EnleashedEnleashed
Mission #1Delivery plan

Fix the energy market

Re-architect how energy is priced, procured, and coordinated across the grid.

Move the GB electricity market from periodic central optimisation and marginal pricing towards a continuously-coordinating, physics-aligned architecture (see the FP-AMM candidate solution in /challenge) — while keeping the lights on, prices fair, and the transition legally and politically deliverable.

2

Status quo

What exactly exists today — legally, institutionally, technically and operationally — that the desired system needs to change?

Law

Energy Act 2023 and predecessor legislation

The Electricity Act 1989 (as amended) remains the underlying legal basis for licensing generation, supply, transmission and distribution. The Energy Act 2023 created the National Energy System Operator (NESO) and gave DESNZ and Ofgem additional powers over strategic planning, but did not itself redesign wholesale market pricing or settlement.

Regulation

Ofgem licensing and price control

Generation, supply, transmission and distribution are separately licensed by Ofgem. Network companies operate under RIIO price controls. Wholesale trading itself is largely unregulated (bilateral contracts plus balancing), while settlement and imbalance pricing are governed by industry codes rather than direct licence conditions.

Institutions

NESO, Ofgem, DESNZ and the network companies

NESO operates the transmission system and runs balancing markets. Distribution Network Operators (DNOs) manage local networks. Ofgem regulates; DESNZ sets policy. Responsibility for market design change is split across all of them, with no single institution owning end-to-end market architecture.

Markets & mechanisms

Day-ahead/intraday trading plus balancing mechanism

Wholesale trading happens mostly bilaterally and on exchanges ahead of real time; NESO then balances the system in near-real-time through the Balancing Mechanism, settled half-hourly (moving towards more granular settlement). Pricing is marginal and largely uniform-national rather than reflecting local network conditions or continuous re-optimisation.

Funding

Network costs recovered through regulated charges

Network and balancing costs are recovered through regulated use-of-system charges on consumer bills, set through Ofgem price controls. There is no existing budget line for testing or transitioning to an alternative market architecture.

Technology

Legacy settlement and metering infrastructure

Settlement systems were built around half-hourly (increasingly moving to more granular) periodic clearing, not continuous or event-driven market coordination. Smart meter rollout gives more granular consumption data than a decade ago, but market systems have not been redesigned around that data.

Data

Fragmented, largely non-real-time data access

Market and network data is held across multiple parties (NESO, DNOs, Elexon, suppliers) with limited standardised, real-time, publicly accessible interfaces. Independent replication of market analysis is difficult without negotiated data access.

Operations

Manual, forecast-driven balancing

Day-to-day operation depends heavily on forecasting and corrective balancing actions rather than continuous, participant-driven coordination. Increasing shares of distributed generation and flexible demand are straining an architecture designed around a smaller number of large, predictable generators.

3

The change map

Every concrete change required to move from the status quo to the desired system, with who has authority, the legal mechanism, and current status.

RegulationResearching

Ofgem licence/rule change enabling AMM-based settlement

Regulatory / market design · Licence modification

+

Current state

Settlement and imbalance pricing operate under existing Balancing and Settlement Code (BSC) rules and supplier/generator licence conditions, built around periodic marginal clearing.

Desired state

A licence and/or code framework that permits continuous, AMM-based clearing and forward flexibility procurement to operate alongside (and eventually instead of) the existing mechanism.

Change required

Ofgem would need to run a case for change, consult, and either modify relevant licence conditions or approve a code modification route (see the linked BSC change item) to permit the new mechanism to operate, initially likely in a sandboxed or pilot form.

Authority / delivery

Ofgem· Authority

Pathway

Regulatory

Evidence required

Technical feasibility evidence, a regulatory impact assessment, and a consumer/distributional impact analysis.

Funding required

Regulatory and legal pathway analysis (indicative estimate, not yet costed).

Owner: Enleashed / mission lead

InstitutionsNot started

Balancing and Settlement Code modification for continuous clearing

Industry code · Industry code modification

+

Current state

The BSC defines half-hourly (moving towards more granular) settlement, administered by Elexon under BSC Panel governance.

Desired state

A BSC modification (or equivalent successor code) that accommodates continuous, event-driven clearing rather than only fixed-period settlement.

Change required

Raise a formal modification proposal, work it through an Elexon workgroup and impact assessment, and secure a BSC Panel/Ofgem decision.

Authority / delivery

Elexon / BSC Panel· Authority

Pathway

Industry code

Depends on

Independent AMM pilot on a live network segmentNot started

Evidence required

Working technical demonstration of continuous clearing compatible with existing settlement obligations.

