Retail Risk Register
Date of latest update
Type
Change
ID
C3-0140
Urgent
No
Latest Update
-
Summary
The Risk Register is a key document set out in the Performance Assurance Schedule. This schedule drives the structure of the risk register as follows: 1. It drives the Risk Register to focus on Retail Risk, which includes both compliance with the Code, but also the delivery of right outcomes, both for customers and market participants. 2. It is clear that the Risk Register covers both Party performance and that of the REC Service Providers. 3. It limits any Performance Assurance interventions to areas identified in the Risk Register. Retail markets are both dynamic and complex, often with specific issues occurring and needing to be resolved quickly, with information from multiple participants needed to identify their root cause. The Risk Register, therefore, is structured with risks structured around the REC objectives. ‘Risk Drivers’ are associated with risks which measure the market and trigger appropriate action. These Risk Drivers can measure either compliance or customer outcomes. This Risk Register is reviewed annually by the Code Manager and approved by PAB. The Code Manager has conducted a review for 2025-26 and proposed changes covering: • Removed Retail Risk VI which was added last year as a result of expected increase in transformation activities resulting from transfer of responsibility for the Central Registration Service (CRS) from DCC to RECCo. Whilst there continues to be transformation of REC Service Provision, the level of risk associated with it is reduced. This is, therefore, no longer viewed as a key risk affecting the effective operation of REC arrangements. • Introduction of new Risk Drivers to monitor: o Usage of Change of Occupier (CoO) flag during switching. These are separated by Domestic and Non-Domestic supply points as trends and behaviours in both segments may vary. Based on insights from R0155, which clarified the REC requirements for CoO, we understand if the CoO flag is misused, it can lead to Erroneous Switches especially if some Suppliers have opted to not object to CoO Switch Request. Introducing this Risk Driver helps us monitor if any Supplier have disproportionality high usage, indicating if outcomes were at risk. Once these Risk Drivers are live, we will review performance for the previous 6 months as the CSS reporting is already available and propose thresholds for PAB approval in the following month. o IF045 for issues with Meter Operator Agent (MOA) Appointments. Suppliers are required to appoint a qualified MOA to every meter point they supply, and it measure would help us measure their compliance and identify any meter points open to safety risk due to lack of MOA appointment. This is dependent on reporting from DIP after migration to MHHS arrangements starts. Once the reporting is available and we have a view for c. 6 months of performance data, we will use that to propose thresholds for this Risk Driver. • General housekeeping changes, including: o Removed reference to activities that formed part of the Performance Assurance Operating Plan (PAOP) for 2024-25. o Added reference to activities within PAOP 2025-26. o Updated reference to active REC Change Issues and Proposals. When making these updates, we also considered other possible updates to the Risk Register. Notably this included considering items that have progressed through the change process and rejected or withdrawn, but evidence suggests there is still a user need or risk. These include: a. R0169 Introduction of End of Gate Closure notifications, a change raised in response to the CSS Major Incident in 2023, which intended to help CSS Users identify when all processing is completed. b. R0009 Introduction of SDEP and EES User Maintenance API, which recent sandbox applications indicate a continued need for machine-to-machine interactivity. Both of these were rejected or withdrawn as a cost beneficial solution could not be identified. Whilst we considered raising a Retail Risk, we think these kinds of identified issues are best managed through the Change Panel and Codes Roadmap, or the future Design Authority. This consultation offers REC Parties and Service Providers an opportunity to feedback on the updates proposed to the Retail Risk Register. The Code Manager has also presented this document to the Performance Assurance Board (PAB) on 30 September 2025 and sought their approval, contingent to any refinements that may be made in response to the feedback received. As the Retail Risk Register is a Category 3 document, an industry wide consultation is not required as part of updating the document. Notwithstanding, we have identified that engaging with industry is a key part of implementing the changes and are therefore seeking feedback through a consultation in order to support our Performance Assurance activity.
Status
Implementation Status
Date Raised
Date of Update to Priority
Stages Selection
Company Name
Code Manager (RPA)
Review status
Review required
Organisations with multiple role types EES and SDEP access
Date of latest update
Type
Change
ID
I0285
Change Category
Other Industry Codes impacted
Change Path
Priority
Urgent
No
Latest Update
01/09/2026 - the Party impact assessment has closed. The Code Manager is reviewing responses and conducting the business case assessment.
Summary
It is currently not possible for organisations with multiple role types to have the same person be able to access all assigned role types within the Secure Data Exchange Portal (SDEP) without having a unique email address for each role type.
