Digitalisation Framework: Governance Architecture

“Effective data governance in the energy sector requires clear accountability, defined standards, and enforcement mechanisms that go beyond voluntary compliance.”

Ofgem, Energy Digitalisation Strategy and Framework (2024)

Ofgem's framework articulates what distinguishes governance with teeth from governance on paper. The three elements — accountability, standards, and enforcement — map directly onto the Energy Digitalisation Framework's Board, DBP, and DCF respectively.

The Energy Digitalisation Framework establishes a layered governance structure designed to coordinate digitalisation across the entire energy sector. The structure runs from a strategic board through operational delivery groups to domain-specific coordination, with a cross-cutting working group that handles interdependencies.

The Board

At the top of the governance hierarchy sits the Energy Digitalisation Board. This is the strategic decision-making body that sets the overall direction for energy data digitalisation. The Board comprises senior representatives from NESO, Ofgem, DESNZ, and key industry bodies. Its role is not operational delivery but strategic oversight: approving the framework, resolving disputes between domains, and ensuring alignment with government policy including the Clean Power 2030 target.

The Digitalisation Delivery Group (DDG)

Below the Board, the Digitalisation Delivery Group translates strategic direction into operational coordination. The DDG meets regularly and provides the forum where domain coordinators report progress, flag risks, and resolve cross-domain issues that do not require Board escalation. The DDG is the working level of governance: the place where practical coordination happens between organisations that might otherwise pursue their own roadmaps independently.

The DDG's effectiveness depends on the quality of representation. Each domain coordinator must have sufficient authority to make commitments on behalf of their organisation. If DDG representatives can only “take things back” for internal decision, the group becomes a reporting forum rather than a coordination mechanism. Early evidence suggests that this tension between authority and representation is one of the DDG's ongoing challenges.

The four data domains

The framework divides energy data into four domains, each with a designated coordinator. The domain coordinators are responsible for standards, data quality, and access arrangements within their domain. The allocations reflect the existing institutional landscape:

• Core Energy Data — NESO (confirmed). This domain covers the fundamental data that describes the electricity system: generation output, demand, network topology, constraint data, and system balancing information. NESO's designation as coordinator is logical given its role as system operator and its existing responsibilities for publishing operational data.
• Behind-the-Meter Data — Elexon (provisional). This domain covers data from consumer premises: smart meter readings, demand profiles, generation from rooftop solar, battery storage behaviour, and EV charging patterns. Elexon's provisional designation reflects its role in settlement and its existing access to metering data, though the final confirmation depends on the DCF consultation outcome.
• Metering Data — Elexon (provisional). This domain covers the metering infrastructure itself: meter technical details, communication status, data quality metrics, and the registration systems that track which meter is at which premises. The separation from Behind-the-Meter reflects the distinction between the data that meters produce and the data about the meters themselves.
• Consumer Data — RECCo (confirmed). This domain covers consumer-facing data: account information, tariff details, switching history, consent records, and the data that feeds consumer-facing services. RECCo's designation aligns with its existing role as the Retail Energy Code Company and its development of the Centralised Consent Service.

The distinction between confirmed and provisional designations matters. NESO and RECCo have been confirmed as domain coordinators. Elexon's designation for Behind-the-Meter and Metering data is provisional pending the DCF consultation outcome. This means the governance architecture is not yet fully settled, and the final shape of domain coordination could change depending on consultation responses and Ofgem's assessment.

XTWG: Cross-Domain Technical Working Group

The Cross-Domain Technical Working Group is the mechanism for handling interdependencies between domains. When a data standard change in the Metering domain would affect how Behind-the-Meter data is processed, the XTWG is where that conflict is identified and resolved. When the DSI needs to catalogue data from all four domains using consistent metadata, the XTWG defines the common metadata standard.

