The Energy Consultants Association has written to RECCo, copying Ofgem and Elexon, to raise concerns about R0290 – Legacy Data Item API Service.

This may sound like a technical industry change, but it has potentially significant consequences for TPIs, brokers and the non-domestic customers we support.

R0290 relates to the move towards Market-wide Half Hourly Settlement (MHHS). As part of that transition, certain legacy electricity data items may no longer be available, may become optional, or may become harder to retrieve once a meter point has migrated.

Those data items include:

• Profile Class
• Standard Settlement Configuration (SSC)
• Time Pattern Regime (TPR)
• Measurement Class
• Meter Timeswitch Code (MTC)

These are not just background industry codes. They can be essential when checking whether a customer has been correctly billed, correctly profiled, placed on the correct tariff, or supplied in line with the actual configuration of their meter.

For example, the Meter Timeswitch Code can help identify the type of meter installed and whether it supports single-rate, multi-rate, time-of-use or related meter arrangements. SSC and TPR data can also be critical when reviewing whether charges have been correctly applied across different registers or time periods.

Why This Matters for TPIs and Brokers

For ECA members, the concern is clear. Many TPIs and brokers carry out historic contract reviews, billing checks and supplier challenge work on behalf of non-domestic customers. That work often requires access to historic metering, tariff and settlement data. If that data is no longer retained or retrievable, customers may lose the ability to evidence historic supplier errors or overcharging.

This is especially important where reviews may need to go back several years. In many cases, customers may need to investigate charges within a six-year period, reflecting the ordinary limitation period for many contractual claims. A short-term data solution that disappears after MHHS migration is therefore unlikely to be sufficient.

Historic Data and Customer Protection

The ECA is also particularly concerned about historic Profile Class accuracy. We are aware of cases where non-domestic customers appear to have been left incorrectly profiled, including customers left on Maximum Demand profiles, restricting their ability to access the wider market or obtain suitable contracts. Where suppliers may not have complied correctly with BSCP516 requirements, historic Profile Class and SSC data may be vital to identifying and correcting those errors.

Concerns Around R0290 and Industry Engagement

The R0290 proposal appears to have been considered with very limited engagement. The consultation response level was exceptionally low and appears to have been limited to industry parties. There does not appear to have been meaningful representation from non-domestic customers, independent TPIs or brokers, despite TPIs being directly affected.

The ECA’s position is not simply that R0290 must be approved exactly as drafted. The issue is wider than that. If RECCo believes the proposed API is too costly or not the right technical solution, then an alternative must be put in place.

What cannot happen is that MHHS results in the loss of historic data needed by customers and their appointed representatives to verify billing accuracy, settlement accuracy and supplier compliance.

What the ECA is Calling For

The ECA is calling for:

• Historic legacy data items to be preserved beyond MHHS migration.
• Access to be made available to authorised TPIs, brokers and customer representatives.
• Data to be retained for a suitable period, at least six years.
• A controlled access route, such as a REC-governed portal, batch request process or API.
• Appropriate customer authority, audit controls and data protection safeguards.

The key point is simple: customers should not lose access to evidence simply because the industry has changed its settlement arrangements.

Why Collective Industry Representation Matters

MHHS is intended to modernise the market. It should not make it harder for non-domestic customers to challenge incorrect charges, review historic supplier conduct or obtain fair redress.

The ECA will continue to press RECCo, Ofgem and Elexon to ensure this issue is properly addressed. We will also continue to push for TPIs and brokers to be properly represented in discussions where industry data access, customer evidence and non-domestic market transparency are directly affected.

Members should be aware of this issue, particularly if they carry out historic billing reviews, profile checks, tariff validation or supplier dispute work.

If legacy data access is not protected, the ability of TPIs to support customers may be materially reduced.

This is exactly why collective industry representation matters.

Join the ECA and Help Shape the Future of the Industry

Issues such as R0290 demonstrate why collective industry representation matters. Decisions being made today around data access, market reform and customer protections will have a direct impact on TPIs, brokers and the customers they support for years to come.

The Energy Consultants Association exists to ensure the voice of energy consultants, brokers and intermediaries is heard by regulators, industry bodies and policymakers.

If you would like to find out more about ECA membership, member benefits or how we are representing the sector on key industry issues, please visit our Contact Us page or get in touch with the team today.