Change Plan
Change Report (Proposal Plan) approved by Change Panel
Completed
Start:
Due:
Completion:
04 Nov 2025Impacted REC Services
Impacted REC Parties and Market Participants
Status
Status
Implementation Status
Date Raised
Fuel
REC Decision Maker
Date of Update to Priority
Solution Development
Proposed Solution Document
Document title
Zip file with I0285 legal text
Archive
Off
Document title
I0285 Solution Development Report V1.0
Archive
Off
Problem Statement
Organisations with more than one role type are required to have unique email addresses for staff who require access to multiple role types, leading to inefficiencies, unnecessary administrative burdens and a poor user experience.
Stages Selection
SME
SME Role
Lead Technical Analyst
I0285 submission form
I0285 Change Report (Proposal Plan) V1.0 approved 04.11.25
I0285 Extension to Plan V1.0 approved 25.02.26
I0285 Extension to Plan V2.0 approved 24.06.26
Company Name
-
Review status
Review required
Return of Legacy Meters
Date of latest update
Type
Issue
ID
I0282
Change Path
Priority
Urgent
No
Latest Update
08/04/2026 - The Closure Report was presented to the REC Metering Expert Panel at their meeting on 08 April 2026. The Issue has now been classed as resolved.
Summary
The issue identified is that current arrangements require or assume that legacy Meter Asset Providers (MAPs) take back old, non Smart Meters once they are removed from Consumers’ Premises, even though many of these meters are obsolete, cannot be reused, and ultimately require disposal. This has resulted in large volumes of legacy meters being transported across the country between storage providers and legacy MAPs, creating unnecessary cost, administrative burden, and environmental impact. Storage providers are issuing extensive lists of Meter Serial Numbers (MSN) to try to establish meter ownership, and legacy MAPs must manually verify these details. This process has been made more difficult by historical changes in company names and ownership structures. Once ownership is confirmed, the meters are frequently transported to the legacy MAP only for them to arrange disposal, which provides no net value and simply adds further transportation and handling costs.
Impacted REC Parties and Market Participants
Status
Implementation Status
Date Raised
Fuel
REC Decision Maker
Date of Update to Priority
Solution Development
Problem Statement
The process for handling removed legacy non Smart Meters is inefficient and environmentally costly, with unclear ownership, unnecessary transport, and no established recycling route. A consistent, sustainable disposal solution is needed to reduce waste, simplify operations, and clarify the management of any scrap value.
Stages Selection
Stages Selection
I0282 submission form
I0282_Closure Report_v1.0 (26 March 2026)
Company Name
-
Review status
Review required
Extending R0067 Refresh Functionality
Date of latest update
Type
Issue
ID
I0281
Change Category
Change Path
Priority
Urgent
No
Latest Update
03/07/2026 - The Service Provider Impact Assessment is ongoing and expected to be completed by 07 August 2026.
Summary
CSS Market Messages sent by the Central Switching Service (CSS) to Switching Data Service Providers (SDSPs) are either not being received, being received after Gate Closure, or are being received out of the order that they were originally sent in. This Issue originally aimed to extend the Refresh functionality, implemented for the Gas Retail Data Agent (GRDA).to the Electricity Retail Data Agent (ERDA). Following solution development for I0281, it was agreed that the Refresh functionality would be made available for all Market Participants in receipt of the in-scope messages.
Impacted REC Documents
Impacted REC Services
Impacted REC Parties and Market Participants
Status
Status
Implementation Status
Date Raised
Fuel
REC Decision Maker
Date of Update to Priority
Solution Development
Problem Statement
CSS messages are not received by the SDSPs in the order in which they were originally sent, or after Gate Closure, so it can be difficult to detect and often requires significant manual effort to resolve. This issue can directly impact Consumer switching experiences, causing disruption and possible delays in a switch.
Stages Selection
Stages Selection
SME
SME Role
Lead Technical Analyst
SME User
maxime.van-eyseren@capgemini.com
SME Role
Lead Assurance Analyst
SME User
amoden@deloitte.co.uk
I0281_Change Report (Update to Plan) v1.0 (Pre-approval)
I0281_Change Report (Update to Plan) v1.0 Approved 20.05.2026
Company Name
-
Review status
Review required
EES User Guides – MHHS updates
Date of latest update
Type
Change
ID
C3-0139
Urgent
No
Latest Update
-
Summary
This Cat 3 CP is to implement the Electricity Enquiry Service and Secure Data Exchange Portal User Guides following updates made to the service for MHHS.
Status
Implementation Status
Date Raised
Date of Update to Priority
Stages Selection
Company Name
Code Manager (RPA)
Review status
Review required
EES DAM – MHHS update
Date of latest update
Type
Change
ID
C3-0138
Urgent
No
Latest Update
-
Summary
This Cat 3 CP is to implement an updated Electricity Enquiry Service Data Access Matrix, which captures the permissions approved for new user categories and new data items under MHHS. The proposed data access permissions were approved by the Performance Assurance Board on 17/12/2024 and industry consulted on the updated EES DAM in 18/12/2024 to 15/01/2025.