Funding required

Not yet costed.

InstitutionsResearching

NESO operational responsibility for forward flexibility procurement

Institutional · Institutional decision

+

Current state

NESO procures balancing and some flexibility services through existing balancing-mechanism and ancillary-service routes.

Desired state

NESO (or a successor operational function) directly procures forward flexibility through the AMM mechanism as a core operational responsibility.

Change required

NESO leadership would need to scope, trial and formally adopt the new procurement route as part of its operational remit.

Authority / delivery

NESO· Delivery body

Pathway

Institutional

Evidence required

Pilot results demonstrating operational reliability.

Funding required

Not yet costed.

PolicyBuilding support

DESNZ policy support for an AMM-based market design pathway

Government policy · Other

+

Current state

DESNZ's market reform work (e.g. Review of Electricity Market Arrangements) has considered zonal/nodal pricing reforms but has not evaluated an AMM-based architecture as a distinct option.

Desired state

DESNZ treats an AMM-based architecture as a credible option within its market reform programme, backed by evidence.

Change required

Brief the DESNZ market reform team, submit evidence to relevant consultations, and build a credible case alongside the regulatory and technical workstreams.

Authority / delivery

DESNZ· Authority

Pathway

Government policy

Evidence required

Independent technical and economic evidence; comparison against other reform options under consideration.

Funding required

Not yet costed.

LawNot started

Confirm whether primary legislation is required

Legislative (conditional) · Legislation

+

Current state

It is not yet established whether the Electricity Act 1989 and Energy Act 2023 already provide sufficient legal basis for this change via licence/code modification, or whether new primary legislation would be needed.

Desired state

A clear legal opinion on the minimum legislative pathway required, so effort isn't wasted pursuing a legislative route if a regulatory one would suffice (or vice versa).

Change required

Commission a legal feasibility review comparing the licence-modification route against a legislative route.

Authority / delivery

Parliament· Authority

Pathway

LegislativeRegulatory

Evidence required

Legal feasibility analysis.

Funding required

Legal and regulatory pathway analysis (indicative estimate, not yet costed).

TechnologyNot started

Independent AMM pilot on a live network segment

Technical · Procurement

+

Current state

The AMM mechanism has been modelled and simulated (see /challenge candidate solutions and evidence) but not yet operated against a live network segment.

Desired state

A working pilot, run with a willing network operator or supplier, operating the AMM mechanism against real (or shadow) load and generation.

Change required

Secure a pilot partner (e.g. via an innovation-funding route such as Ofgem's Strategic Innovation Fund), build the pilot infrastructure, and run it under appropriate regulatory sandbox arrangements.

Authority / delivery

Distribution Network Operators· Delivery bodyIndependent academic and technical experts· Expert

Pathway

TechnologyProcurement

Evidence required

Pilot results; safety and reliability evidence.

Funding required

Pilot build and operation (indicative estimate, not yet costed).

4

Who can act?

Decision makers, delivery bodies, influencers, beneficiaries, potential opponents, experts, the public and funders — transparent democratic advocacy, not tactics.

Decision maker (3)

Ofgem

Regulator · Office of Gas and Electricity Markets

Unknown

Formal power

Sets and modifies licence conditions; approves code modifications; runs price controls.

Informal influence

Regulatory signalling shapes what industry treats as viable to invest in.

Interests

Consumer protection, system reliability, value for money, net zero delivery.

Concerns

Untested mechanisms creating consumer or system risk; process legitimacy.

DESNZ

Government department · Department for Energy Security and Net Zero

Unknown

Formal power

Sets energy policy; can bring forward legislation; funds innovation programmes.

Informal influence

Ministerial attention strongly shapes Ofgem and NESO's prioritisation.

Interests

Bill affordability, energy security, net zero delivery, political deliverability.

Concerns

Delivery risk during an already-complex market reform programme (REMA).

Parliament

Legislature

Unknown

Formal power

Only body that can pass primary legislation, if a legislative route turns out to be required.

Informal influence

Select committee scrutiny can put pressure on Ofgem/DESNZ even without new law.

Interests

Constituent bill impact, energy security, net zero commitments.

Concerns

Legislative time is scarce; this would need a strong, evidenced case.

Delivery body (3)

NESO

System operator · National Energy System Operator

Unknown

Formal power

Operates the transmission system and balancing mechanism; a required delivery partner for any live pilot.

Informal influence

Technical credibility with Ofgem and DESNZ on operability questions.

Interests

System reliability, operability, a manageable transition path.

Concerns

Operational risk from running two mechanisms in parallel during transition.

