDPR.

Data security:  We agree that data security should remain a core assessment criterion. However, security should be assessed across the entire data lifecycle, including how data is stored, governed, transferred, and accessed, rather than focusing solely on publication decisions. In particular, the analysis should recognise that centralising data storage or transferring data to a central body may increase systemic risk by creating attractive targets for attack and introducing potential single points of failure. These architectural trade-offs should be explicitly reflected in the assessment.

Data quality:  We welcome the inclusion of data quality into the assessment. To clarify scoring in this area, we suggest providing an authoritative definition of what is meant by “data quality”, distinguishing, for example, between schema compliance, completeness, accuracy, timeliness, and fitness for purpose. This distinction is particularly important when assessing the extent to which automated processes can improve quality. The assessment should also identify who is responsible for improving data quality under each option, together with the associated implementation and operational costs.

Cost:
We encourage further transparency on the assumptions underpinning the cost assessment. In particular, it is unclear how anticipated savings for individual licensees have been calculated and whether these represent genuine efficiency gains or simply the transfer of costs to a central coordination function. The analysis should also consider how any savings would be used in practice. For example, would reduced expenditure on local publishing platforms enable greater investment in data quality, governance, and workforce capability, or would these simply be treated as financial savings? In addition, we are concerned that indirect costs – including staff training, specialist expertise, organisational change, and ongoing governance – are underrepresented relative to technical implementation costs. In our experience, these organisational costs frequently exceed technology costs and should form part of any comparison of delivery models.

Question 3: Would you suggest any other criteria that you would consider critical for analysis?

We recommend the following additions to Ofgem’s analysis criteria:

Liabilities: while ownership/accountability is an analysis criteria, this does not fully enable the required assessment of who/which body would be held liable for publication decisions, nor assess processes required to handle situations in which data publishers and other relevant decision-makers disagree. In the Hybrid model, it is also notable that the use of automated processing may incur a specific discussion of liability where machine decision-making interacts with human decisions. Liabilities assigned to a potential DCF are also significant and not yet discussed, which requires further thought – particularly where liabilities are affected by other forms of legislation (e.g. Data Use and Access Act (DUAA)) or Codes (e.g. DCUSA data publishing specifications).

Governance: The governance of a system cannot be left as separate to the architecture of the system, but governance details would benefit from further depth in all options. In the Central and Hybrid functions in particular, this creates a large and undefined burden on a future body, whose own format and governance model remains subject to future consultation. As part of governance assessment, we suggest that Ofgem considers the clarity, transparency, and accountability of decision-making processes. For example, processes for assessing risks at the collective level, and determining action, would benefit from further detail. Such processes are important as they intersect with liability assessments. For example, if a licensed entity’s decision to publish Open data is challenged, this is left at conflict with the licensee’s internal process and/or potential obligations under industry codes.

Resilience: current analysis does not identify and assess risks emerging from the potential to create new single points of failure within the energy data landscape. This consideration goes beyond practices within monopoly bodies to also implicate single points of failure regarding aspects such as:

• An open data publishing portal (central/hybrid models)
• Decision-making (central model)
• Automation processes (central/hybrid models)

Interoperability: while the consultation presents arguments for open data publishing to be architecturally separate from other Trust Frameworks, this separation should not be extended to process and data assurance. IB1 suggests that the triage process – and the off-ramp for sharing data subject to restrictions (Shared data) – is not adequately discussed. Rather than presenting a vulnerability, consistency of process and data governance between the DSI, adjacent Trust Frameworks (e.g. CCS, Open Banking, IB1) and Open Data practices lend benefit to data security. Additionally, integration with Trust initiatives in the sector could offer the benefit of integrating Identity and Verification (ID&V) for data users and publishers, thereby streamlining onboarding, increasing confidence in the provenance of published Open Data and reducing the capacity for bad actors to misrepresent themselves across different platforms and processes. Failing to integrate could also unintentionally increase costs through duplication, as flagged via industry engagement groups in relation to Trust Frameworks being developed for the DSI and CCS.

We include analysis under these four categories as part of our response to Q4-6 below.

