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.

At the Perseus 2025 AGM it was reported that Perseus is:

• evolving from ‘financing green’ to embedded sustainable finance creating a potential addressable market of £5-10 billion
• adding gas, extending energy coverage from Scope 2 (electricity) to Scope 1
• estimated, via its existing members, to have potential reach of over 1 million UK SMEs and cover over 70% of use cases
• continuing to advance ‘Perseus Ready’ implementations with commercial members
• running a live sandbox (equivalent to production) for use by Carbon Accounting Providers (CAPs) and Energy Data Providers (EDPs) to develop solutions
• working with Perseus members to develop go-to-market capabilities to support hundreds of thousands of SMEs
• exploring integration with Open Banking to enable cross-sector interoperability
• producing XBRL outputs to enable integration with financial reporting systems
• pioneering the development of a voluntary, cross-sector Smart Data scheme, aligned with the UK Data Act and supported by an openly-licensed digital public infrastructure (DPI) architecture for secure data sharing 

“Perseus makes it easier for everyone to do their carbon calculations properly, and comfortably moves us years ahead of the most stringent proposed updates to the GHG Protocol. This is exactly why Sage intends to roll out a Perseus enabled product to make reporting easier for hundreds of thousands of UK SMEs.”

George Sandilands, Vice President, Sage Earth

From financing green to embedded sustainable finance

For much of the last decade, ‘green finance’ has focused on funding individual projects: a retrofit here, a solar installation there. Important, but limited. 

Perseus marks a shift to something far more systemic: it moves beyond financing green to embedding sustainable finance by integrating trusted, verifiable emissions data directly into everyday accounting and financial decision-making.

This evolution means Perseus can be applied across the whole SME market, not just specialist green products. Rather than expecting SMEs to seek out solutions themselves – something most lack the time or expertise to do – Perseus brings trusted insights to where they are (e.g. inside their existing accounting, banking and carbon applications). 

Perseus can support lending, credit and debit products, and even savings accounts, allowing sustainability performance to be reflected wherever financial decisions are made. The impact on SMEs is significant: personalised insights, lower reporting costs, easier access to capital for energy-efficiency upgrades, and new space for financial innovation. By making sustainability data usable at scale, Perseus aims to help turn ‘net zero’ from a niche ambition into a normal feature of how the economy works.

“As a leading smart data initiative, Perseus is developing guardrails for assurable data to support finance and supply chain decisions towards a sustainable economy.”

Hannah Gilbert, Director of Sustainability, British Business Bank

We are pleased to announce that IB1 will be supporting The Retail Energy Code Company (RECCo) in the design and development of Ofgem’s  policy position to implement a Consumer Consent Solution (CCS). 

The CCS is a secure, digital solution that empowers energy consumers to control who can access their energy data. It enables people to easily grant, manage, review, and revoke consent. This supports transparency, consumer choice, and strong data protection across the retail energy market. 

IB1’s Role

IB1 will provide expert advisory support, assisting in the design of the Trust Framework that underpins the CCS. This framework will be central to ensuring that the service is reliable, transparent, trusted and usable by both consumers and market participants.

We will leverage our extensive experience in designing, developing, and advising on Trust Frameworks, Consent and Permission, and in cross-sector stakeholder engagement to deliver market-scale solutions. 

In particular we will bring learnings from the Perseus project, which enables SMEs to securely share emissions data with banks, calculated from their metered energy consumption, in a permission-based framework.

Sharing data with consumer or business consent is at the core of the smart data economy heralded by the Data (Use and Access) Act 2025. We are delighted to be working on a key initial focus of the Act, and intend for our learnings to be repurposed across sectors to help achieve legal, policy and technical alignment.

We spoke with Pierre Tabet, Founder and CEO of Voltview, about how the company began, the growing role of smart data schemes like Perseus, and Voltview’s contribution as part of the Perseus technical advisory group. We also explored how banks, eager for more accurate data to strengthen their ESG reporting, are likely to see Perseus as a critical enabler.

Ross: How did Voltview begin? 

Pierre: So, I started Voltview just over two years ago. I’d always been interested in the energy sector, having previously worked as a back-end engineer for an energy management company. When I moved back to the UK, I knew I wanted to stay in that field.

At the time, I began speaking to business owners who were unknowingly in the middle of the energy crisis. Many were still on fixed contracts, but when their renewals came up, their bills more than doubled. Hospitality businesses were hit especially hard because of their high energy consumption. For example, one fish and chip shop I spoke with saw annual bills jump from around £10,000 to £35,000. That kind of increase can threaten the viability of a business.

