Expression of interest invitation: code manager candidates

What this is about

This is the procedural starter pistol for the Code Manager regime. The source text corrects the framing in the analysis summary: Ofgem is not seeking candidates across eleven codes in one sweep. It is seeking expressions of interest for two consolidated bodies, the Electricity Commercial Code and the Gas Network Code. The Energy Act 2023 regime does not simply re-license eleven existing codes under new managers; it folds them into a smaller number of consolidated codes, each run by a single licensed code manager accountable to Ofgem rather than to the industry panels that govern the codes today. This notice is the first formal entry point into that competition.

Why it matters is governance, not procedure. The current code arrangements (BSC, CUSC, Grid Code, UNC, and the rest) are self-governed by panels of incumbents, with Ofgem holding only an appeal and approval function. The Code Manager regime replaces that with a licensed entity that Ofgem selects, holds to performance conditions, and can sanction. Who clears the eligibility filter at this stage shapes who can hold strategic control of the rulebook for electricity commercial arrangements and gas network operation for years. The eligibility form's four sections (basic information, suitability to hold a licence, independence and conflicts of interest, organisational capability) are the screen. Section 3 is the one to watch: an incumbent code body or a party owned by network or supply interests has an obvious conflict in running a code its parent is bound by, and how Ofgem reads that conflict test determines whether the regime delivers genuinely independent code management or a relabelling of the status quo.

Key points

- Two roles, not eleven. The competition is for code manager of the consolidated Electricity Commercial Code and the Gas Network Code. The eleven designated codes are being consolidated into these (and other) instruments; this notice covers the two named here. - Mechanism is a call for input, not a consultation. Publication type is "Call for input" with no policy question attached. It is an operational filter: submit an eligibility assessment form, demonstrate you meet the requirements, proceed to the next stage of selection. - Eligibility form structure. Four sections: (1) basic information and expression of interest, (2) suitability to hold a licence, (3) independence and conflicts of interest, (4) organisational capability and expertise. Separate forms for each code (Electricity Commercial Code DOCX, Gas Network Code DOCX). - Hard deadline. Forms to industrycodes@ofgem.gov.uk by 20 March 2026. The page records a closed date of 21 March 2026 and now shows status "Closed", so this window has passed; the value of the notice now is as a marker of where the selection process stands, not an open opportunity. - Governing guidance. Completion is governed by Ofgem's "guidance on code manager selection", which sets the eligibility thresholds the form tests against. Signed off by Heather Stewart on behalf of the Authority. - Lineage. This sits downstream of the BSC and REC basis-of-selection determinations (March 2025) and the RECCo first licence-grant proposal (August 2025). Those established the selection methodology and the precedent of granting a code manager licence to an existing code body (RECCo for the REC). This EoI is the same machinery applied to the electricity commercial and gas network codes.

What happens next

The eligibility stage is a gate, not the decision. Candidates who clear the form move into Ofgem's fuller selection process under the published code manager selection guidance: assessment against the licence conditions, scrutiny of independence and conflicts, and ultimately a licence-grant decision for each code. The RECCo precedent from August 2025 indicates Ofgem is willing to grant the first licences to existing code bodies where it judges the independence test satisfied, which raises the question of whether the Electricity Commercial Code and Gas Network Code managers will be new entrants or repackaged incumbents (Elexon and Xoserve are the obvious incumbent candidates for the electricity commercial and gas network functions respectively).

Watch for three things. First, the licence-grant proposals for these two codes, which will be consulted on individually and will name the preferred candidate; that is where the substance lands. Second, the consolidation instruments themselves, the legal vehicles that define what the "Electricity Commercial Code" and "Gas Network Code" actually contain, since the scope of each consolidated code determines how much strategic control the manager holds. Third, how Ofgem applies the Section 3 conflicts test in practice: a permissive reading delivers continuity and incumbent capture risk; a strict reading delivers independence but a transition cost and an execution risk if no credible independent candidate exists.

The closed status means the next visible step is Ofgem's, not the market's. The selection process now runs internally until Ofgem publishes the licence-grant proposals. Those proposals, not this notice, are the point at which industry can contest who ends up holding the pen on the rules.