Government and regulated-sector reference models
This is the sixth of 8 Technology Architecture modules. Reference models are common in government, defence, utilities, and regulated sectors. This module covers the G198 government reference model guidance, regulated-sector patterns, and the discipline of borrowing useful structure without mistaking borrowed vocabulary for local architecture.
By the end of this module you will be able to:
- Explain what reference-model thinking contributes in public and regulated settings
- Describe the G198 and G21D government enterprise architecture guidance and its key recommendations
- Distinguish borrowing structure from copying another organisation's architecture wholesale
- Apply the adopt, adapt, or resist framework to reference-model decisions
- Identify regulated-sector patterns for energy, water, and transport utilities
- Relate reference-model use to London's regulated utility context without losing the local case reality

Real-world case · 2022
Four months mapping. Zero decisions changed.
In 2022, a regulated water company was asked by its board to demonstrate alignment with a cross-sector digital infrastructure reference model published by a government advisory body. The architecture team spent four months mapping the company's technology estate to the reference model's categories.
The result was a set of diagrams that looked impressively aligned but told the Architecture Board nothing it did not already know. When a non-executive director asked, "What architecture decisions did this alignment exercise change?", the team could not point to a single one.
The reference model had been treated as a compliance target rather than as a source of useful structure. The team had copied categories instead of borrowing the thinking behind them.
If a reference-model alignment exercise produces impressively aligned diagrams but changes no architecture decisions, what has the enterprise actually gained?
This module explains the difference between borrowing useful structure and copying categories, covers the G198 and G21D government architecture guidance, identifies regulated-sector patterns, and provides the adopt-adapt-resist framework for reference-model decisions.
41.1 Why reference models exist
Reference models can give the enterprise a shared vocabulary, a stable structural baseline, and a way to compare or align architecture thinking across programmes, institutions, or regulated domains. That can reduce needless argument and make interoperability or assurance work easier.
The benefit is structure, not substitution. A reference model is not the local architecture. It is reusable guidance that may or may not fit well enough to adopt directly. The Enterprise Continuum in TOGAF recognises this explicitly: it classifies architecture assets from very generic (useful anywhere) to very specific (useful only in your organisation). Reference models sit towards the generic end. Local architecture sits towards the specific end. The enterprise needs both.
Reference models are common in government, defence, utilities, healthcare, and financial services. In each setting, they serve a similar purpose: reducing the cost of argument about common structure so that the enterprise can focus on the local differences that actually matter.
“Reference models are valuable when they improve vocabulary, comparison, or interoperability. They become harmful when they are mistaken for the local architecture itself.”
Working definition derived from G21D government enterprise architecture guidance - G21D, Using the TOGAF Framework in the Government Enterprise Architecture Context
The distinction between borrowing structure and copying categories is the central message. A reference model should make local architecture easier to explain, not unnecessary.
41.2 The G198 and G21D government guidance
G21D, "Using the TOGAF Framework in the Government Enterprise Architecture Context," is the primary TOGAF Series Guide for government and regulated-sector architecture. It provides guidance on how to apply the ADM in environments with strong accountability requirements, multi-organisation interoperability needs, and external assurance obligations.
Key recommendation 1: Reference models as accelerators, not replacements. G21D positions reference models as accelerators that reduce the cost of common structure but insists that local architecture reasoning must still happen. The enterprise should be able to explain its architecture in its own terms, not only in reference-model terms.
Key recommendation 2: Cross-organisation interoperability. Government and regulated-sector enterprises often need to share data, coordinate processes, and demonstrate assurance across organisational boundaries. Reference models help by providing shared vocabulary and structural patterns. But the interoperability must be tested in practice, not just mapped on paper.
Key recommendation 3: Accountability and evidence. In government and regulated settings, the architecture must support accountability to external bodies: regulators, audit committees, parliamentary scrutiny, or industry oversight. Reference models can provide a structure for that accountability, but the evidence must be local and specific.
Key recommendation 4: Multi-tier governance. Government enterprises often operate across multiple tiers: national strategy, departmental programmes, agency delivery, and local implementation. Reference models can provide consistency across tiers, but each tier must have enough architectural autonomy to address its own specific responsibilities.
