In response to the Department for Energy Security and Net Zero (DESNZ) consultation on ‘Smart Secure Electricity Systems (SSES) Programme: draft load control licence regulations and conditions’, Energy Systems Catapult said:

Load control will be central to unlocking consumer-led flexibility and supporting a secure, flexible, Net Zero electricity system. Implementation of the load control licence regulations and conditions should be proportionate and risk-based, targeting only those who control load while supporting innovation and competition.

Key points

• Load control licensing should enable secure, trusted consumer-led flexibility. A clear statutory footing, with Ofgem able to license the right duty holders, should strengthen accountability, consumer confidence, and system security as activity scales.
• Implementation must be proportionate and risk-based, with clear scope boundaries. High fixed costs and unclear boundaries risk excluding smaller, software-led providers and discouraging modular supply chains. Government should clarify how Home Energy Management Systems (HEMS) and optimisation services are treated where they may initiate or schedule control actions, particularly where they are optimised for weather conditions and comfort levels in homes.
• Definitions, exemptions, and compliance routes must be practical and scalable. Clear guidance and worked examples, light-touch evidencing where appropriate, and code obligations that are clearly defined and scaled with materiality will reduce friction. Targeted exemptions for small-scale pilots and confirmation that passive intermediaries are out of scope would help.