The next 12 months will likely bring significant change for energy brokers as market-wide half-hourly settlement (MHHS) advances, meter data and pricing processes evolve, consent requirements take shape, TPI regulation develops and smart-metering challenges move into sharper focus. Together, these changes will create new opportunities for time-of-use products, renewable technologies and more sophisticated customer advice, while also requiring brokers to strengthen their data processes, customer authority, disclosures, supplier relationships and operational resilience.
Reshaping the energy market
MHHS is set to reshape how Britain’s energy market understands demand, prices consumption and supports the transition to a more flexible system. By settling customers against half-hourly usage, the programme should give suppliers a clearer view of when energy is consumed, help the grid manage capacity and enable products that reward businesses for moving demand away from peak periods. It should also strengthen the business case for batteries, solar generation and power-purchase agreements.
Migration is already well advanced, with around 70% of the market reported to have moved across. Further supplier waves are continuing, with another phase scheduled for 2027. Yet progress at programme level does not mean the operational challenges have disappeared. Sites whose meters cannot support the new arrangements may still require an exchange, while brokers and suppliers must manage a period in which legacy and migrated data coexist.
Better data can support more tailored products and stronger energy advice. Realising it, however, will depend on consistent data, capable systems and careful handling of customers whose meters do not follow the standard path.
Data holds the key
Access to half-hourly energy data is becoming central to accurate pricing, time-of-use products and better customer advice. Yet the industry must decide how customers will authorise that access and how brokers, suppliers and technology providers can prove the authority is valid.
Potential changes are being considered through the Retail Energy Code. Today, organisations generally rely on an appropriate customer agreement or letter of authority to obtain detailed consumption data. The unresolved question is whether future arrangements will require an additional layer of consent or identity verification, particularly for smaller businesses whose buying behaviour may resemble a consumer comparison journey.
The importance of consent wallets
Consent wallets could provide the answer. In principle, a customer would verify their identity and authorise access once, allowing approved parties to retrieve the necessary data securely. The concept could simplify data sharing. However, poor implementation would only act to add friction at the point of sale. Brokers will, therefore, need a practical way to help customers grant permission without interrupting the quotation process or creating uncertainty about who can use the data. To be effective, the industry must determine how identity is checked, where consent is recorded, which parties may rely on it, how long it remains valid and whether it can move with the customer between providers.
Data availability is as important as permission. A newly migrated customer may have only a short period of half-hourly history, which is unlikely to support a reliable assessment. Any future framework must therefore address the quality, depth and portability of data as well as the legal basis for accessing it.
For TPIs, the practical impact will depend heavily on supplier processes. Some suppliers may retrieve the information and calculate prices automatically once consent is confirmed. Others may expect the broker to obtain and upload the data. Either way, if done well, stronger consent arrangements could improve trust and make sophisticated energy products easier to access.
Regulation moving higher up the agenda
TPI regulation is moving higher up the agenda for the non-domestic energy market. Although the final framework and timetable are still developing, the direction is towards stronger transparency, clearer responsibility and better evidence of how brokers sell, advise and charge customers.
The residential market already operates under extensive conduct and disclosure requirements. Applying a comparable approach to non-domestic intermediaries could affect commission disclosure, sales records, customer communications, complaints handling, contractual terms and the division of responsibility between suppliers and brokers.
For brokers, the practical message is to prepare now. Customer journeys should make authority, fees, commissions and service scope clear. Sales records must show what information was presented, what the customer agreed to and how any recommendation was reached. Contracts should explain renewal arrangements, termination rights and continuing obligations in plain language. Complaint routes and escalation responsibilities should also be unambiguous.
Raising confidence
Consent and data access will be closely connected to the regulatory debate. Brokers may increasingly need to demonstrate not only that a customer authorised a contract, but also that permission to access consumption data was valid and appropriately recorded. If those requirements are fragmented or overly burdensome, they could create friction, reduce competition and make it harder for customers to access time-of-use products or more sophisticated energy advice.
Suppliers will have an important role as well. A successful framework must clarify the checks suppliers should perform on TPIs, the evidence they must retain and where liability sits when processes fail. Without consistent expectations, responsible brokers could face duplicated administration while poor practice remains difficult to identify.
Regulation should ultimately raise confidence in the market rather than restrict it. Brokers that can demonstrate transparent charges, reliable records, clear authority and genuine customer value will be best placed to adapt. Those relying on vague disclosures, weak audit trails or unclear contractual terms face greater risk. The immediate priority is therefore not to predict every detail, but to strengthen governance, document customer interactions and ensure commercial practices can withstand scrutiny.
The next phase of transition
Smart meters will play a central role in the next phase of Britain’s energy transition. However, the transition will not be straightforward for every site. Schools, complex estates and other organisations may have legacy infrastructure, AMR arrangements or communications problems that prevent a meter from migrating or transmitting data reliably. These cases will require investigation, manual intervention or equipment replacement.
The potential benefits are substantial, but technology alone will not deliver them. Success will depend on accurate readings, interoperable systems, accessible histories and fair product design. Brokers that can translate complex meter data into practical customer decisions will be well placed as the market becomes more flexible and increasingly data-led.
As market-wide half-hourly settlement, consent rules, TPI regulation and smart metering develop, brokers should focus on preparation rather than prediction. Review data processes, letters of authority, privacy wording, disclosures, sales records and contracts. Make sure supplier relationships and technical escalation routes are clear, and seek guidance whenever meter data, pricing or regulatory requirements are uncertain. The brokers best placed to succeed will be those that combine strong governance and transparent customer journeys with the ability to turn increasingly complex energy data into practical, valuable advice.
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