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.

So what’s the difference?

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

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

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

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

Why harmonisation matters: lessons from TNFD

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

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

The benefits of harmonisation

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

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

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

Why harmonisation fits IB1’s approach

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

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

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

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

So when does standardisation have a part to play? 

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

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

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

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

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

The data sharing landscape

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

Harmonisation over Standardisation

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

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

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

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

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

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

The results are in

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

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

What’s next?

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

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

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

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

So what is a smart meter?

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

Not all smart meters are created equal

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

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

Why does the Water Sector matter for net zero?

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

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

What can we learn from energy smart meters? 

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

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

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

But what exactly is a smart data scheme?

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

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

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

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

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

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

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

Smart Data in action

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

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

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

Similarities and differences between household energy and water smart meter systems 

The Act (which covers both consumer and business data) places significant emphasis on Smart Data Schemes. These schemes, which enable secure, user-authorised data sharing between organisations, stand out as a transformative step for the UK economy.  

The benefits are far-reaching, with the potential to unlock innovation, enhance competition, and improve user control and choice. Backed by the UK Industrial Strategy’s £36 million investment in new schemes across financial services, energy, and beyond, these changes promise real-world impact. Open Finance alone is estimated to boost UK GDP by £30.5 billion each year.

Done well, the Data Act will mean:

• Data portability and control of your data 
• Better access to useful data
• Clearer rules and stronger protections for safety and fairness
• Greater empowerment and control for users to enable data sharing
• Foundations for better data sharing governance to enable real-world benefits of apps, AI and related tech services, while better addressing rights, consent and permission

This includes: 

• A statutory code on automated decision-making

Meaning the government will create a legally-recognised code of practice to guide organisations that use automated systems to make decisions. 

• Greater enforcement of the rules

More power to enforce data protection laws, making sure compliance isn’t optional and bad actors are held accountable.

• Increased emphasis on DPIAs (Data Protection Impact Assessments)

DPIAs are risk assessments that organisations must carry out before starting projects that involve high-risk processing of personal data (e.g., large-scale surveillance, sensitive health data).

• What about this whole AI thing?

Advanced software (such as AI and machine learning) is now being used to analyse data and in some cases to automate decision making. These systems are joining data together, in new ways across our economy. If we are to build and maintain trust, both voluntary and regulatory frameworks are essential to ensure they operate not only within the law, but also transparently and in the public interest. You can contribute to our conversation on this here. 

Why Smart Data Schemes matter for a Net Zero future

Smart Data Schemes aren’t just good for the economy – they are essential for our Net Zero future, because decarbonisation requires faster, smarter decisions powered by better data.

Over the past five years, we’ve been turning this vision into impact across energy, water, transport, finance and beyond. Our key learning so far? Implementation matters.

Our data infrastructure is maturing to deliver real-world impact. Initiatives like Open Energy are open, networked and verifiable to enable faster, better decisions to be made across systems. To deliver a net zero future we need data to flow as efficiently as energy itself. 

Through Open Energy, we’re creating a connected web of energy data and have already shown how better access to data delivers tangible, net zero-aligned outcomes. 

For example: 

• Our work with Scottish and Southern Electricity Networks (SSEN), shows how improved data access can better align grid capacity with EV demand. 
• On the REACT project, we found that making data more accessible helps reduce delays in connecting green energy developers to the grid, enabling Transmission Owners to deliver critical infrastructure upgrades faster.

The Act also marks a major milestone for our work on Perseus, a national smart data initiative focused on enabling green finance for SMEs. Recently featured in the Willow Report, Perseus is a live example of how to operationalise Smart Data across sectors. Provisions in the Act (e.g. smart meter data infrastructure) directly strengthen our efforts to ensure every SME can access finance for the net-zero transition.

A decade in the making; the real work starts now

This moment is the culmination of more than a decade of work. In 2012, I was appointed founding CEO of the  Open Data Institute, as the UK became a global leader in open data policy. During my tenure, I initiated what became a founding paper asking Who owns our Data Infrastructure?. 

In 2015, I was appointed co-chair of the Open Banking Working Group that created the Open Banking Standard which proved that Smart Data Schemes could move from theory to practice, creating a blueprint for sectors like energy, telecoms, and transport. And, in 2023 I joined the UK Smart Data Council as its co-chair. 

It’s been over a decade since that initial work and the UK is once again setting the bar on data infrastructure. Legislation is just the starting line: to deliver real outcomes for our economy and our environment, we must now build on this foundation at pace, with the same ambition, urgency, and collaboration that brought us here.

Example: