113 entrieslast append amendments 0register open

dcentralmind

A public register on decentralization: why power should move from the few to the many
← register
№ 57 · appended

Britain is deciding who may be exempt from needing a licence to control your heat pump, and the consultation has already closed

The exemption list is the answer to the question of who is allowed to touch the edge. A licensing regime raises the floor on cyber security and consumer protection, which is welcome to any household that would rather its heat pump not join a botnet, but it also sets a fixed cost of entry, and fixed costs sort a market towards incumbents. Class C is the one to read closely, because it tries to carve out the party controlling load for the consumer's own benefit rather than selling that flexibility upstream. Whether that carve-out is drawn wide enough to cover a community energy group, a housing association, or a household running its own software over its own battery is the entire argument, and it is being settled in drafting rather than in public.

On 7 August 2026 the Department for Energy Security and Net Zero published a consultation on class exemptions from the requirement to hold a load control licence. It closed at 11.59pm on 7 September 2026. The subject sounds narrow and the consequence is not: under The Electricity Act 1989 (Load Control Licence) Regulations 2026, carrying out load control activity without a licence or an exemption becomes a criminal offence.

Load control means deciding how or when somebody else's appliance runs. The regime is built around energy smart appliances, which in practice means electric vehicle chargepoints, heating appliances such as heat pumps, and domestic battery storage. The definition reaches the decision rather than only the wire: a company that decides when a heat pump runs is load controlling even where the instruction is carried out through an intermediary such as a home energy management system.

DESNZ proposed three exemption classes. Class A covers load controllers and flexibility service providers dealing only with appliances outside the regime's scope, which is to say not electric vehicles, not heating appliances and not battery storage. Class B covers flexibility service providers serving only customers who are neither domestic nor small business consumers. Class C covers those carrying out load control only for the purpose of benefiting consumers, and not on behalf of transmission operators, distribution network operators or wholesale traders. The department said it was also considering further exemptions for small-scale operators. The instrument being amended is the 2001 class exemptions order.

Why this is a decentralisation story and not a compliance story: the list of exemptions is the answer to the question of who is allowed to touch the edge. A licensing regime raises the floor on cyber security and consumer protection, which any household would want for a device that can be switched on and off from a server. It also, unavoidably, sets a fixed cost of entry, and fixed costs sort a market towards large incumbents. Class C is the interesting one, because it attempts to carve out the party controlling load for the consumer's own benefit rather than selling that flexibility upstream. Whether that carve-out is drawn wide enough to cover a community energy group, a housing association running its own scheme, or a household running open-source software over its own battery, is the whole argument, and it will be settled in the drafting.

What is not established needs saying, because this brief is being written from the outside. The consultation is closed and it could not be confirmed whether the government has published a response. Ofgem's parallel consultation on implementing the regime was published on 10 December 2025 and closed in February 2026, with a stated intention to respond in spring 2026 alongside final consumer protection guidance; that response could not be confirmed to exist. The commencement dates are unsettled across sources: some material says the regulations take effect by the end of 2026 with the licence requirement following at the end of 2027 after a twelve-month transition, while another reading gives March 2027 and March 2028. This item should not be published with a commencement date in it until somebody has read the regulations as laid.

Recomputes the content hash in your browser and compares it with the stamp.

Public comments

Loading…