Consumer Scotland has published its response to the Department for Energy Security and Net Zero (DESNZ) call for evidence on developing an energy smart data scheme, dated 10 March 2025. The statutory body for consumers in Scotland said it welcomed the ambitions of the proposal, under which households could consent to share data on energy consumption, tariffs and other metrics, for historic periods or in real time1.
"Consumer Scotland welcome the opportunity to respond to this consultation on a proposed smart data scheme in the energy market."
The body said such a scheme could support consumers in securing lower bills and in contributing to the net zero transition, but that it would only be as useful as the data informing it. It said this underlined the importance of increasing smart meter penetration and of the capability of smart meters to record and report different metrics1. It also pointed to a 2024 Citizens Advice report highlighting issues with smart meters across the UK, saying that addressing data gathering and provision would be central to the scheme's success1.
Consumer Scotland set out risks including that benefits do not outweigh costs, and that a scheme could cause harm if misused, for example through unsolicited contact, promotion of inappropriate products, or unfairness where consumers are penalised directly or indirectly on the basis of historically high energy consumption1. It said many consumers are understandably wary about consenting to share data, and that trust depends on consumers controlling which aspects of their data are shared and for what purpose, being able to revoke consent, rigorous processes for authorising third parties, and effective reporting and enforcement1.
On oversight, the response said the government should set out different possible models of oversight, and that a strong, proportionally represented governance model would be important. It suggested consideration of consumer organisations' involvement in design and oversight, building on arrangements such as the Smart Energy Code Panel, and said it would welcome discussion of how monitoring, assessment and enforcement of any AI or machine learning models used in the scheme would work1. It also said it would welcome government setting out how digitally excluded consumers could opt in and then manage the control element, and what evidence has been gathered on groups experiencing detriment from not having access1.
The response answered "No comment" to a number of the consultation questions, including those on lessons from Open Banking, international examples, additional value alongside existing data sharing initiatives, customer needs, barriers for established market actors and third parties, aspects of the GB energy mix, use cases, datasets, and prioritisation of use cases1.
Why it matters for households
An energy smart data scheme would sit alongside the existing energy comparison sites, brokers and third party intermediaries that already handle household data, and would extend the range of information a household could choose to share. For a home's energy independence, the practical question raised in the response is control: whether a household can decide which data is shared, for what purpose, and withdraw that consent, rather than consenting once and losing the ability to change it1. The response also notes that consumers with the financial resources to buy smart devices and appliances are better placed to use smart data products, and that the costs of such appliances may be prohibitive for consumers on low incomes, who may therefore be less likely to benefit1. It adds that the costs of the scheme should not fall on those unable to participate, or choosing not to1.
What happens next
The response is dated 10 March 2025 and was published by Consumer Scotland1. No decision, timetable or next stage for the scheme is set out in the response. Consumer Scotland's suggestion that Ofgem could act as a suitable scheme regulator is not stated in the response text; the response instead calls for the government to set out possible oversight models and for consumer representation in oversight1.