Question 4: Do you agree with our Option Assessment scoring and conclusion for the Centralised Model?

Our analysis suggests that a Centralised model presents the highest risks and lowest additional advantage as a pathway for improving the sector’s open data security, as well as uncertainty on costs. While the current Options Assessment captures some of these risks, we suggest that the full depth of risks to data security presented through centralised infrastructure have not been fully explored. There are also considerable legal and governance implications for permitting a central coordination body to view and triage all raw data. We suggest a number of points below that, if incorporated in the scoring, we believe would downgrade the Centralised model to the lowest scoring option.

Data security:

• 3.9: ‘The process flow diagram above shows how licensees would send ESD (untriaged) through their Data Preparation Node (DPN) across the Data Sharing Infrastructure (DSI), where it would be subject to Data Quality (DQ) review and then passed to a Triage Function within the Digitalisation Coordination Function.’:
  • Transference of large volumes of data to a central body creates a large threat risk, as acknowledged in the wider literature on information security and engineering. While section 3 describes this as ‘reducing the threat surface area’ this is not an accurate representation of risk; rather than reducing the threat, it concentrates it.
  • Currently, the Options Assessment does not specify how the proposed central structure would handle key governance decisions such as data deletion. If the body decides that data should not be published, it is unclear how the data is handled, where it sits within the central body vs licensees, and how decisions are documented and recorded. 
  • The boundaries of what raw data is transferred to the central function on this basis are unclear, as well as who makes the decision about what is or isn’t included for analysis. Scope creep presents a potential issue which could increase costs and act as a resource drain in the central body.
• 3.16 ‘the risk of accidental over-publication is lowered’ – analysis currently makes the assumption that trained individuals in the centralised process are less likely to create errors. It is unclear how this is different to equivalently-trained individuals in distributed licensees. Additionally, when they occur, a centralised body potentially increases the scale of consequences for errors.
• We suggest that tooling or methods applied to check triage compliance and consistency could be decentralised, defined and enforced via a Trust Framework. Centralisation of this function is not necessary to deliver the same outcomes.

Cost:

• We agree with the assessment on cost (score 1 – poor). Design, implementation and operation of the triage/data publishing service would duplicate functions already present in DNOs.
• The overall cost score appears to be contradicted by point 3.14: ‘The model should provide savings for the licensees, as the costs of triage and running an Open Data Platform would be reduced significantly’. This depends on how the DCF is funded and managed, which is not yet determined.

Data quality:

• We query why this metric is scored as 4. In particular, we raise concerns that assumptions have been made about the necessity and feasibility of the role that the central function is envisaged to perform in 3.16 ‘Additional data utility benefits can be accrued through a single centralised portal, increasing interoperability, and allowing for data quality and schema validation as part of data processing, increasing the consistency of data offerings across the sector.’:
  • Analysis assumes that the digital coordinator is successful in defining a schema all parties agree with, and 
  • Will ensure that data provided using the schema is conformant (this may be costly or face limits on compliance). 
• We suggest that schema agreement and conformance do not require centralisation; the same outcomes could also be achieved in a decentralised manner via mandating the use of a Trust Framework.

Liability:

• Structure not currently discussed, though the model implies a high degree of reliance on the process and decisions of the DCF. 
• Potential for liability conflict unless clarified.

Governance:

• Governance of key processes run by the DCF are as yet undefined.
• Governance of the process to decide whether metadata is published openly is unclear.

Resilience:

• This model creates single points of failure in relation to process/decision-making and technical architecture (portal). 
• Relationships/liabilities between data providers and the DCF require clarifying with regards to how licensees may be impacted by a failure or breach of centralised systems. 

Interoperability:

• If successfully imposed (this is a risk – see Q2-3), the application of Schema could result in a high degree of data interoperability with the DSI. However, a centralised approach is not the only way to ensure this.
• Legal interoperability must also be addressed; the consultation currently does not propose a function to address licence consistency.
• Interoperability with other Trust Frameworks has not been actively considered in the consultation document.

Question 5. Do you agree with our Option Assessment scoring and conclusion for the Hybrid Model?

