13Institutions

Elexon, RECCo, SECCo, and DCC: Roles, Gaps, and Coordination in the EnergyOS Architecture

The EnergyOS governance model does not emerge into a vacuum. The UK energy sector already hosts a set of specialist code and service delivery bodies whose mandates, digital capabilities, and institutional positions will be decisive in determining whether a coherent digital architecture can be achieved. Four bodies in particular — Elexon, the Retail Energy Code Company (RECCo), the Smart Energy Code Company (SECCo), and the Data Communications Company (DCC) — sit at critical junctures in the energy data and communications landscape.

The UK Government's Energy Digitalisation Framework (EDF), published in March 2026, provides the most authoritative recent mapping of these bodies' roles. The EDF establishes a data domain model for the energy system, assigning domain coordinator responsibilities to specific bodies and creating a governance structure that will ultimately be overseen by a new Digitalisation Coordination Function. The EDF's analysis both validates the central thesis of this white paper — that governance gaps are the primary obstacle to digitalisation — and provides important detail on how the existing institutional landscape must evolve.

Elexon

From Settlement Administrator to Domain Coordinator

Current Role

Elexon administers the Balancing and Settlement Code (BSC), the central regulatory framework governing the wholesale electricity market. Its core function is the settlement of electricity trades — calculating the imbalances between contracted and metered volumes for every market participant. This makes Elexon the custodian of some of the most important data in the UK electricity market: half-hourly metered data for every generation and demand unit registered in the BSC.

Future Role under EDF

The EDF assigns Elexon two domain coordinator roles: Metering Data Domain Coordinator (coordinating standards for all metering data through its DIP and SDR programmes) and Behind-the-Meter Asset Domain Coordinator (coordinating data standards for distributed energy assets including type, specifications, connection characteristics, ownership, registration, and operational data).

Key Programmes

Elexon Kinnect: Re-architected BSC central systems onto a flexible digital platform, delivering Customer, Settlement, and Insights Solutions

MHHS Programme: Transforming settlement from monthly estimated reads to half-hourly metered data — a fundamental prerequisite for real-time energy markets

SSES Governance: Appointed as governance body for Smart Secure Electricity Systems, establishing the regulatory framework for energy smart appliances

FMAR: Flexible Market Asset Register — a common register of distributed energy assets participating in flexibility markets

Gaps & Challenges

SDR/SMeDR overlap with DCC — parallel development of metering data repositories with no decision on reconciliation, risking embedded incompatibility

Behind-the-Meter Domain Coordinator appointment is provisional, pending Ofgem's consultation on enhanced asset visibility

Potential tension between SSES governance role and domain coordinator responsibilities requires careful institutional design

FMAR scope and relationship to DCC's CRS asset registration infrastructure remains undefined

RECCo

Consumer Domain Coordinator and Retail Market Backbone

Current Role

The Retail Energy Code Company (RECCo) is the Code Manager for the Retail Energy Code (REC), which governs the processes and systems that underpin the retail energy market. RECCo's responsibilities encompass the Central Switching Service (CSS) — the digital infrastructure enabling consumer switching — and the Consumer Consent Service (CCS), which manages permissions consumers grant to third parties to access their energy data.

Future Role under EDF

The EDF assigns RECCo the role of Consumer Domain Coordinator, responsible for coordinating data standards for consumer consent information, tariff data, switching data, and account information. RECCo is also assigned a critical infrastructure coordination role alongside NESO, with CCS and DSI required to achieve full interoperability across three layers: technical, accreditation, and common standards.

Key Programmes

Central Switching Service (CSS): Digital infrastructure enabling consumers to switch energy supplier — a foundational piece of the retail market

Consumer Consent Service (CCS): Manages the permissions consumers grant to third parties to access their energy data

Tariff Interoperability: Standardised sharing of energy tariff data across the market, enabling smart time-of-use and demand-response tariffs

CRS Improvements Plan: Joint programme with DCC to improve address data quality, change management, incident management, and reporting

Gaps & Challenges

CCS and DSI trust frameworks being developed independently — risk of diverging technical architectures and fragmented user journeys

SSES load control framework and CCS consumer consent not yet coordinated — consumer consent implications of SSES not reflected in CCS design

CRS Improvements Plan focused on incremental improvements rather than the fundamental redesign EnergyOS may require

Relationship between RECCo's Consumer Domain role and the broader EnergyOS consumer API not yet defined

SECCo

Smart Meter Code Governance and Security Oversight

Current Role

The Smart Energy Code Company (SECCo) is the Code Manager for the Smart Energy Code (SEC), the regulatory framework governing the operation of the smart metering system in Great Britain. The SEC defines the obligations of all parties interacting with the DCC's smart meter communications infrastructure and sets the security, privacy, and operational standards governing these interactions.

