26 March 2026
While the decision applies across the wider energy code reform programme, it has significant implications for the gas sector as work progresses towards the development of a consolidated Gas Network Code.
The publication moves the code reform programme further from policy design into implementation. For gas market participants, this is an important moment to understand what has been decided – and how the industry can help shape what comes next.
From policy to implementation
Ofgem’s decision confirms its approach across several important elements of the future governance framework, including the future code modification process, Stakeholder Advisory Forums (SAF), cost recovery arrangements, and the role of central system delivery bodies.
Alongside the decision, Ofgem has published proposed code text reflecting these policy positions and is inviting feedback from stakeholders.
The regulator has also issued updated guidance on the Code Manager selection process and opened a call for expressions of interest to participate in the Code Consolidation Workgroup (CCW) for Phase 2.
Together, these steps signal the transition from high-level proposals to the practical development of the new governance framework.
Collaboration will be essential
Earlier this month Encodar and Xoserve, alongside Talan, submitted a joint expression of interest to become the Gas Network Code Manager and deliver Ofgem’s energy code reform. Our Gas Network Code collaboration brings together the deep expertise of the Central Data Services Provider, UNC Code Administrator and Independent Gas Transporter UNC Code Administrator, giving us a comprehensive understanding of both the shared challenges and the nuanced differences across the entire gas market.
With proven experience in delivering previous code consolidations, we offer holistic insight and practical capability needed to shape a streamlined, efficient and effective code framework for the future.
As part of our collaborative approach to delivering successful code reform, Kate Elleman from Encodar and Jayne McGlone from Xoserve helped support Ofgem as legal text expert readers to review the code modification process and Stakeholder Advisory Forum code text, which is now being consulted on.
Both Kate Elleman and Jayne McGlone have decades of regulatory and contractual experience and were able to provide Ofgem with comfort that all code text was complete and can be smoothly implemented to deliver the policy direction.
A key opportunity for the gas sector
Energy code reform represents one of the most significant changes to industry governance in many years. Successfully implementing these changes will depend on continued collaboration between regulators, code bodies and industry stakeholders.
The experience and expertise that already exists across the gas sector will be essential in ensuring that the new framework supports efficient governance while maintaining stability and transparency for market participants. Active engagement from across the industry will help ensure that the new code arrangements work effectively in practice and support the long-term development of the gas market.
For the gas industry, one of the most important next steps will be the Code Consolidation Workgroup (CCW) Phase 2, which is expected to begin later this summer.
This group will play a central role in developing the modifications required to create a single consolidated Gas Network Code - a key objective of the wider reform programme.
Participation in the workgroup provides an important opportunity for stakeholders to ensure that the new consolidated code reflects the operational realities of the gas market and supports the sector as it continues to evolve. The closing date for expression of interest is 17 April 2026.
Next steps for stakeholders – a moment to engage
Ofgem has opened several opportunities for stakeholders to engage with the next phase of code reform.
By 17 April 2026, organisations are asked to review and provide feedback on the proposed code text for the future code modification process and Stakeholder Advisory Forums and submit an expression of interest to participate in the Code Consolidation Workgroup.
These engagement opportunities provide a pathway for industry to contribute to shaping the future code framework and we look forward to contributing to Phase 2 of the Code Consolidation Workgroup and supporting the sector through this important transition.
As the code reform programme progresses, the continued involvement of the gas sector will play an important role in ensuring that the new governance arrangements deliver on the objectives set out in the Energy Act 2023 – consolidating and simplifying existing codes into a single gas network code, supporting the transition to future gas markets and aligning with net zero objectives.
By working collaboratively across the industry, stakeholders can help shape a code framework that supports effective governance, enables innovation and reflects the realities of the gas market.
Get in touch
If you have any feedback or questions on any of the above, please email us at communications@xoserve.com.
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