41.3 The adopt, adapt, or resist framework
The useful relationship with a reference model is not binary. The enterprise does not have to adopt it completely or ignore it entirely. Three positions are available, and the architecture team should make a deliberate choice for each element.
Adopt. Borrow structure or vocabulary with little change because the local context is close enough and the model genuinely helps. This works when the reference model was designed for a context similar to the enterprise's own. Adoption saves time and improves comparability. But adoption without assessment is copying, not architecture.
Adapt. Use the model as a starting point but translate it to local responsibilities, controls, and service realities. This is the most common useful position. The enterprise benefits from shared vocabulary without pretending that every category fits precisely. Adaptation requires the team to identify where the reference model fits, where it needs translation, and where local extensions are needed.
Resist. Choose not to force the model where it would add compliance theatre rather than better architecture understanding. This is the right choice when the reference model was designed for a fundamentally different context. Resistance is not rejection. It is an informed decision to develop local architecture rather than force-fit borrowed structure.
For each reference-model element, the architecture record should state which position was chosen and why. That record makes the reasoning visible to the Architecture Board and to external reviewers.
41.4 Regulated-sector patterns
Regulated sectors share common architecture patterns that reference models can capture. Understanding these patterns helps the enterprise know what to look for in a reference model and where local translation will be needed.
Pattern 1: Regulatory reporting architecture. Regulated enterprises must produce regular, auditable reports for external bodies. The architecture must support data collection, validation, transformation, and submission with full audit trail. In energy, this includes LTDS publication. In water, it includes annual performance reporting to Ofwat. In transport, it includes safety reporting to the Office of Rail and Road.
Pattern 2: Multi-regulator environment. Many regulated enterprises report to more than one regulator. A distribution network operator in the UK may need to satisfy Ofgem (economic regulation), NCSC (cyber security), DESNZ (energy policy), and the HSE (health and safety). Each regulator has its own framework, vocabulary, and evidence requirements. The architecture must support all of them without creating a separate system for each.
Pattern 3: Operational technology governance. Regulated utilities operate safety-critical OT systems that have different governance requirements from enterprise IT. Reference models designed for enterprise IT rarely address OT governance adequately. The enterprise needs its own OT governance architecture, informed by but not copied from IT-focused reference models.
Pattern 4: Cross-sector data exchange. Utilities and regulated enterprises often need to exchange data with other organisations: other utilities, market operators, regulators, and national bodies. Reference models can provide shared data models and exchange standards (like the Common Information Model in energy), but the implementation must reflect local system realities.
41.5 Common reference-model families
Federal Enterprise Architecture Framework (FEAF). Used in US federal government. Defines performance, business, data, application, infrastructure, and security reference models. Useful for vocabulary and comparison in large government settings. Most directly applicable to US federal agencies but provides structural patterns that other governments adapt.
UK Government Digital Service (GDS) standards. The UK government publishes service standards, technology code of practice, and spending controls that function as de facto reference models for government digital services. These are less formally structured than FEAF but more practically influential in the UK context.
TOGAF government guidance (G21D). Explains how TOGAF applies in government and regulated contexts. It does not impose a single reference model but provides guidance on how to use reference-model thinking within the TOGAF framework.
DoDAF and NATO Architecture Framework (NAF). Defence-sector frameworks that define architecture viewpoints for operational, systems, and technical perspectives. Relevant to defence suppliers and organisations that interface with military systems.
Sector-specific models. Energy, water, transport, and healthcare sectors often produce their own reference architectures. In energy, the Smart Grid Architecture Model (SGAM) and the Common Information Model provide domain-specific reference structures. These tend to be more useful than cross-sector models because they address domain-specific responsibilities.
The key principle across all of them is the same: borrow structure, do local analysis, and record the translation decisions.
Common misconception
“Aligning to a reference model means copying its categories into the local architecture document.”
The moment a reference model starts replacing local analysis, it is no longer helping the architecture. It is protecting the team from doing the harder work. A reference model should make the local architecture easier to explain and compare. It should never make the local architecture unnecessary.
