Why non-domestic data access could become one of the biggest issues facing TPIs and brokers
The Energy Consultants Association has written to Ofgem, DESNZ, RECCo, the ICO, the CMA, Elexon, SECCo, Smart DCC and ElectraLink to raise urgent concerns about the future of non-domestic energy data access.
This may sound technical, but the issue is simple: if the industry gets this wrong, TPIs, brokers and customer-appointed representatives could find it much harder to access the Half-Hourly data needed to help customers switch, validate bills, challenge errors, compare offers and identify energy-saving opportunities.
That would not just affect TPIs. It would affect customers, competition and the delivery of net-zero services across the non-domestic market.
What is being developed?
Several major data-access initiatives are now developing at the same time.
RECCo is designing the Consumer Consent Solution, known as the CCS. This is intended to give customers a central way to grant, manage and revoke consent for sharing energy data. It is being developed under Ofgem’s direction and will sit within the Retail Energy Code framework.
Elexon is developing the Smart Data Repository, known as the SDR, through BSC Modification P494. This follows Market-wide Half-Hourly Settlement, under which Elexon will receive far more granular metering data. The SDR is intended to make data available to authorised users, subject to governance, assurance and data-protection controls.
Ofgem and DESNZ are also considering the wider smart metering data framework, including how data repositories should operate, how access should be governed, and how consumer benefit should be maximised.
In principle, these developments should be positive. Better access to accurate Half-Hourly data should support competition, switching, billing accuracy, time-of-use products, flexibility, demand response, solar, battery storage, energy efficiency and carbon reporting.
The ECA supports secure, transparent and properly governed access to energy data. The concern is not with data protection or security. The concern is that a solution designed primarily around domestic consumers could be extended into the non-domestic market without properly considering how non-domestic customers and their appointed representatives operate.
Why this matters for TPIs and brokers
Many non-domestic customers do not have the knowledge, systems or time to obtain and interpret Half-Hourly data themselves. Small businesses, charities, churches, community halls, sports clubs, schools and volunteer-run organisations often rely on TPIs, brokers and consultants to act for them.
If those customers are required to complete a domestic style journey every time they want help, provide personal documents, pass identity verification, log into unfamiliar portals, approve individual data users and repeat the process for each quotation or review, many simply will not engage.
The result would not be better privacy. It would be less switching, less competition, fewer independent checks and more reliance on incumbent suppliers.
TPIs know the reality. Customers often do not have bills to hand. Deemed-contract customers may wait months before receiving a first invoice. New occupiers may not yet have supplier paperwork. Customers in dispute may not trust the data provided by their supplier. Volunteer-run organisations may not have one person willing to provide personal documents for access to organisational energy data.
If the data-access model becomes document-heavy, provider-specific and consent-heavy, the non-domestic market will slow down.
The distinction the industry must get right
The central point is that not all non-domestic MPAN-level Half-Hourly data is the same.
Domestic data will often be personal data because it relates to identifiable individuals. Sole traders, farms, home-based businesses and mixed-use premises may also raise personal-data issues.
But many non-domestic sites are operated by limited companies, charities, churches, clubs, public bodies, landlords or other organisations. Their consumption data may be commercially sensitive or confidential, but that does not automatically make it personal data.
That distinction matters. A company, charity or sports club can be an energy customer, but it is not a GDPR data subject. Where the issue is organisational authority, the access route should be based on authority to act, not personal consent from a domestic occupier.
The ECA’s concern is that the phrase “Consumer Consent Solution” could blur that distinction. A “consumer” in energy regulation is not always a domestic individual. If the industry treats all non-domestic data as if it requires a domestic personal-consent journey, it risks creating unnecessary barriers across the market.
The risk to competition
Incumbent suppliers already hold historic consumption data. If TPIs, consultants, brokers, independent advisers, new entrant suppliers and flexibility providers face disproportionate barriers to accessing the same data, the market becomes distorted.
Large suppliers and large market participants can absorb complex compliance requirements. Smaller TPIs and specialist advisers may not be able to.
That could lead to fewer independent advisers, reduced price transparency, weaker billing validation, fewer competitive tenders, reduced switching and less customer choice.
In practical terms, a customer may remain with an incumbent supplier simply because the process for releasing data to a TPI is too difficult.
That is why the ECA has also raised the issue with the Competition and Markets Authority. Data access is no longer just a technical or data-protection issue. It is a competition issue.
The risk to net zero
The same problem affects net-zero delivery.
Half-Hourly data is essential for assessing solar, battery storage, demand-side response, flexibility, carbon reporting and energy-efficiency opportunities. Without accurate data, providers cannot produce credible savings models, payback calculations or site-specific recommendations.
If TPIs and energy-service providers cannot easily access data, customers will receive less advice, fewer project proposals and less evidence to support investment decisions.
That could slow down renewable energy adoption, demand management and non-domestic decarbonisation.
What the ECA is asking for
The ECA is not asking for unrestricted access to data. It is asking for a proportionate framework that reflects the real differences between domestic and non-domestic markets.
The ECA is calling for a separate non-domestic authority route, allowing customer-appointed representatives to access data where they can show valid authority through routes such as:
letters of authority, consultancy agreements, broker appointments, director or authorised officer approval, trustee or committee approval, landlord or managing-agent authority, authorised email domain confirmation, account-holder confirmation or other recognised organisational mandates.
That route should still include proper controls: accreditation, audit trails, role-based access, data minimisation, purpose limitation, security standards, dispute routes and sanctions for misuse.
The key point is that those controls must be proportionate. They must not make data access so difficult that customers stop engaging.
Why ECA members need to engage
This is a critical moment for TPIs and brokers. The rules being designed now could shape how non-domestic data is accessed for years.
If TPIs are not represented in the design process, the framework may be built around domestic customer journeys, incumbent supplier assumptions and large-market-participant compliance models. That would be a serious mistake.
The ECA will continue pressing for Ofgem, DESNZ, RECCo, Elexon, SECCo, Smart DCC, ElectraLink, the ICO and the CMA to work with TPIs and customer representatives before final decisions are made.
The non-domestic market needs a data-access framework that protects customers, respects data law, prevents misuse and supports competition.
It must not become a system that unintentionally locks TPIs out, strengthens incumbent suppliers and leaves customers unable to access the advice, quotations and net-zero solutions they need.
Join the ECA and help shape the future of the industry
This is exactly why the Energy Consultants Association exists: to give TPIs, brokers and consultants a stronger collective voice when decisions are being made that could directly affect our businesses, our customers and the wider non-domestic energy market.
If you are already an ECA member, your support helps us challenge the issues that matter and engage with Ofgem, DESNZ, RECCo, Elexon, the ICO, the CMA and other industry bodies on behalf of the sector.
If you are not yet a member, now is the time to join. The future of non-domestic data access, customer representation and fair competition is being shaped now. Together, we have the knowledge, experience and collective influence to help change the industry for the better.
To find out more, contact us at [email protected] or visit www.energyconsultantsassociation.co.uk
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