Elexon / BSC Panel

Code administrator · Elexon

Unknown

Formal power

Administers the BSC modification process; the Panel recommends modification decisions.

Informal influence

Sets the practical pace at which any code-based change can move.

Interests

Settlement integrity, industry-wide workability.

Concerns

Implementation complexity and cost for all BSC parties, not only this mission.

Distribution Network Operators

Delivery / potential pilot partner

Unknown

Formal power

Control access to the network segments any pilot would need to run on.

Informal influence

Practical gatekeepers for real-world trial credibility.

Interests

Network reliability, an evidence base for their own investment planning.

Concerns

Operational and reputational risk from an unproven mechanism.

Beneficiary (1)

Households and businesses

Consumers

Unknown

Formal power

No direct formal power over market design decisions.

Informal influence

Collective consumer sentiment shapes political pressure on ministers and Ofgem.

Interests

Lower, fairer bills; reliable supply.

Concerns

Complexity or risk that ends up passed through to bills.

Potential opponent (1)

Incumbent suppliers and generators

Market participants

Unknown

Formal power

No formal veto, but participate in code modification workgroups and consultations.

Informal influence

Substantial lobbying capacity and existing relationships with Ofgem/DESNZ.

Interests

Revenue predictability, manageable transition and compliance cost.

Concerns

Stranded investment under existing market rules; competitive exposure under a new mechanism.

Expert (1)

Independent academic and technical experts

Expert reviewers

Open

Formal power

No formal decision power, but credibility with regulators depends on independent validation.

Informal influence

Peer review and replication materially affects how seriously Ofgem/DESNZ take the evidence.

Interests

Methodological rigour, publishable research questions.

Concerns

Evidence needs to be genuinely independently reproducible, not just self-published.

Funder (1)

Innovation and philanthropic funders

Funders

Unknown

Formal power

Control access to grant and innovation funding routes (e.g. Ofgem SIF, research councils, philanthropy).

Informal influence

Funding decisions signal credibility to other stakeholders.

Interests

Public-interest impact, well-evidenced proposals.

Concerns

Delivery capability and governance of the recipient organisation.

5

Pathways to change

Not every change happens the same way. These are the generic routes this mission's changes can take — highlighted where a change item actually uses them.

Legislative

In use

Change requires new primary or secondary legislation from Parliament.

Drafting → Parliament → Bill → Act → Implementation

Regulatory

In use

Change requires a regulator (e.g. Ofgem) to run a decision or licence-modification process.

Case for change → Regulator consultation → Decision → Licence / rule change → Implementation

Industry code

In use

Change is delivered through an industry code's own governance process (e.g. BSC, CUSC, Grid Code).

Modification proposal → Workgroup → Impact assessment → Panel / authority decision → Implementation

Government policy

In use

Change requires a government department to adopt a policy position and commit to it.

Evidence → Department engagement → Ministerial support → Policy decision

Institutional

In use

Change is a decision an institution (e.g. NESO, a network operator) can make about its own responsibilities or operations.

Proposal → Board / leadership decision → Organisational reform

Procurement

In use

Change is delivered by specifying and procuring a system, service or pilot.

Specification → Funding → Procurement → Deployment

Voluntary market adoption

Change spreads through the market without a mandate — early adopters demonstrate it, then it scales.

Demonstration → Early adopters → Scaling

Technology

In use

Change depends on building and proving working software or infrastructure first.

Research → Prototype → Pilot → Production → Integration

Public / political

Change depends on public understanding and political will, not only technical or regulatory steps.

Evidence → Communication → Coalition → Public support → Political commitment

Funding

Change is blocked on securing the money to do the work, not on a decision or a mechanism.

Case → Funder → Commitment → Deployment

6

Change agents

What forces could actually make this change happen?

Economic necessity

The cost of the status quo becomes too high to justify inaction.

Academic evidence

Peer-reviewed or independently validated research shifts the debate.

Technical demonstration

A working prototype or pilot proves the idea is real.

Regulator leadership

The regulator's own leadership decides to prioritise this.

Consultations

A formal consultation creates the structured route to a decision.

Funding

Money becomes available to do the work that unblocks everything else.

7

Coalition / buy-in

What legitimate concerns must be resolved to build a coalition capable of delivering change?

Champion (0)

Supportive (0)

Open (1)

Independent academic and technical experts

Evidence needs to be genuinely independently reproducible, not just self-published.

Unknown (9)

Ofgem

Untested mechanisms creating consumer or system risk; process legitimacy.

DESNZ

Delivery risk during an already-complex market reform programme (REMA).

Parliament

Legislative time is scarce; this would need a strong, evidenced case.