Status
Implementation Status
Date Raised
Date of Update to Priority
Stages Selection
Company Name
Code Manager (RPS)
Review status
Review required
Guidance on Electricity Metering Points - MHHS
Date of latest update
Type
Change
ID
C3-0137
Urgent
No
Latest Update
-
Summary
This Cat 3 CP is to implement the new ‘Guidance on Electricity Metering Points – MHHS’. This is an additional document to the existing ‘Guidance on Electricity Metering Points’. It includes amendments to make the document relevant for MHHS Metering Points. The existing document remains valid for non-MHHS Metering Points.
Status
Implementation Status
Date Raised
Date of Update to Priority
Stages Selection
Company Name
Code Manager (RPS)
Review status
Review required
MHHS Metering Guidance
Date of latest update
Type
Change
ID
C3-0136
Urgent
No
Latest Update
-
Summary
This Cat 3 CP is to implement the following new metering guidance documents created to support Parties with understanding systems and processes updated for the new Market-wide Half Hourly Settlement (MHHS) arrangements: Sharing Metering Asset Data – MHHS Guidance Document Change of Market Segment – MHHS Guidance Document MOA Appointment – MHHS Guidance Document These documents were consulted on in June and July 2025 and were approved by the Metering Expert Panel to be implemented as Category 3 documents under their responsibility at the July and August MEP meetings.
Status
Implementation Status
Date Raised
Date of Update to Priority
Stages Selection
Company Name
Code Manager (RPS)
Review status
Review required
Addition of new category to EES DAM (NESO)
Date of latest update
Type
Change
ID
C3-0135
Urgent
No
Latest Update
-
Summary
This change proposes that several data items be made available for NESO to fulfil its role in the strategic direction of the GB energy system.
Status
Implementation Status
Date Raised
Date of Update to Priority
Stages Selection
Company Name
Code Manager (RPS)
Review status
Review required
Establishing the Safe Isolation Provider (SIP) as a Standalone REC Party
Date of latest update
Type
Issue
ID
I0278
Change Category
Other Industry Codes impacted
Change Path
Priority
Urgent
No
Latest Update
21/07/2026 - An Update to Plan has been approved by the Change Panel on 21 July 2026.
Summary
This proposal recommends the formal recognition of the Safe Isolation Provider (SIP) as a standalone Party under the Retail Energy Code (REC). This aligns with the direction set out in Ofgem’s recently published Strategic Direction Statement (SDS), which explicitly calls for the establishment of SIPs as a standalone Party role. The aim is to address the growing scale of unregulated SIP activity, mitigate associated consumer safety risks, and ensure the metering industry is equipped to support the UK’s Net Zero ambitions. By enabling easier access to certified SIPs, this change will enhance consumer protection, accelerate low-carbon technology deployment, and improve operational efficiency across the energy sector.
Impacted REC Documents
Impacted REC Parties and Market Participants
Status
Status
Implementation Status
Date Raised
Fuel
REC Decision Maker
Date of Update to Priority
Solution Development
Problem Statement
The current SIP framework poses several risks: - Consumers, MEMs and unaccredited practitioners’ safety. Unaccredited and unregulated isolation work increases the risk of unsafe installations and potential harm to Consumers. NAPIT highlighted to RECCo and DESNZ that 17 and 13 unregulated practitioners respectively died in 2023 and in 2024 due to unsafe isolation. With the right Party undertaking this work, there would also be less safety issues for the Consumer at their premises; - Inequity. Independent Installers face longer wait times compared to supplier-led installations, creating a two-tier system; - Low competitive market. Currently prospective Parties can be put off from applying to be a SIP as it appears they would need full MEM Accreditation which is often too far outside their current business operating model. Providing SIPs with their own pathway and requirements could result in more Parties becoming SIPs and therefore giving Consumers more choice in their provider; and - Decarbonisation delays. The inability to scale SIP capacity undermines the timely deployment of LZCTs, threatening Net Zero targets.
Stages Selection
Stages Selection
SME
SME Role
Lead Technical Analyst
SME Role
Lead Assurance Analyst
SME User
amoden@deloitte.co.uk
I0278 submission form
I0278 Change Report (Proposal Plan) V1.0 (Pre-Approval) 09.10.2025
I0278_Change Report (Extension to Plan) v1.0 (Pre-Approval) 12.01.2026
I0278_Change Report (Extension to Plan) v2.0 (Pre-Approval) 13.07.2026
I0278_Change Report (Extension to Plan) v2.1 (Approved) 21.07.26
I0278_Consolidated Information Request DNO Responses
I0278_Consolidated Information Request MEM-SIP Responses PUBLIC
I0278_Consolidated Information Request RPA Responses
Company Name
-
Review status
Review required