The XTWG operates at a technical level, below the DDG's strategic coordination. Its members are technical specialists from each domain coordinator organisation, supplemented by representatives from key industry participants. Decisions at the XTWG level are technical recommendations that feed into the DDG for formal approval. The XTWG does not have independent decision-making authority, which ensures that cross-domain technical decisions are subject to strategic oversight.

DCF: Data Coordination Function

The Data Coordination Function is the proposed body that would provide ongoing coordination across all four domains and the transformation programmes. The DCF consultation is expected to conclude by end 2026, with a mobilisation period of two to three years before the function reaches full operation.

The DCF's proposed role goes beyond what the DDG currently provides. Where the DDG coordinates through regular meetings and consensus, the DCF would have operational authority to set standards, enforce compliance, and resolve disputes. It would be permanently resourced rather than relying on secondments from participating organisations. It would maintain a comprehensive view of all energy data assets, standards, and access arrangements across the sector.

The consultation addresses several fundamental questions. Should the DCF be a new body or an extension of an existing organisation? How should it be funded: through industry levies, regulatory allowances, or general taxation? What enforcement powers should it have? How does it relate to existing regulatory bodies, particularly Ofgem? These questions are politically sensitive because they involve decisions about organisational authority, funding, and accountability that affect every participant in the energy market.

The RIIO-3 price control provides the funding context. The £876.7 million digitalisation baseline in RIIO-3 represents the regulatory allowance for network companies to invest in digitalisation. This is not the total cost of the Digitalisation Framework — it covers the network company portion of the investment. The DCF, transformation programmes, and central bodies are funded through separate mechanisms. But the RIIO-3 baseline establishes the scale of investment that the regulatory framework envisages for energy data digitalisation.

DSAP: Digitalisation Strategy and Action Plan

The DSAP is the primary accountability instrument through which network companies demonstrate their digitalisation commitments. Each network company — the 14 DNOs and the transmission operators — publishes a DSAP that describes its digitalisation strategy, planned investments, and measurable outcomes. The DSAP is assessed against five dimensions:

1. Data management: how the company manages its data assets, including quality, accessibility, and governance.
2. Digital capabilities: the digital tools, platforms, and skills the company is developing.
3. Innovation: how digitalisation supports new approaches to network planning, operation, and customer service.
4. Stakeholder engagement: how the company involves stakeholders in shaping its digitalisation priorities.
5. Delivery and outcomes: measurable progress against stated objectives, with evidence of actual delivery.

The DSAP creates a public commitment mechanism. Because DSAPs are published, stakeholders can assess whether a network company's digitalisation investment is delivering the promised outcomes. Ofgem reviews DSAPs as part of its price control assessment, creating a regulatory incentive for quality and delivery. The five-dimension framework provides a common structure that enables comparison across companies, though the level of ambition and detail varies significantly.

DBP: Data Best Practice

The Data Best Practice guidance, now expanded from guidance to a licence condition, establishes the minimum standards for how energy companies manage and share data. The core principle is “presumed open”: all data should be openly available unless there is a specific reason to restrict it, such as commercial sensitivity, personal data protection, or security concerns.

The DBP moved from voluntary guidance to a formal licence condition in January 2026, significantly strengthening its enforceability. Under the licence condition, network companies must demonstrate compliance with Data Best Practice principles as a condition of their operating licence. Non-compliance can trigger enforcement action by Ofgem, including financial penalties.

The distinction between DSAP and DBP is important. The DSAP is a forward-looking strategy document: it describes what a company plans to do. The DBP is a compliance standard: it describes the minimum requirements that a company must meet today. A company can have an ambitious DSAP that describes transformative future capabilities while simultaneously failing to meet basic DBP standards on data quality and accessibility. The two instruments are complementary but serve different functions in the governance architecture.

Together, DSAP and DBP create a governance framework that combines strategic ambition with operational compliance. The DSAP drives investment and innovation; the DBP ensures minimum standards. The DCF, once operational, will provide the coordination layer that connects domain-specific DSAP commitments into a coherent sector-wide digitalisation programme.