Clarification of REC Maintenance of Qualification Schedule
Summary
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Latest update and next planned activity
Date of latest update
Latest Update
Change withdrawn following agreement to combine with R0059
Impacts Overview
Impacted Consumers
Electricity
Gas
Domestic
Non-Domestic
Impacted REC Parties and Market Participants
Energy Supplier
Distribution Network Operator
Gas Transporter
Priority and rationale
Priority last updated on 17 Sep 2026
Solution development
No documents available.
There is currently no Change Plan.
Original submission
Change details
Bryan Heap - -
12 Jun 2022
Change details
Clarification of REC Maintenance of Qualification Schedule
Schedule 9 (Maintenance of Qualification for the REC) contains an obligation to document any system changes or processes which may impact interfaces with the CSS Provider or other Market Participants. This is inconsistent with the guidance document which advises that material event includes major systems and process change (rather than “any” changes).
There is an inconsistency between the two documents which may result in issues of interpretation when parties are completing the annual audit process. The requirement to document any change is disproportionate to the objectives of the schedule and the audit regime and could significantly increases the costs of the audit and also result in a significant number of system changes being identified which have no material impact on retail risk.
Alignment of the Schedule and Guidance document to require major system or process changes to be declared. We would recommend that the definition of a “major” change proposed in the earlier drafting of the Interpretations Schedule (V0.3 June 2019) should be revisited.
At the December REC PAB meeting, the DNO representative asked the Code Manager to clarify if only material changes should be raised as part of Maintenance of Qualification, as there is a difference between the wording in the Code and the associated guidance. The Code Manager clarified that the guidance is in place to give further detail, and states that only significant and material changes should be reported to the Code Manager. This is inconsistent with the wording in the actual requirements and the template for the annual statement.
Other industry codes only require material changes to be disclosed for example the BSC Annual statement and SEC annual security assessment only require “material” system changes to be declared.
Other industry codes only require material changes to be disclosed for example the BSC Annual statement and SEC annual security assessment only require “material” system changes to be declared.
Impacts
Electricity, Gas, Domestic Prepayment, Domestic Credit, Microbusiness, Small and Medium Enterprise (SME), Industrial and Commercial (I&C)
Other (please provide details in Additional information box below)
Efficient discharge of regulatory requirements
Schedule 9 - Qualification and Maintenance
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No details provided
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Energy Suppliers, Distribution Network Operators, Gas Transporters
Impact on DNOs and Suppliers as the requirements to provide updates will be aligned with the guidance document.
No details provided
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No
No details provided
Priority & timing
Yes
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The change proposal should be implemented at a time to give sufficient notice to parties ahead of the annual audit.
No
No details provided
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