TL;DR: Key Takeaways
The News: On 10 December 2025, the Government published a consultation under the Smart Secure Electricity Systems (SSES) programme introducing a Load Control Licence for energy flexibility providers. This new energy flexibility regulation ends the unregulated “Wild West” era of Demand Side Response.
Small Business Protections: If your business consumes under 200,000 kWh per year or has fewer than 50 employees, you are now a “Protected Customer” with rights to fair treatment, proportionate exit fees, and Energy Ombudsman access.
Cyber Security Standards: Any licensed provider must meet the Cyber Assessment Framework (CAF) - proving they have robust defences against cyber attacks before they can control your energy smart appliances.
The Timeline: Regulations expected Autumn 2026, applications open late 2026, aggregator licensing requirement in force by end of 2027.
What This Consultation Signals
Last week, we told you that your business could earn revenue by being flexible with its energy. This week, the Government announced the flexibility provider regulation that makes it safe to do so. The Load Control Licence is an important piece of the puzzle that turns consumer-led flexibility from a niche experiment into a standard business asset.
The Problem: Why Flexibility Felt Risky
For many business owners, the idea of Demand Side Response - allowing a third party to turn down your heating or pause your EV charging remotely - sounds financially attractive but operationally scary.
The concerns were legitimate:
- What if they hack my system?
- What if they treat me unfairly?
- Who do I complain to if something goes wrong?
Until now, this market was largely unregulated. You had to trust that your aggregator was competent and honest - with no regulatory backstop if they were not.
The Government’s new consultation under the SSES programme has signalled the end of this uncertainty. A Load Control Licence will be required for any organisation that remotely controls your energy smart appliances.
1. You Are Now a “Protected” Customer
Historically, business energy protections have been weak compared to domestic consumers. But under these new energy flexibility regulation proposals, “Small Business Consumers” are getting a major upgrade in consumer-led flexibility protections.
Who Qualifies as a Small Business Consumer?
If your business meets either of these criteria:
- Annual electricity consumption under 200,000 kWh, OR
- Fewer than 50 employees
…then any Flexibility Service Provider (FSP) you contract with will be legally required to follow strict conduct standards.
Your New Rights
Fair Treatment: FSPs must adhere to strict Standards of Conduct regarding honesty and transparency. No more aggressive sales tactics or misleading claims about what flexibility can deliver.
No “Lock-Ins”: Exit fees must be proportionate and cannot exceed the provider’s direct economic loss. You can switch providers easily without penalty traps.
Ombudsman Access: If things go wrong, you will have the right to take disputes to the Energy Ombudsman - a power previously reserved mostly for domestic energy supply issues.
2. Cyber Security is Non-Negotiable
Handing over control of your energy smart appliances requires digital trust. You do not want a hacker turning off your factory’s power or manipulating your EV chargers.
The new flexibility provider regulation introduces a Cyber Assessment Framework (CAF) as part of the SSES programme.
Two-Tier Security Model
Tier 1: For massive aggregators managing 300MW or more. These operators will be designated as “Operators of Essential Services” under the Network and Information Systems Regulations 2018, regulated directly by Ofgem.
Tier 2: For smaller providers managing under 300MW. This tier covers most SME-focused flexibility providers and still requires robust cyber security standards.
What This Means for You
Any licensed partner you work with must prove they have robust defences against cyber attacks. You are not just connecting to an app - you are connecting to regulated, secure infrastructure.
Before signing with any flexibility provider, ask them: “Are you CAF Tier 1 or Tier 2 compliant?” If they cannot answer clearly, they may not survive the coming regulatory requirements.
3. The “Intermediary” is Regulated
The new rules distinguish between two types of players in the flexibility market:
Load Controller
The tech company sending the digital signal to your device. This is the organisation that:
- Creates the load control signal
- Changes or modifies load control signals
- Controls the timing of sending signals to effect load control
Flexibility Service Provider (FSP)
The company you sign a contract with - the entity that enters into agreements with consumers to provide load control services on their Energy Smart Appliances.
