MP171 Undertaking a FUSA without a Supply Licence

Proposer Karen Lee
Lead Analyst SEC Change
Date raised 18/06/2021
StageWithdrawn
Implementation date N/A
Latest update Following discussions with the Security Sub-Committee (SSC), our legal team and the Proposer. It is now believed that the objectives of this modification can be achieved without the need for a modification to the Smart Energy Code (SEC). The Proposer notified SECAS on 22 April 2022 of their intention to withdraw this modification. This modification has now been withdrawn.

What is the issue?

Following changes to licencing arrangements in 2019, prospective market entrants must now obtain their Supply Licence quite late on in their onboarding process. Without a Supply Licence, Suppliers cannot undertake a Full User Security Assessment (FUSA), preventing them from becoming a Data Communications Company (DCC) User. This could add several further months of delay between gaining a licence and being able to install and support smart metering for consumers. New market entrants are looking to be able to run the FUSA in parallel with the Ofgem licensing process, such that the FUSA is completed subject to successful award of a Supply Licence. This would enable them to be ‘smart from the start’.

A second issue has also been identified by the Proposer. The Smart Energy Code (SEC) currently does not allow for an organisation to withdraw from the SEC whilst holding a Supply Licence. This means the Supplier remains obligated to comply with the SEC, even if it has no registered smart metering points. Consequently, the Supplier could be incurring costs for activities such as security assessments and is trying to exit the smart energy market.

Who is impacted?

Large Suppliers
Small Supplier

What SEC documents are affected?

• SEC Section G ‘Security’
• SEC Section H ‘DCC Services’
• SEC Section M ‘General’

Timeline

18 Jun 2021
Draft Proposal raised
29 Jun 2021
Presented to CSC for initial comment
01 Feb 2022
to
31 Mar 2022
Draft Proposal converted to Modification Proposal
01 Mar 2022
to
15 Apr 2022
Draft legal text
01 Mar 2022
to
22 Apr 2022
SECAS developed solution with Proposer
06 Apr 2022
Modification discussed with Working Group
22 Apr 2022
Modification withdrawn

Modification documents

MP171 Working Group meeting summary - April 2022
12/05/2022
MP171 Modification Report v0.3
04/05/2022
DP171 Modification Report v0.2
01/09/2021
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