Future Role under EDF

The EDF does not explicitly assign SECCo a domain coordinator role, but its governance of the SEC is critical to EnergyOS in three respects: it governs the security framework for the UK's largest IoT network; its modification processes are the primary pathway for implementing EnergyOS standards in the smart metering system; and its security governance expertise should directly inform the EnergyOS security framework.

Key Programmes

SEC Panel: Oversees changes to the Smart Energy Code, governing the modification process for the smart metering regulatory framework

User Security Assessment: Assessment process by which parties demonstrate compliance with SEC security obligations before accessing DCC systems

Privacy Assessment: Assessment process ensuring parties meet SEC privacy obligations when handling smart meter data

CIO Administration: Management of the User Competent Independent Organisation that administers security and privacy assessments

Gaps & Challenges

No formal coordination mechanism between SEC governance and the broader EnergyOS governance framework

SEC was designed for a bounded purpose and its processes are not designed for cross-system, multi-domain coordination

As smart meter boundaries become more porous (SSES, EV chargers, flexibility markets), SEC governance needs to evolve

No defined interface between CIDDB architectural requirements and SEC modification process

DCC

Communications Infrastructure Provider and Future Digital Backbone

Current Role

The Data Communications Company (DCC) is the licensed provider of the communications infrastructure connecting smart meters to energy suppliers, network operators, and authorised parties. DCC operates a national communications network — using cellular, radio, and wide-area network technologies — providing secure, two-way communications between approximately 32 million smart electricity and gas meters and the central systems of market participants.

Future Role under EDF

Ofgem's DCC Review Phase 2 (September 2025) concluded DCC should retain its Licence and Code responsibilities for the CRS, but identified areas requiring strengthened operational model and governance. The EDF identifies DCC as critical enabling infrastructure alongside NESO's DSI and RECCo's CCS, with metering data to be made available through the DSI with Elexon as Metering Data Domain Coordinator.

Key Programmes

Smart Meter Network: National communications infrastructure connecting ~32 million smart meters — the UK's largest IoT network

Centralised Registration Service (CRS): Authoritative register of smart meters and their associated suppliers and network operators

Data Services: Enabling authorised parties to access smart meter data through secure, standardised interfaces

SMETS2 Protocol: Bespoke communications protocol for the smart meter network — secure but not natively compatible with open IP standards

Gaps & Challenges

SMETS2 protocol not natively compatible with open IP-based EnergyOS standards — significant technical bridging required

SDR/SMeDR overlap with Elexon unresolved — risk of incompatible metering data architectures being embedded

DCC's governance model (private company under licence) may not be fit for purpose in an open, interoperable EnergyOS world

CRS scope insufficient for the millions of behind-the-meter assets that EnergyOS must register and coordinate

Critical Coordination Gaps

Interface	Current State	Gap	EnergyOS Requirement
Elexon SDR ↔ DCC SMeDR	Parallel development of overlapping metering data repositories	No decision on reconciliation; risk of embedded incompatibility	Single, interoperable metering data layer with Elexon as domain coordinator
RECCo CCS ↔ NESO DSI	Separate trust frameworks being developed independently	Diverging technical architectures; risk of fragmented user journeys	Full interoperability across three layers: technical, accreditation, standards
SECCo SEC ↔ EnergyOS	No formal coordination mechanism between SEC governance and EnergyOS	SEC changes not aligned with EnergyOS architectural requirements	Formal interface between CIDDB and SECCo for SEC modification governance
DCC SMETS2 ↔ EnergyOS DSI	Bespoke communications protocol not compatible with open IP standards	Smart meter data not natively accessible through EnergyOS Digital Spine	Defined translation/gateway architecture enabling smart meter data in DSI
Elexon SSES ↔ RECCo CCS	SSES load control framework and CCS consumer consent developed independently	Consumer consent implications of SSES not reflected in CCS design	Coordinated design of SSES consent model and CCS consumer domain
Elexon FMAR ↔ DCC CRS	Separate asset registers for flexibility market assets and smart meters	No common asset identifier across flexibility and metering domains	Unified asset registration framework with common identifiers

Roadmap

Conclusion & Recommendations