Presentation of the Hybrid model offers advantages in terms of checks for consistent application of triage processes, while retaining primary decision-making as a decentralised function. However, the current Option Assessment for the Hybrid Model does not adequately address the governance of automated checks, how this functions with human decision-making, how collective decision-making will be conducted, or how data quality improvements are guaranteed. We believe that amendments to scoring based on points raised below would downgrade the Hybrid model’s overall score and encourage Ofgem to consider this when determining their minded-to position.

Data security:

• Issues related to data centralisation and deletion remain, as described in Q4.
• The automated component of the model may function for certain aspects of assessment – e.g. providing an additional compliance function to check triage steps have been followed – however further exploration of how this interacts with human decision-making would be beneficial.
• Governance of automated checks is not fully described at present. This potentially interacts with gaps in liability assessment identified in Q2-3. Example: dataset is approved by automated compliance function but later found to present risks that were not picked up: does the original data publisher, centralised body, or provider of the tool (if third party) hold liability?
• The model does not fully address how decisions beyond compliance will be made, particularly regarding data which:
  • requires an assessment of risk at the collective level, and
  • requires an assessment of risk related to landscape changes over time.
• We suggest that tooling or methods applied to checking triage compliance and consistency could be decentralised, using a Trust Framework to both define good and enforce it.

Data quality:

• Observations outlined in Q4 are also applicable to the Hybrid model; it is unclear how data quality improvements are guaranteed through this proposal in a manner that is different to improved coordination/accountability applied to decentralised data triage. 

Liability:

• The Hybrid model’s liability structure, and relationship to DCF liabilities, is not yet defined.
• Liabilities for automated processing decisions are not discussed.

Governance:

• Governance of key processes run by the DCF requires definition.
• Governance of automated processes is not currently discussed.
• Monitoring, Reporting, and Verification (MR&V) mechanisms are missing to ensure data published conforms to requirements.

Resilience:

• This model reduces certain single points of failure present in the Centralised model by keeping triage processing decentralised and adding an automated process check. 
• However, the data portal element remains centralised, as does data Schema assessment.

Interoperability:

• If successfully imposed (this is a risk – see Q2-3), the application of Schema could result in a high degree of data interoperability with the DSI. However, this can also be achieved in a more decentralised manner than the Hybrid model presents.
• Legal interoperability must also be addressed; the consultation currently does not propose a function to address license consistency.
• Interoperability with other Trust Frameworks has not been actively considered in the consultation document.

Question 6: Do you agree with our Option Assessment scoring and conclusion for the Educational Model?

We disagree with the current scoring of the Educational Model. In particular, the Options Assessment does not address how decentralisation automatically increases security threats despite high cybersecurity standards within licensees, why data quality cannot be assured with effective data governance, or any MR&V mechanisms for the proposed model. 

Ownership and accountability: 

• We suggest that this score is revisited; distributed ownership does not necessarily complicate accountability. All data publishers are regulated parties whose accountability to Ofgem, and other bodies, is guaranteed in relation to many other functions they deliver. We disagree with the current assessment score on this basis. 

Data security:

• We disagree with the low scoring for this category. Licensees are required to maintain high cybersecurity standards for many forms of operational data, including critical national infrastructure. Based on this, it is unclear why distributed responsibility equates to low cybersecurity scoring.
• We suggest that distributed data presents a lower security threat than centralised infrastructure for several reasons. This includes:
  • No single point of failure or leverage
  • Different internal security infrastructure at each licensee makes “full spectrum” breaches much harder
  • Untriaged data does not leave the organisation boundary
• On this basis we suggest that the data security score is reviewed and recategorised. 

Data quality:

• We disagree with the low scoring for this category. The assessment appears to define data quality through only a centralised scheme validation despite the ability for agreed standards, accountability, and assurance processes with effective data governance. 
• The same data quality investments considered for the Centralised and Hybrid model should be included for the educational model. 

Liability:

• Liability is clearly assigned to each data publisher.
• Collective liability would need to be addressed, e.g. in the case where data publishing needs to be assessed at the collective level. This could be addressed meaningfully through a Trust Framework approach with appropriate governance and associated decision-making.

