Ofgem proposes binding data rules for code managers

Ofgem has proposed changes to code managers’ standard licence conditions that would make compliance with energy Data Best Practice guidance a formal regulatory requirement.

Digitalisation Strategies and Action Plans would also become subject to a consistent licensed framework, replacing an approach in which data improvements have depended more heavily on individual code processes and voluntary adoption.

Code managers administer the detailed commercial and technical rules supporting market operation. Their work covers modification proposals, consultations, meeting records, implementation programmes, technical documents, system interfaces, and datasets used by networks, suppliers, generators, traders, service providers, and system operators.

In January 2026, Ofgem decided not to extend the proposed obligations through separate modifications to each energy code. Standard licence conditions now provide the preferred route, allowing common requirements to be applied across licensed code-management organisations without repeating the same change through several governance processes.

The proposals seek to make data more discoverable, accessible, interoperable, and usable while maintaining suitable controls over personal, commercially sensitive, and security-relevant information. Digitalisation plans would identify existing limitations, delivery priorities, dependencies, planned improvements, and measures of progress.

Code managers, code administrators, central system bodies, energy companies, technology providers, and other affected organisations have until 10 September 2026 to respond through the formal consultation process.

Code information increasingly feeds automated systems

Energy codes developed around separate market, settlement, network, and technical functions, leaving information distributed across documents, databases, identifiers, access arrangements, and update cycles. Combining those sources can require extensive reconciliation before a new technology or market participant can automate even a relatively defined process.

A usable digital framework requires more than placing existing documents into machine-readable files. Names, units, timestamps, asset identifiers, geographic references, metadata, quality indicators, version controls, and change histories must be sufficiently consistent for receiving systems to interpret the information without additional manual correction.

Code modifications also carry consequences for software and operational processes. A rule change may require alterations to settlement platforms, market interfaces, network controls, participant systems, data exchanges, testing environments, and implementation schedules, with dependencies extending across several organisations.

Digitalisation Strategies and Action Plans can provide a managed route through those dependencies by identifying priority datasets, user needs, legacy-system constraints, delivery dates, and ownership. Once placed within licence conditions, progress becomes subject to regulatory oversight rather than remaining solely a matter of organisational intent.

Proportionality will remain necessary because code managers differ in scale, technical responsibility, data volume, and system maturity. Requirements suited to a central settlement platform may be excessive for a smaller governance function unless implementation reflects the operational consequence and complexity of the information involved.

Accessibility must also be distinguished from unrestricted publication. Network topology, vulnerability details, personal information, and commercially sensitive records require controlled access, meaning that effective digitalisation must incorporate classification, authentication, authorisation, logging, retention, and secure interfaces.

Ofgem is developing related governance through its proposed energy data-domain coordinator model, which would allocate responsibility for standards, quality, accessibility, and interoperability across defined areas of the energy system.

The two initiatives address different layers of the same infrastructure. Code-manager obligations concern the organisations maintaining formal technical and commercial rules, while domain coordination would span datasets and participants extending beyond individual code boundaries.

Alignment will be required to prevent duplicate reporting, inconsistent identifiers, or competing standards. A code manager could be required to follow Data Best Practice while exchanging information through a domain governed by separate technical specifications, making ownership and version control essential.

As interfaces become more standardised and information easier to combine, cybersecurity and operational resilience will require equal attention. Automated exchange can reduce manual error and administrative cost, but it can also allow inaccurate data, unauthorised changes, or software faults to propagate more widely.

Identity management, validation, monitoring, approval workflows, and recovery arrangements must consequently develop alongside interoperability. The objective is not merely to publish more information, but to create datasets that can be trusted within market, settlement, planning, and operational systems.

The consultation moves energy-code digitalisation towards enforceable delivery, with final effectiveness dependent on the quality and usability of the resulting data. Strategies and licence obligations will provide limited benefit unless they produce maintained interfaces, consistent definitions, accountable ownership, and measurable improvements within the systems that depend on them.