NESO

Operational risk from running two mechanisms in parallel during transition.

Elexon / BSC Panel

Implementation complexity and cost for all BSC parties, not only this mission.

Distribution Network Operators

Operational and reputational risk from an unproven mechanism.

Households and businesses

Complexity or risk that ends up passed through to bills.

Incumbent suppliers and generators

Stranded investment under existing market rules; competitive exposure under a new mechanism.

Innovation and philanthropic funders

Delivery capability and governance of the recipient organisation.

Concerned (0)

Opposed (0)

8

Evidence needed for change

Different decision makers require different evidence. Connects back to the Challenge investigation's evidence where it already exists.

Independent replication of the AMM simulation

Academic validation · supports "Independent AMM pilot on a live network segment"

Missing

Required by: Ofgem, academic reviewers

How we get it: Commission or partner with an independent academic group to reproduce the published results.

Consumer and distributional impact analysis

Consumer impact · supports "Ofgem licence/rule change enabling AMM-based settlement"

Missing

Required by: Ofgem, DESNZ

How we get it: Commission economic modelling of bill impact across household types.

Legal feasibility of the licence-modification route

Legal feasibility · supports "Confirm whether primary legislation is required"

Missing

Required by: Ofgem legal, DESNZ

How we get it: Commission external legal opinion comparing licence-modification and legislative routes.

Cybersecurity assessment of real-time settlement infrastructure

Cybersecurity · supports "Independent AMM pilot on a live network segment"

Missing

Required by: NESO, Ofgem

How we get it: Independent security review ahead of any live pilot.

International precedent review (PJM, Australia NEM, GB alternatives)

International precedent

Available

Required by: DESNZ, general credibility

How we get it: Already covered in the /challenge candidate-solution comparison (GB, Zonal, PJM, Australia, FP-AMM).

9

Fund the mission

Funding as a first-class delivery workstream — required, secured and the gap, by workstream.

Required

£550,000

Secured

£0

Gap

£550,000

Evidence

Independent replication & peer review

Research funding

Indicative estimate — not yet independently costed.

£50,000

£0 secured

Law

Legal and regulatory pathway analysis

Philanthropy

Indicative estimate — not yet independently costed.

£50,000

£0 secured

Technology

SIF discovery-phase project

Innovation funding

Indicative estimate modelled on published Ofgem Strategic Innovation Fund discovery-phase grant sizes — not a submitted bid.

£150,000

£0 secured

Technology

AMM pilot build and operation

Innovation funding

Indicative estimate, likely route: Ofgem Strategic Innovation Fund or equivalent, following a successful discovery phase.

£250,000

£0 secured

Campaign

Public explainers and communications

Community funding

Indicative estimate — not yet independently costed.

£20,000

£0 secured

Coalition

Coalition and stakeholder engagement capacity

Philanthropy

Indicative estimate — not yet independently costed.

£30,000

£0 secured

Fund this mission →
10

Campaign / communication

Public understanding and political support this mission needs, and what each piece of communication is trying to achieve.

Explainer

Why the GB electricity market needs an AMM

Planned

Give a non-technical audience a clear, honest explanation of the problem and the proposed direction.

Consultation response · supports "Ofgem licence/rule change enabling AMM-based settlement"

Response to the relevant Ofgem/DESNZ market reform consultation

Planned

Put the evidence and proposed pathway formally on the regulatory record.

Parliamentary engagement · supports "DESNZ policy support for an AMM-based market design pathway"

Briefing for the relevant select committee

Planned

Build parliamentary awareness and scrutiny pressure alongside the regulatory and policy workstreams.

11

Build

Technology is one delivery workstream among many — shown here only where it's required to deliver the agreed solution.

TechnologyNot started

Independent AMM pilot on a live network segment

Technical · Procurement

+

Current state

The AMM mechanism has been modelled and simulated (see /challenge candidate solutions and evidence) but not yet operated against a live network segment.

Desired state

A working pilot, run with a willing network operator or supplier, operating the AMM mechanism against real (or shadow) load and generation.

Change required

Secure a pilot partner (e.g. via an innovation-funding route such as Ofgem's Strategic Innovation Fund), build the pilot infrastructure, and run it under appropriate regulatory sandbox arrangements.

Authority / delivery

Distribution Network Operators· Delivery bodyIndependent academic and technical experts· Expert

Pathway

TechnologyProcurement

Evidence required

Pilot results; safety and reliability evidence.

Funding required

Pilot build and operation (indicative estimate, not yet costed).