Governance:

• Effective governance within a Trust Framework can define what is required and enforce it without centralisation.
• MR&V mechanisms would be required to ensure data published conforms to requirements.
• The Educational Model could be adapted to give publishing parties the triage check tooling from the Hybrid Model that otherwise sits centrally in the digitalisation coordinator. The DCF, or anyone else who has the specifications and technical ability, could provide the checking functionality, allowing the DCF to focus only on decision-making and collective assessments.

Resilience:

• See security section above: this option presents significant advantages by avoiding the creation of single points of failure and making a full spectrum breach less likely. 
• We do not believe that system resilience has been adequately accounted for in Ofgem’s current analysis – doing so could significantly change the minded to position.

Interoperability:

• A Trust Framework can support interoperability by establishing common requirements and assurance mechanisms across publishers.
• Identities and standards established in the DSI trust framework may be used to harmonise trust signals for Open data, such as provenance and assurance, with those for data shared securely within the DSI, with both operating the same peer-to-peer data sharing principle.

Question 7: Do you agree with our minded to position? If not, what is your view as to the best approach to this issue?

We support Ofgem’s focus on strengthening data governance but believe the key challenge is improving the decision-making framework and governance processes that determine whether data should be Open, Shared, or Closed, rather than developing new technical infrastructure. Our preferred approach is the Educational Model, strengthened through a Trust Framework, enabling collective decision-making and standard-setting for data triage and risk assessment. With the addition of governance, liability, resilience, and interoperability as core criteria, the Educational Model provides more robust assurance while avoiding unnecessary centralisation of technology or liability. Effective governance should establish clear standards with monitoring, reporting, and verification processes, allowing the DCF to focus on oversight and decision-making. Any changes to Open Data policy should be supported by evidence-based risk assessment that balances security considerations with consumer benefits, innovation, system coordination, and progress towards net zero. 

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

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

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

Read the concept note here

Emily Judson

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

Defining the role

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

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

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

Essential functions

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

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

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

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

Three core capabilities

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

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

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

Delivery body format

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

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

This approach offers several advantages:

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

Evaluating delivery body types

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

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

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

Get involved

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

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

Meeting Aims: 

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

Summary:

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

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

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

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

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

The incentive problem

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

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

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

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

Data & Trust

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

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

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

Communicating value: a hearts and minds challenge

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

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

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

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

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

Help shape the future of I&C Flexibility

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

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

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

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

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

Call for input response

Prioritisation of sectors and use cases

Through IB1 programmes and years of expertise, IB1 supports following a use case approach to data sharing initiatives. This approach centres user needs, makes a business case for the investment in data sharing, and allows for:

1. Market incentives: there must be an economic argument that policy can then amplify or mandate. If there is no financial incentive, there will be no movement.
2. Removal of transactional friction: There must be “something in it” for everyone, or at least a path to cost reduction or a new business model. Removing friction can help everyone go together: this is never solely a ‘technology problem’ (e.g. absence of a data ontology).
3. Documentation with the identified problem statement, actors and stakeholders, a clear goal, and the envisaged impact. 

Smart Data becomes effective when it is connected

In terms of prioritisation of sector, use cases requiring cross-sector interoperability and cohesion offer the greatest immediate ability to create impact, with a manageable degree of complexity involved in rollout. These use cases support private sector growth and require achievable government intervention, allowing green growth and environmental goals to be met.

User and customer needs should be identified through a robust governance process which can understand, process, and define use cases with relevant stakeholders. In IB1’s Scheme governance (standard operating procedures), IB1 emphasises the importance of having a user needs & impact advisory group which explores, prioritises, and works through use cases (including identifying users, their needs, and mapping data value chains). This process allows for the development of business, value, and impact cases and their impact on policy, businesses, and financial instruments. 

To maximise the benefits, use cases must:

• Address governance, user needs, business, social, legal, engagement and communications to ensure the solution is fit for purpose, and can be adopted by the market. IB1 observes that technical-led programmes tend to fail to gain traction or deliver against material user needs.
• Foster a community to ensure there is cross-sector collaboration. IB1 strongly recommends taking a joined up approach which is interoperable with initiatives across the economy. IB1 suggests defining relationships with adjacent bodies in the sector and beyond to enable cross sector interoperability.