No More Loopholes
Both types of organisation will be brought under the regulatory umbrella. This ensures there are no “loopholes” where a company can claim they are not responsible for your service just because they are “just the software provider.”
The consultation specifically notes that intermediaries cannot dodge responsibility by separating their commercial and technical functions across different entities.
4. The Regulatory Timeline
The SSES programme regulations for aggregator licensing are set to come into full force by the end of 2027. Here is the expected sequence:
Autumn 2026: Regulations expected to be laid before Parliament
Late 2026: Application window opens for Load Control Licences
End 2027: Licence requirement comes into force (12-month transition from regulations)
2029: Energy Smart Appliance regulations Phase 2 comes into force
The “Gold Rush” for Quality
This creates a market sorting mechanism. The cowboys will leave the market, and legitimate, tech-first players will remain.
Businesses that want to participate in flexibility should use this window to identify quality providers - those already preparing for compliance will be the safest long-term partners.
5. What Energy Smart Appliances Are Covered?
The first phase of Load Control Licence regulations covers these energy smart appliances:
- Electric vehicle smart charge points (EVSCPs)
- Smart heating appliances (heat pumps, smart storage heaters)
- Domestic-scale battery energy storage systems (BESS)
- Private electric vehicles
If your business has any of these assets and is considering consumer-led flexibility participation, the provider managing them will need a licence.
The PAS1878 Connection
This regulation works alongside the PAS1878 interoperability standard we discussed in our DSR guide. Equipment that is PAS1878 compliant can work with any licensed aggregator - meaning you are never trapped with a single provider.
What This Means for Your Business
If You Are Already Participating in Consumer-Led Flexibility
Check with your current aggregator or FSP about their aggregator licensing plans. Ask them:
- Are you preparing for Load Control Licence application?
- Which CAF tier will you comply with?
- What happens to my contract during the transition period?
Legitimate providers should have clear answers. Evasive responses are a warning sign.
If You Are Considering Flexibility
This regulation removes one of the biggest barriers to participation: trust.
You can now confidently explore flexibility knowing that:
- Your provider will be regulated by Ofgem
- Cyber security standards are mandatory
- You have Ombudsman recourse if things go wrong
- Exit fees cannot trap you unfairly
The revenue opportunity from Demand Side Response remains - early adopters are offsetting 10-20% of their total energy bill. Now it comes with regulatory protection.
Why Meet George Welcomes This
At Meet George, we believe that automating your energy smart appliances should be as safe as banking online. These energy flexibility regulations are the final piece of the puzzle that turns consumer-led flexibility from a niche experiment into a standard business asset.
Our Position: We welcome any regulation that raises standards in the energy market. We have already seen the impact of Ofgem’s TPI regulations on cleaning up the broker market. The Load Control Licence will do the same for flexibility.
Our Flexibility Partners: While we do not manage flexibility directly yet, we have vetted partners who are already aligning with these high standards. We only work with aggregators who demonstrate:
- Clear cyber security credentials
- Transparent commercial terms
- Commitment to regulatory compliance
If you are interested in exploring flexibility options today, email us at flexibility@meetgeorge.co.uk. We can introduce you to partners who are preparing for this regulated future.
The Bigger Picture: Regulatory Convergence
This Load Control Licence announcement under the Smart Secure Electricity Systems (SSES) programme is part of a broader regulatory shift we have been tracking. Combined with:
- Ofgem’s 2026 TPI registration for energy brokers
- Market-wide Half-Hourly Settlement (MHHS) changing how costs are allocated
- The Cost Allocation and Recovery Review examining network charges
…the message is clear: the future of energy is transparent, flexible, data-driven, and regulated.
Businesses that adapt early will benefit. Those that wait may find themselves locked out of the best opportunities.
Ready to explore your flexibility options with a partner you can trust? Learn how DSR can turn your energy bill into income or join the Meet George platform waitlist to be notified when we launch.
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