Technical milestones

  • Pilot partner secured — enables "Independent AMM pilot on a live network segment"Not started
  • Prototype operational — enables "Independent AMM pilot on a live network segment"In progress
12

Roadmap

Milestones from every workstream, together — not a generic month-by-month calendar.

Policy
  • Desired outcomes agreed
  • DESNZ policy engagement
Law
  • Legislative pathway identified
Regulation
  • Ofgem engagement
  • Regulatory impact assessment
  • Consultation launched
  • Regulatory approval
Evidence
  • Candidate architecture published
  • Academic evidence published
  • Independent replication
Funding
  • Pilot funded
Technology
  • Pilot partner secured
  • Prototype operational
Implementation
  • National implementation— needs Regulatory approval, Pilot funded, Prototype operational, Legislative pathway identified
  • Outcome verification— needs National implementation
13

Blockers / risks

What could stop this?

Incumbent opposition to redesigned settlement

Open
Likelihood: HighImpact: Highaffects "Ofgem licence/rule change enabling AMM-based settlement"

Suppliers and generators with revenue certainty under the current mechanism may lobby against change.

Mitigation: Engage incumbents early; design a transition path that limits sudden exposure; use independent evidence to keep the debate on substance.

Insufficient independent evidence to satisfy the regulator

Open
Likelihood: MediumImpact: High

Self-published simulation results may not be treated as sufficient by Ofgem.

Mitigation: Prioritise securing independent replication before seeking formal regulatory engagement.

Funding gap stalls the pilot

Open
Likelihood: MediumImpact: Mediumaffects "Independent AMM pilot on a live network segment"

Without secured funding, the pilot (and the evidence it would produce) cannot proceed.

Mitigation: Pursue multiple funding routes in parallel (innovation funding, philanthropy, industry partners).

Cybersecurity or resilience concerns block regulatory approval

Open
Likelihood: LowImpact: Highaffects "Independent AMM pilot on a live network segment"

Real-time settlement infrastructure is a plausible target for scrutiny on security grounds.

Mitigation: Commission an independent security review ahead of seeking approval, not after.

Political attention shifts away from market reform

Open
Likelihood: MediumImpact: Medium

DESNZ's REMA programme and ministerial priorities can change; this mission depends partly on that attention continuing.

Mitigation: Keep the case grounded in economic necessity and evidence, not dependent on any one political moment.

14

Next actions

What actually needs to happen next.

Not started

Secure a network operator for an SIF discovery-phase pilot

Owner: unassigned · related to "Independent AMM pilot on a live network segment"

Introduce a network operator
Not started

Produce an Ofgem regulatory-pathway analysis

Owner: unassigned · related to "Ofgem licence/rule change enabling AMM-based settlement"

Not started

Meet the DESNZ market reform team

Owner: unassigned · related to "DESNZ policy support for an AMM-based market design pathway"

Not started

Secure independent replication of the AMM simulation

Owner: unassigned

Not started

Raise £50k for legal and regulatory pathway analysis

Owner: unassigned · related to "Confirm whether primary legislation is required"

Fund this
In progress

Complete an independent AMM simulation covering GB-scale operation

Owner: unassigned · related to "Independent AMM pilot on a live network segment"

15

How can I help?

Enleashed is collaborative — concrete ways to get involved with this mission.

Explain · Convene

Conversations & outreach

Public conversations that explain this mission's thinking and expose it to criticism and collaboration. This supports delivery — it isn't evidence that the underlying solution works.

A Fair, Flexible, Zero-Waste Digital Electricity Market

EnergyOS

This conversation explores the thinking behind a fundamentally different electricity-market architecture: one designed around digital infrastructure, distributed assets, network constraints and fairness, rather than continually adding new mechanisms around a legacy market. The discussion connects Shaun Sweeney's PhD research with the wider Enleashed mission to ask a more fundamental question: if we were designing an electricity market today using modern computing, communications and control technology, would we design anything resembling the market we currently have?

Explore conversation

Entrepreneurship 101: From Industry to Research-Led Entrepreneurship

Universal Podcast Network

Why would someone leave industry and return to academia to solve a problem? This conversation explores the path from working inside the energy sector to stepping outside its existing assumptions, undertaking a PhD and eventually founding Enleashed as a research-led initiative. It considers the tension between entrepreneurship and academic research, the role of first-principles thinking in tackling systemic problems, and how research can be turned into candidate solutions capable of being tested and ultimately deployed. The second half of the conversation focuses on electricity-market reform: why electricity-market architecture matters to ordinary households, how fairness can become a formal engineering and market-design objective, and what a fundamentally different relationship between households and the electricity system could look like.

Explore conversation
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