For identified energy use cases, see IB1’s response to DESNZ energy smart data scheme call for evidence question 14. 

The interplay between industry and government progress in developing schemes or regulations, and how to encourage fast progress

It is important that progress toward sharing data is incentivised before waiting for one perfect data sharing solution to be built as there is demand for data immediately. 

For example, in the near-term it is unlikely that the energy data sharing infrastructure (DSI) will be suitable for all use cases, as it is currently unclear when and how non-regulated actors will be able to access data via the DSI, for what purposes, and under what assigned roles. These actors constitute major customers for connections data (e.g. heavy industry, retail, local authorities etc). While they may well be users of the DSI in future, opportunities to service these data customers in a secure, structured and well-governed manner must not be put on hold until the DSI is ready. 

As there is demand by non-regulated users for data now, there would be benefits to developing high-impact schemes in the short term that operate autonomously, but are legally and technically structured to facilitate integration with future common data sharing infrastructure. It is essential that as the government makes progress on developing schemes and regulations that they do not block valuable industry initiatives from being established quickly.

The coordination layer

To enable valuable government and industry schemes to progress quickly in parallel while remaining coherent and interoperable, IB1 strongly recommends intentional coordination of the cross-programme rules, standards, credentials and access controls that make data flow possible at scale. We recommend that responsibility for the coordination layer sits in an independent mission-locked entity that holds – or subcontracts – the sector’s Trust Framework and provides the sector’s neutral data coordination function. While different ownership options exist, industry co-ownership and co-Directorship of such a body provides a meaningful route for ensuring stakeholder buy-in and co-funding, akin to the model of Open Banking Ltd.

A neutral data coordination function must consider:

• How will schemes’ governing bodies coordinate with developments within and beyond their own scope? 
• How will this feed into goals, design choices, and definition of technical/architectural parameters? 
• How might this need to evolve over time? For example, sectoral coordination laddering up to cross-sector.
• How might Scheme development interact with overarching sector and national data/digitalisation strategies?
• How can Schemes encourage competition, markets and service creation within and across boundaries?

The coordination function requires a Secretariat to act as a neutral facilitator for participatory governance processes which can adapt flexibly to evolving coordination needs and ensure accountability. This requires:

• Strong governance processes – e.g. covering participant selection, means of input, minuting, reporting, and decision-making
  • Ability to offer tailored mechanisms where required – e.g. working groups to focus on specific sectors or data flows, or task-and-finish groups to support elements of data strategy delivery.
  • Flexible staffing, with ability to take on additional domain specialists/contractors as necessary
• Experienced administrators to execute governance processes and communicate expectations of timescales, plans, key decisions etc.
• Where required, the provision of independent chairing or facilitation services
• Dispute resolution processes, linked to existing sector mechanisms and to individual Scheme governance processes where relevant.
• Participant accountability mechanisms 
• Commitment to open publishing as a default approach (unless there is strong reason to do otherwise) 

It is vital for the coordination body to be fully independent; it cannot be nested in a body with pre-existing market functions without risking conflict of interest or transparency problems. 

Effective coordination should also be supported by monitoring in two key areas:

• Mapping of the domain(s) in which coordination is enacted in order to support effective participatory governance in an ongoing manner
• Monitoring and reporting on the outcomes of coordination activity to improve transparency and join-up with adjacent policy/regulatory goals
  • Where relevant, this may additionally include monitoring the delivery of a sector’s data strategy / roadmap.

We suggest that the above activities would require a small permanent staff to ensure continuity of process and expertise, with additional needs met via subcontracting and secondment on a time-limited basis for agile response to emergent needs (e.g. particular technical or domain expertise concerning a coordination challenge). This lightweight approach delivers the intended benefits at a reasonable cost to the bill or tax payer, supporting the general principle of minimisation outlined earlier in this response.

Finally, we propose that any enforcement powers for the coordinator can be most readily delivered via existing regulatory and legislative capabilities. This reduces cost and risk of establishing new statutory bodies.

