Citizens Advice response to Ofgem's consultation on a Smart Data Repository: policy rationale and proposed governance framework
This consultation concerns itself with the provision of the legal vires required to allow the creation and management of a Smart Data Repository, essential for the success of the Consumer Consent Solution. A key priority should be ensuring that the SDR interoperates with RECCo’s Consumer Consent Solution and the wider infrastructure of the Energy Digitalisation Framework. We don’t have strong views on the specifics of how the creation and management of an SDR is enabled; we are more concerned with ensuring that any decisions are made with the goal of improving consumer confidence in smart metering at the heart.
The ability to make choices as to whether or not to share smart meter data is important to consumers, as noted in our response to RECCo’s consultation on the design of the Consumer Consent Solution earlier this year and our response to Ofgem’s consultation on the Consumer Consent Impact Assessment*.
The concerns we have previously raised all remain relevant - particularly that the goals of this project have shifted away from its original aim of providing consumers with information about who is accessing their smart meter data and giving them the ability to make choices about that access where possible. Rather than being consumer centered, the new proposal is more focused on offering benefits to industry by creating a tool that can allow them to establish and manage consent from their customers on an opt-in basis.
*Citizens Advice (2026) Response to RECCO's Consumer Consent Solution Design Consultation; Citizens Advice (2025) Response to to Ofgem’s Consultation on the Consumer Consent Impact Assessment