Energy code reform: competitive code manager selection

What this is about

This consultation closes the loop on the institutional mechanics of energy code reform. The Energy Act 2023 hands Ofgem the power to license code managers: bodies that will run the eleven GB industry codes (BSC, CUSC, Grid Code, UNC, the lot) in place of the current patchwork of code administrators and panel-driven governance. In May 2025 Ofgem published its decision and guidance on how code managers would be selected. The enabling regulations came into force on 6 June 2025. What was missing was the operational detail of the *competitive* route: when more than one credible candidate wants a code manager licence, how does Ofgem choose between them?

That is what this consultation fills in. It proposes the text Ofgem will insert into its code manager selection guidance to govern the licensing assessment stage of a competitive selection: the scoring methodology, the weighting across assessment areas, the tiebreak procedure, and a word limit on candidates' scored answers. It is procedural on its face and structural underneath. The scoring rules are the point at which the question "is this role genuinely open to new entrants, or is it the incumbent administrators' to lose?" gets answered. A weighting that rewards demonstrated track record of running a code at scale is a weighting that favours the firms already running the codes. A weighting that rewards governance design, conflict-of-interest separation, and delivery capability lets a credible new entrant compete. The consultation document is short (179KB) because the substance is in the draft guidance (747KB) and the response template, not in the framing.

Sixteen responses came back, from suppliers, charities, code administrators, and central delivery bodies. A majority supported the proposals, and support was consistent across every area covered. Ofgem decided to proceed with its proposed scoring methodology, weighting structure, tiebreaking process, and the use of a word limit. The one substantive concession to stakeholder feedback: candidates get an additional 500 words for scored questions. The decision and updated guidance were published on 16 March 2026 and the consultation is now closed with decision.

Options on the table

The consultation document and response template are not in the extracted text, so the specific scored options Ofgem put to consultees cannot be enumerated from the source. What the outcome statement does confirm is the structure of the choice, and that structure is itself the decision space:

Scoring methodology

Ofgem proposed a defined methodology for scoring candidate responses against the assessment criteria and decided to proceed with it unchanged. The criteria that matter for code reform are the ones flagged in the significance: capability (can the candidate actually run a code), governance (how decisions get made and who they are accountable to), and conflicts of interest (whether the manager can be neutral between code parties with opposing commercial interests). How these are scored, and how granular the scoring is, determines whether a strong governance proposal from a new entrant can outscore an incumbent's operational incumbency. Ofgem held its line here. Incumbent administrators are the natural beneficiaries of any methodology that does not actively reward fresh governance design, because experience running the code is the one thing they have and a new entrant cannot manufacture on paper.

Weighting structure

The relative weight placed on each assessment area is the single most consequential parameter in the whole exercise. Weight capability and track record heavily and the competitive route becomes a formality that confirms the incumbent. Weight governance, independence, and conflict management heavily and the route does what code reform is supposed to do: introduce contestability into roles that have never faced it. Ofgem consulted on a specific weighting, a majority backed it, and Ofgem proceeded with it. The barrier-to-entry question turns on numbers that are in the guidance PDF, not the extracted page.

Tiebreaking process

Where two candidates score equally, Ofgem proposed a defined tiebreak procedure and decided to keep it. A tiebreak rule is low-salience until the day it decides who runs the BSC. Whether the tiebreak favours, for example, lower cost to code parties, stronger consumer-interest alignment, or some default to incumbency is the kind of detail that looks administrative and is in fact allocative.

Word limit on scored questions

Ofgem proposed a word limit on candidates' answers to scored questions. This is the one place stakeholders moved the outcome: the limit was retained in principle but increased by 500 words per scored question. A tight word limit disadvantages candidates with complex governance proposals to explain, which in practice means it disadvantages new entrants proposing something other than "we already do this." The 500-word increase is a marginal loosening of that constraint, not a removal of it. The principle, that responses are bounded and the assessment is not won by volume, survived consultation intact.

There are no rival "Option A versus Option B" choices in the source material. The structure is a single proposed package (methodology + weighting + tiebreak + word limit), consulted on for endorsement and amendment rather than as a menu. The only live amendment that landed was the word count.

Questions being asked

The consultation response template (DOCX, 86.88KB) and the consultation document (PDF, 178.61KB) contain the scored and unscored questions, and neither is in the extracted text. The specific question wording cannot be reproduced faithfully from the source, and inventing it would be worse than omitting it. What the outcome statement establishes is that the consultation sought views on four discrete areas, which map to the questions consultees were asked to address:

Scoring methodology

Whether Ofgem's proposed approach to scoring candidate responses is appropriate. (In substance: does the methodology discriminate between a genuinely strong proposal and a merely incumbent one, and is it transparent enough that candidates know what they are being marked against?)

Weighting structure

Whether the proposed weighting across assessment areas is right. (This is the barrier-to-entry question in disguise: how much should demonstrated capability count relative to governance design and conflict management?)

Tiebreaking

Whether the proposed tiebreak process is appropriate for separating equally scored candidates. (What is the decisive criterion when the headline scores do not separate the field?)

Word limit

Whether a word limit on scored questions is appropriate, and if so at what level. (The one question where the consultation changed the answer: limit retained, 500 words added per scored question.)

For the precise question text and the distinction between scored and unscored questions, the consultation document and response template at the links below are authoritative. This memo does not reconstruct them from a truncated page.

How to respond

This consultation is closed. It opened on 8 December 2025 and closed on 24 January 2026. Ofgem published its decision and updated guidance on 16 March 2026, and the status is "closed (with decision)." There is no longer an open response window.

For the record, the original mechanics were:

- Deadline: the page text carries a date inconsistency. The headline closed date is given as 24 January 2026, while the "How to respond" instruction says respond by "Friday 23 January 2025." 23 January 2026 was a Friday; 23 January 2025 was not, and "2025" predates publication, so the "2025" is a typo in the source. Treat 24 January 2026 (the stated closed date) as the operative deadline; 23 January 2026 was the response-by date in the instructions. Flagging the discrepancy rather than silently picking one. - Submission method: complete the consultation response template, or send a PDF, Word, or Excel document. - Contact: industrycodes@ofgem.gov.uk

To act on the outcome rather than the closed consultation, the documents that matter now are:

- *Energy code reform: decision on competitive code manager selection* (PDF, 215KB) — the final scoring methodology, weighting, tiebreak, and the increased word limit - *Guidance on code manager selection* (updated 16 March 2026) — the operative text against which real code manager candidates will be assessed - *Non-confidential responses* (ZIP, 2.81MB) — the sixteen submissions, useful for reading who argued for what on the weighting and word-limit points

Anyone intending to bid for a code manager licence, or to scrutinise whether the competitive route is genuinely contestable, should work from the decision document and updated guidance. The weighting and scoring detail that decides the barrier-to-entry question lives there, not on this consultation landing page.