London Grid Distribution: reference models in a regulated utility
London Grid Distribution sits in a strongly governed environment, so reference-model thinking is useful. It can help with common structure, regulated vocabulary, and external comparison. But the London architecture still has to explain the real utility context.
What London should adopt. The Common Information Model for electricity network data exchange is a well-established, domain-specific reference model that London should adopt where it applies. The NCSC Cyber Assessment Framework provides a structure for cyber security assessment that London should adopt for its regulatory reporting.
What London should adapt. Cross-sector digital infrastructure reference models (like those published by government digital bodies) provide useful vocabulary for enterprise IT services but do not address OT, telecom, or field-communications specifics. London should adapt the IT categories and develop its own vocabulary for OT and telecom domains.
What London should resist. Generic enterprise architecture reference models designed for office-based organisations do not address the safety-critical, OT-heavy, field-operations-intensive reality of a distribution network operator. Forcing London's architecture into those categories would hide the most important local responsibilities.
- Regulated context increases the value of reference-model thinking but does not remove the need for local architecture.
- The London case should look informed by external structure, not replaced by it.
- OT, telecom, and field-communications domains are poorly served by most general-purpose reference models. London needs its own vocabulary for those layers.
- The adopt-adapt-resist decision should be recorded for each reference-model element so that external reviewers can see both the alignment and the local reasoning.
A regulated utility maps its technology estate to a government reference model and produces a set of aligned diagrams. A board member asks which architecture decisions the alignment exercise changed. The team cannot identify any. What does this suggest?
According to G21D, how should government and regulated-sector enterprises use reference models?
An architecture team is evaluating a cross-sector digital infrastructure reference model. Three of five categories map well to the enterprise. Two do not fit the OT-heavy utility context. What is the strongest approach?
Which of the following is a regulated-sector architecture pattern identified in this module?
Key takeaways
- Reference models are reusable structure, not a substitute for local architecture. The Enterprise Continuum classifies assets from generic to specific; reference models sit towards the generic end.
- G21D provides four key recommendations for government and regulated sectors: reference models as accelerators, cross-organisation interoperability, accountability and evidence, and multi-tier governance.
- The adopt, adapt, or resist framework gives the architecture team three deliberate positions for each reference-model element, with recorded reasoning for each choice.
- Regulated-sector patterns (regulatory reporting, multi-regulator environment, OT governance, cross-sector data exchange) help the enterprise know what to look for in a reference model.
- Copying too literally produces compliant-looking but weak architecture. The strongest test: would removing the reference-model labels reveal a gap in the enterprise's own thinking?
- In London, CIM and the NCSC CAF should be adopted; cross-sector digital infrastructure models should be adapted for enterprise IT while developing local OT and telecom vocabulary; generic office-enterprise reference models should be resisted.
Standards and sources cited in this module
G21D, Using the TOGAF Framework in the Government Enterprise Architecture Context
Full guide
The primary TOGAF guidance for government and regulated-sector architecture. Referenced throughout this module for reference-model thinking and adoption reasoning.
Federal Enterprise Architecture Framework (FEAF) Overview
Overview and reference models
US federal reference architecture framework referenced in Section 41.5 as a major government reference-model family.
The TOGAF Standard, 10th Edition (C220)
Part 5, Enterprise Continuum and Architecture Repository
The core standard for the Enterprise Continuum concept that classifies architecture assets from generic to specific, providing the theoretical basis for reference-model use.
NCSC Cyber Assessment Framework
Full framework
UK national cyber assessment framework for operators of essential services, referenced as a reference model London should adopt.
Smart Grid Architecture Model (SGAM)
Overview
Energy-sector reference architecture referenced in Section 41.5 as a domain-specific model more useful than cross-sector alternatives for energy utilities.
You now understand how reference models can help without replacing local architecture reasoning. The next question is how to run technology gap analysis that stays capability-led rather than product-led, and how to record trade-offs that survive Architecture Board review. That is Module 42.
Module 41 of 64 · Technology Architecture