Best practice in scheme design, including for vulnerable and other consumers, and to maximise how well the system works for services that use data from more than one sector

A core centralised capability must be the design principles. Critically, aligning on design principles for governance will lead to greater cohesion and interoperability of outcomes. 

Governance processes should collaboratively agree upon:

• The intent to work toward interoperability and working in widely understood formats. 
• Licence compatibility – creation of preemptive multilateral contracts/agreements, including appropriate permissioning where required
• Human- and machine-readable representations of scheme rules
• Adoption of common open web standards as the default (unless insufficient) to allow for widest possible number of technologists to understand
• Open publication of new specifications (legal, procedural and technical) that may be adopted by other schemes to aid interoperability
• The use of consistent tooling that is well understood by stakeholders
• Appropriate proven security standards
• The use of open source 
• Conceptual alignment on what metadata means (better yet  – technical compatibility), and aligning around standards

Within this governance function, there must be adequate consideration of the amount of communications and time needed to convene, design, implement and develop consumer messaging for schemes.

To enable interoperability, IB1 recommends considering how Schemes will interact. Key aspects of this are:

Identity. IB1 suggests this should not be a centralised identity, but a mechanism which can enable cross scheme identity verification. This is a key area of research with further needs around how a federated identity system may work. IB1 is exploring this within Perseus, to enable an identity interaction with Open Banking’s identity establishment. 

Access, licensing and permissions. There is a need to invest in research into this, as uncertainty in rights to access, use, combine, sell or share data is a drag on innovation and introduces unnecessary cost. Different regulatory environments can lead to additional confusion for cross-sector data use. There is potential to develop permissioning and purpose representations that can be understood readily by data users and their customers, but interpreted at scale by machines.

Assurance: Schemes need to address the assurance needs of data users in order to deliver value. Considerations include provenance, quality, processes, auditability, liability and redress. Protections for scheme participants (companies) and the customers they serve must be clear. A common language and machine-readable representation for these aspects of data sharing enables confident use of data and accelerates adoption.

Potential cross-sector innovation support, or data or regulatory sandbox services, and how they are designed 

IB1 recommends investment in common tooling to develop public digital infrastructure and open source support which can be re-used across schemes. 

There is a potential role for the National Data Library to curate common standards for scheme rules and their representations and convene the working groups that define them.

The places and methods through which competition should be enabled or promoted in the smart data system, and the pros and cons involved

Scheme development will be a part of the public digital infrastructure development, with appropriate governance oversight to avoid anticompetitive practices, and to guard against cartels to ensure it is a fair place to do business. IB1 thinks of this as “collaborate on the [data sharing] rules, compete on the [services] game.” It is part of the governance process to delineate what is considered pre-competitive and to have short term targeted projects (e.g. mapping stakeholders who must be consulted when developing a specific area of pre-competitive activity).

IB1 also recommends to include value-mapping guidance in the handbook (recommended approaches to do it for a scheme) and to identify and caution against perverse incentives.

Underlying trust services (for example identity, verification, compliance monitoring, permission management, version-controlled registries of scheme rules) must have open standards, ideally with Open Source reference implementations. Scheme operators should have a competitive market of trust service providers to choose from, whose services comply with these standards. The aim is to create a market that operates along the same lines as the HTTP web standard and web hosting providers. 

Methods and forums for engagement with those outside government and join-up between sector-level and cross-sector developments (such as the guidebook)

• Opportunity to capitalise on existing data sharing governance forums:
  • Perseus
  • Open Energy 
  • Stream
  • https://ib1.org/sops/governance-schemes/
• Any coordinating entity must be accountable to its stakeholders. We suggest this is supported by the following:
  • Openness policies enabling scrutiny (e.g. of methodologies, processes, minutes, reports)
  • Where required (for security purposes), clear rules defining how scrutiny will be undertaken among closed audiences
  • Defined process for dispute resolution integrated with existing sector mechanisms
  • Clear processes for change management
  • Defined avenues for external involvement in participatory processes
• Wider engagement than just the incumbents and/or regulated entities within a sector (e.g. in the energy sector this must include actors beyond the roles licensed by Ofgem)
• Cross sector convening needs to be around coherent use cases with a wide range of stakeholders representing the different roles and stakeholders within the data value chain

Join-up between smart data and other data policy, and with international partners

There are developing debates in sectors such as energy and property as to what is considered under the realm of smart data, versus what is considered ‘system data’  There is potential for some issues emerging there and in other sectors which need to be considered and worked through with the relevant stakeholders. Definitions established under the Data Use and Access Act must be respected where relevant.

