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CSE responds to Smart Data Repository consultation

The Centre for Sustainable Energy has backed government plans for a Smart Data Repository holding household energy use data, while calling for consumer groups to sit in its governance and for success to be judged on consumer outcomes.

A newspaper on a kitchen table beside a model of rules and regulation.

The Centre for Sustainable Energy (CSE) has published its response to the government consultation on a Smart Data Repository, saying it strongly supports the repository's creation and considers it "a potentially transformational part of the future energy system"1. The response was published on 20 October 20261.

The repository would store household energy use data. Under the proposed model, third-party organisations could access aggregated data, while access to an individual household's data would require the bill payer's consent, an approach CSE says it supports1. CSE states that with access to a customer's historic energy use, comparison websites could provide more tailored advice, helping people find tariffs and flexibility services that better suit their needs. It adds that half-hourly electricity data could support new time-of-use tariffs, which offer different prices at different times of day, as well as services that reward people for shifting their electricity use. The repository could also help energy networks plan for future demand and provide a resource for research and policy development1.

CSE's response raises two concerns about the proposed framework. It says governance appears to be led by the energy industry, without representation from consumer groups, and that the proposed monitoring arrangements focus on operational compliance and controlling access to data, rather than outcomes for consumers1. It also warns that low-income, vulnerable and digitally excluded households risk missing out if new services are not designed with their needs in mind, and that it is not fully clear how the data will be used, who will benefit and how potential harms will be identified1.

"We recently responded to the government’s consultation on a Smart Data Repository."
Centre for Sustainable Energy1

The response sets out four calls, summarised in the table below.

CSE's calls on the Smart Data Repository
Consumer and civil society representation in the repository's governance
Clear objectives that put consumer benefit and the public interest at the heart of its operation
Ongoing monitoring of consumer outcomes, including unintended harms and the distribution of benefits
A requirement for energy suppliers to offer customers tariff comparisons based on their historic energy use through the repository

Source: Centre for Sustainable Energy1

CSE traces the proposal to work it began in 2017, when it and Sustainability First set up the Smart Energy Data Public Interest Advisory Group (PIAG). That group concluded that existing energy datasets are fragmented and not granular enough for many public policy purposes, and recommended enabling access to anonymised and aggregated smart meter data through a secure, trusted framework, so that public bodies, regulators and accredited researchers can use it for legitimate public interest purposes1. CSE argues that success should not be measured simply by how well the repository operates or how much data it makes available, but by whether it helps consumers make informed choices, protects their interests and ensures the benefits of a changing energy system are shared fairly1.

Why it matters for households

The repository would hold highly sensitive information about how households and businesses use energy, and the terms of access decide how far that information travels: aggregated data could be used more widely, while anything identifying a single home would need the bill payer's consent1. For a household, the practical question is whether better data leads to offers that fit its actual pattern of use, such as a time-of-use tariff matched to when it uses most electricity, rather than a generic deal. CSE's warning that low-income, vulnerable and digitally excluded households risk missing out points to a distributional question: a smarter system built on detailed consumption data could sharpen choices for some homes while leaving others on standard arrangements. Its call for suppliers to offer tariff comparisons based on historic use through the repository would make that comparison a routine part of supply rather than something a household has to seek out1. The governance point matters too, because who sits on the body controlling access shapes what the data is used for and which harms are looked for.

What happens next

The consultation is run by Ofgem, which published the policy rationale and proposed governance framework1. CSE's response has been submitted and published; no timetable for the government's decision or for the repository's launch is given in the published response1. The consultation sits within the wider process by which energy consultations lead to rules, with DESNZ the department behind home energy policy.

Sources1 sources
  1. Smart energy data must put consumers first - Centre for Sustainable Energy, cse.org.uk