Primer – Energy Codes and Licenses

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Primer – Energy Codes and Licenses

IGov Primer – Energy Industry Codes and Licenses


IGov has consistently argued that the codes and licences that govern the energy system in GB need to change in order to better enable a low carbon transformation. Our thinking and research has included blogs, consultation submissions, a roundtable event, a number of papers and case studies. Our take away message is that self-regulation of Codes should cease and should be replaced by a Code Manager. Detailed information on all our outputs, in chronological order, are below.

For a detailed overview of energy industry codes, the issues they create and some solutions to these we recommend our 2015 working paper. For a higher level overview we recommend the 2017 journal article in Utilities Policy (open access).  For an understanding of how we see code reform and management fitting into a new fit-for-purpose governance framework for GB see our two September 2019 briefings: Getting energy governance right: Lessons from IGov and Enabling the transformation of the energy system: Recommendations from IGov.





  • Jan (Blog) Waiting for the ER P2/6 review. Case study of codes impact on system change, looking at the process and review of updating industry standards for security of supply. It highlights the role of code governance and the way in which this can slow down such processes.







  • April (Submission) To CMA on their updated issues statement. Welcoming their broadening out of the theories of harm to include a 5th theory of harm on code governance.
  • July (Blog). The CMA on governance part 1: codes. Summary of our view on the CMA provisional findings in relation to codes & their governance, includes overview of the importance of codes.
  • Aug (Submission). CMA on their Provisional Findings and Possible Remedies. Our views on industry-led system code governance and how that should change to ensure new system actors and system change are not hindered. Also called for a simplification of the length of codes.
  • October (Roundtable) IGov Code Governance for the 21st Century event. Looked at the principles for reforming code governance. The agenda, aims, attendees are all available along with an IGov presentation setting out the history, context and issues with code governance.
  • Nov (Discussion Paper) On Code Governance and Reform. This paper wrote up the findings of the above roundtable covering: a summary of exiting codes; a history of efforts of reform them; an overview of the issues raised (improving information & access; code simplification & consolidation; code governance, administration and architecture). Plus our recommendations.
  • Nov (Submission) To CMA Code Governance: info request to industry participants. Sets out our position on the CMA’s work on codes, setting out the IGov approach for code governance reform and a response to the CMA questions to industry participants.
  • Dec (Working Paper) Innovation and energy industry codes in Great Britain. Provides detailed insights on codes: their importance; governance; the case for reform; and an agenda for reform.
  • Jul (Presentation) The UK energy system- the challenge of institutional inertia. A presentation to a STA event looking specifically at codes and licenses and the issues they create in terms of system inertia.



  • Feb (Submission) DECC consultation on Industry code and licence modifications. Flagging why we felt code and licence governance needed to be reviewed to reflect system change, sustainability objectives; and the need to better governance of code panels and review processes.
  • Aug (Submission) To CMA The Energy Market Investigation Statement of Issues. Sets out why we think codes & licences are not fit for purpose; calls for them to be bought into the investigation.
  • Dec (Oral Evidence) To CMA hearing (opening statement). Setting out the context of governance in shaping system change and how this is constrained within decision making & codes.


Download the primer here: Primer – Energy Codes and Licenses


Last Update: December 2019

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