We saw huge pressure on SMEs, and I realised that’s where Voltview should focus. Early on, I had conversations with Smart DCC, who pointed me towards a government grant for smart tariff comparison in the non-domestic sector. Now, we just missed out on getting that grant, but we were still interested in the space. And from there we pivoted slightly.

Rather than just offering comparisons, we wanted to combine switching with retrofits, so businesses could save on tariffs and reduce consumption. Think of it like Booking.com: when you book a flight, they also suggest hotels, car hire, or insurance. But in energy switching, businesses never get offered solutions like heat pumps, EVs, or electrification measures, even though the data used for switching could easily support those recommendations. With reforms like market-wide half-hourly settlement, that data is more valuable than ever. It felt wasteful for switching to end with just a new tariff, when it could instead trigger bigger energy and cost-saving changes.

Ross: This makes a lot of sense to me. Especially now, what with rising energy costs. It reminds me of Open banking and how it opened up consumer choice. How do you ensure the data accuracy and transparency when you’ve got these tariff comparisons? 

Pierre: Open banking is a great comparison as it allows you to share financial data with authorised third parties, who then provide tailored services. As I’m sure you know, the government now wants to replicate that model in energy, having passed the Data Use and Access Act. 

This is especially relevant in the commercial sector- currently about 80% of UK commercial buildings aren’t compliant with the EPC B rating required by 2030. Non-compliance could mean fines. To address this, businesses need access not just to energy data but also building data, credit scores, financial history, everything required to prioritise and fund retrofits.

What’s really cool now is, a lot of the administrative work which took up a lot of energy consultants’ time, can now be done with AI, so that they’re only working on sort of the high value work.

Ross: That’s really interesting. How exactly can EPC data be linked to financial impact? Is there a link to green mortgages here, in a similar vein to SME emissions data being linked to green finance with Perseus? 

Pierre: Absolutely. Perseus is a great example and we’ve been lucky to contribute on the technical side. It provides a trusted way to share Scope 2 emissions data with banks, who in turn reward businesses with lower interest rates.

The bigger picture here is increasing electrification. In the UK, only about a quarter of energy use is electricity, compared to roughly half in Norway. To close that gap, we need incentives  like cheaper capital for retrofits, particularly for SMEs. Many owners are busy running their businesses, so making retrofits easy is critical to driving uptake.

Ross: And so you’ve got EPC data, half-hourly meter data, and financial data – how hard is it to bring all that together on one platform?

Pierre: It is challenging. Only about 60% of UK business meters are smart compared with roughly 95%+ in some European countries, so many firms are effectively flying blind. The first hurdle is getting half-hourly data; the second is aligning it with building and financial data. We start with specific use cases and design the simplest possible customer journey around them.

Ross: Very cool. And as you mentioned, the Data Use and Access Act should hopefully accelerate this work and smart data schemes like Perseus. I also saw on your website that your clients save 17% on energy bills. Can you share an example of this?

Pierre: Sure. Savings usually come from two areas: matching clients with tariffs that suit their load profiles, and cutting waste. One example was a restaurant kitchen where the ventilation system was switching on at night. The owners had no idea until we flagged it with half-hourly data alerts. Fixing that single issue accounted for about a third of their total savings. So really the savings are already in the data- you just need the right tools to uncover them.

Ross: Let’s dig into Perseus a bit more. How have you found being involved in its development?

Pierre: It’s been a great experience. We’re part of the technical advisory group, which has focused on making Perseus trustworthy, scalable, and incredibly easy for users. Ultimately, it’ll be as simple as ticking one box. In December, when Perseus trialled the process manually, it gave us confidence in how it can work at scale. We’re now about six months away from real-world rollout, and we’re excited to integrate it into our ecosystem.

Ross: And what would that integration look like for Voltview?

Pierre: It might not sit directly on our platform. We may simply guide clients to enable it through their accounting software. The point is that all our customers gain access to cheaper capital for retrofits, regardless of where they switch it on.

Ross: Do you think financial institutions are ready to adopt Perseus and scale up green finance for SMEs?

Pierre: Increasingly yes, the real bottleneck is data quality not intent. Almost half of FTSE 100 companies have had to restate climate metrics every year, mostly due to emissions in their suppliers. Banks and lenders want more reliable data to strengthen their own ESG reporting and sustainability-linked products. Perseus helps by providing verifiable upstream data so there is less estimation, fewer restatements and more confidence to deploy capital.

Ross: Great. To wrap up, what’s next for Voltview?

Pierre: We are nearing the end of the Smart Data Challenge funded by the Department for Business and Trade. The challenge has been to incorporate more cross-sector data into our platform. Our next step is to launch use cases that almost any SME can tap into by sharing their energy, building and financial data. We will announce these later this October as we complete the Smart Data Challenge.

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: