MP073 Alteration of SMKI Repository information and documentation

Proposer Gordon Hextall
Lead Analyst SEC Change
Date raised 23/04/2019
Implementation date 29/11/2019
Latest update This modification was implemented on 29 November 2019 as part of the November 2019 SEC Release.

What is the issue?

Problem Statement

The policy intent in respect of the SMKI Repository is that no information, document or other material that is placed in the SMKI Repository should be deleted, changed, altered, amended, modified or replaced in any way. This is to enable all Eligible Subscribers and Relying Parties to be reliant on the integrity of the information held in the SMKI Repository the content of which is described in SEC Section L5.1.

SEC Section L5 places obligations on the SMKI PMA to lodge, or to require the DCC to lodge, modified information or documents in the SMKI Repository. However, ambiguity within SEC Section L, due to different interpretations of Section L3.22, has lead to the DCC deleting information in SMKI Organisation and Device Certificates without SMKI PMA governance or approval. BEIS has advised that the DCC is not intended, under the SEC, to make any changes to information in the SMKI Repository and that the DCC is a ‘person’ within the meaning of SEC Section L5.5 and L5.6. The proposer wishes to remove any ambiguity from the SEC drafting and ensure there are robust governance arrangements in place.

The full Draft Proposal can be found here

Latest Progress

The Change Sub-Committee has agreed that this issue has been fully defined and is ready to be converted into a Modification Proposal. This Draft Proposal will be presented to the SEC Panel on 14 June 2019.

Does this issue affect your company? Send us your comments to

We have yet to receive any comments on this proposal. Any comments we do receive will be published on this page.

What is the solution?

Clarifying within SEC Section L5 the oversight the SMKI PMA has over any changes proposed to the SMKI Repository.

Who is impacted?


What SEC documents are affected?

SEC Section L 'Smart Metering Key Infrastructure and DCC Key Infrastructure'


23 Apr 2019
Draft Proposal raised
14 Jun 2019
DP converted to MP
17 Jun 2019
09 Jul 2019
Modification Report Consultation
24 Jul 2019
Modification Proposal approved

Modification documents

MP073 Annex A - Legal Text
MP073 Change Board Vote
MP073 Modification Report
MP073 Modification Report Consultation responses
MP073 Modification Report Consultation
DP073 Problem Statement v0.3
No files
No files
No files
No files
No files

If you believe there is a problem with this modification, please let us know HERE.

close slider