2026-081 Legal Support for Code Governance Reform

Energy code reform is modernising Great Britain's energy regulation by replacing complex, outdated governance with a simpler, more agile and forward-looking framework. Many of the rules that govern the operation of the energy system sit within industry codes. Energy code reform is a joint programme between Ofgem and

government to address these issues and turn energy codes into an effective engine for wider system change. It replaces the current governance process for updating the codes with a new framework enabled by powers in the Energy Act 2023. The reforms introduce several key improvements to the current framework, including Ofgem's

licensing new code managers. The Buyer is turning the high-level design of the new governance framework into detailed licence and code modifications to bring the new framework into effect.

Ofgem requires the supplier to provide legal support for Code Governance Reform seeking initially assessment of Balancing and Settlement Code (BSC), along with the identification areas that may require changes/amendments to align with licensing and regulatory frameworks as well as advising on areas of legal risk. The supplier will also

be required to provide legal advice that will assist in decision making. The work from the supplier is intended to include initially for the BSC and thereafter future phases of Code Reform:

• Review of code text, as amended by the prospective Code Manager, in order to ensure consistency with the Standard Licence Conditions (SLC) and associated consultations.
• Provide practical advice on available legal options, including potential legislative, regulatory or licence-based solutions to identified issues.
• Attend workshops and meetings with Ofgem's officials to test and refine legal analysis as policy development progresses if required.
• Produce concise written advice and legal briefing notes suitable for informing policy design, negotiations and decision-making as required.
• Provide follow-up advice on discrete issues arising from the initial analysis.