It is worth noting that not all data is smart data but will need to interact with other data which could/should be shared for key use cases. We caution against excluding ‘non-smart’ data stakeholders when convening around smart data and other data policy. 

Our most prominent international partner – the EU – has invested heavily in technical infrastructure via its Gaia-X initiative. Outcomes have been mixed, due in part to an apparent assumption that “if we build it they will come”. Recent work by the Data Spaces Support Centre on design principles and governance has the promise to encourage more use cases to be brought forward and be implemented. The UK should have a goal of alignment with EU developments on data spaces, but to aim for eventual harmonisation (as with the advice on interoperability within the UK above) as opposed to full technical interoperability at an early stage. As with all data sharing work, the use case is key here. If a use case requires interoperability with EU dataspaces, or interoperability drives very high value, then it is worth the investment to align and connect. Many use cases will not require this, at least in their initial phases.

Links between smart data and AI adoption and innovation, either within the Industrial Strategy sectors or more widely across the economy. 

AI is moving rapidly from performing tasks for people (“summarise this document in under 300 words”, “tell me the top considerations when buying a new fridge”) to performing tasks on behalf of people (“deploy this software”, “find and book a reasonably-priced vegetarian restaurant in Soho for me and 3 others next Thursday evening”). To perform these tasks, agents will need to access the instigator’s personal data, and to exercise delegated authority to act on their behalf. Both of these may implicate multiple providers, using data and access that the instigator didn’t foresee.

AI and smart data intersect in governance and assurance, enabling trust in AI operation by answering questions such as: 

• Where is personal data stored and processed, and to whose benefit?
• Where did the data the model is using come from? (Both for training and for retrieval-augmented generation)
• What personal data did the model use?
• How much reliance can the user put on the inference?
• How are permissions delegated to AI, and how are consumers protected?
• How does the agent ensure that personal information is protected under GDPR when shared?

Relevant materials

Please see other relevant IB1 call for evidence responses:

• DSIT’s Smart Data call for evidence
• DSIT’s Data intermediaries call for evidence
• DESNZ energy smart data scheme call for evidence
• IB1’s response to Ofgem’s Energy digitalisation governance: architectural coordination letter

General principles

Additional comments:

• Reusability: the methodology for exploring and getting Schemes off the ground can have generic/reusable items. But the Schemes themselves must have capacity for tailoring.
• Minimisation: Schemes should do the minimum possible that enables the use case to be addressed.

Meeting Aims: 

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

Summary:

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

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

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

These are confidential to the Steering Group Members.

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

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

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

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

Not one-size-fits-all

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

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

Data, the great enabler

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

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

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

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

Join Open energy

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

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

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

• 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.

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.

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.

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:

Do you agree with the proposed implementation approach? Yes.

Rationale: We appreciate that there is a governance in place to discuss and approve the proposed implementation. We would welcome further transparency on the outcomes of applications to access data via this method and suggest that a summary of cases are made openly available after a 6-12 month trial period. Ongoing avenues for scrutiny remain important.

Please provide any further comments you may have.

As we are looking holistically at the smart meter data landscape, we will continue to work with the SEC and engage as it develops on a case by case basis and impacts wider use cases.

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

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

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

Building trusted open data

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

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

Sector-wide collaboration

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

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

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

Data Action

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

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

Rohan Graham, National Grid

IB1: The great facilitator 

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

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

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

Jay Chen, NGED

What’s next?

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

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

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

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

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

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

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

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

Key points from the position paper

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

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

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

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

Meeting Aims 

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

Summary:

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