Sets out the process for raising, assessing, deciding and implementing changes to the Market Facilitator Rules, and the process for progressing Derogations against Flexibility Market Rules, where applicable.
The purpose of this document is to provide a clear and transparent framework for how changes to the Market Facilitator Rules are to be raised, assessed, decided and implemented.
It sets out the end-to-end process for progressing Change Proposals and Issues, including the criteria against which they are evaluated (the Change Objectives), the roles and responsibilities of the Market Facilitator, System Operators, and Interested Persons, and the mechanisms for consultation and decision-making. By defining these procedures, the document ensures that changes are managed in a consistent, efficient, and fair manner, while safeguarding the integrity and objectives of the Market Facilitator Arrangements.
This document has been developed in accordance with, and is subject to, the Market Facilitator Governance Framework Document (the “Governance Framework Document”), as published and designated by the Authority from time to time.
This document applies to all changes to the Market Facilitator Rules, including the creation of new Market Facilitator Documents and/or Flexibility Market Rules and the amendment or removal of existing ones.
The scope includes the roles and responsibilities of the Market Facilitator, System Operators, Interested Persons, the Authority and the Stakeholder Advisory Board (SAB).
This document does not cover changes to wider Industry Codes, legislation, licences or frameworks.
While a Change Proposal may result in System Operators or other market participants needing to make changes to their own systems or processes, the management and implementation of such changes by those parties are not governed by this procedure.
Changes to the Market Facilitator’s budget, funding arrangements, and the associated appeal process are also outside the scope of this document.
The main users of this procedure are:
Market Facilitator – responsible for managing this Change Management Procedure; determining whether a Change Proposal should be treated as urgent (where requested); prioritising Change Proposals and Issues (where necessary); supporting Proposers and Alternative Proposers in developing their solutions; and determining whether to approve or reject Change Proposals, subject to appeal to the Authority.
SAB – provides guidance and advice on Change Proposals, including on the Change Prioritisation, Progression Route and Progression Plan, and other matters to be considered and assessed; and recommends whether Change Proposals should be approved or rejected.
The Authority – decides on appeals relating to Market Facilitator decisions on Change Proposal and appeals concerning the inclusion or exclusion of Alternative Solutions.
Interested Persons – responsible for raising Issues or Change Proposals, providing information and feedback during consultations, and constructively engaging in this Change Management Procedure.
National Energy System Operator (NESO) and Distribution Network Operators (DNOs) – in addition to the responsibilities of an Interested Person, they may also be required to provide details of the impact of a Change Proposal on their organisation through the IA process.
A Change Proposal (CP) is a formal request to amend, create, or remove any part of the Market Facilitator Rules. It sets out the issue or defect to be addressed, the rationale for change, and the Proposed Solution (including any Alternative Solutions, where applicable). A Change Proposal must contain sufficient information to allow the Market Facilitator and stakeholders to assess its impacts, consider its alignment with the Change Objectives, and determine whether it should be approved or rejected.
A Proposer or Alternative Proposer may withdraw support for their Proposed Solution or Alternative Solution at any time before the publication of the Assessment Report, by notifying the Market Facilitator in writing and providing the reasons for withdrawal.
Upon receipt of such notice, or where the Proposer or Alternative Proposer has become unresponsive, the Market Facilitator shall, as soon as reasonably practicable, notify via the Change Mailing List, that the Proposer and/or Alternative Proposer has withdrawn support. The date on which this notification is sent shall mark the opening of a 15 Working Day adoption window. In that notification, the Market Facilitator shall invite Interested Persons to adopt the Proposed Solution or any Alternative Solutions.
Any adoption shall be on a first-come, first-served basis as notified by the Market Facilitator.
The Market Facilitator may itself choose to adopt any withdrawn Proposed Solution or withdrawn Alternative Solutions.
Where the Proposed Solution and all Alternative Solutions are withdrawn, and no adoption takes place, the Change Proposal shall be treated as withdrawn and shall be closed upon the expiry of the adoption window.
If the Market Facilitator receives notice from an Interested Person willing to adopt the Proposed Solution or any Alternative Solution, that Interested Person shall become the Proposer for the Proposed Solution or the Alternative Proposer for the Alternative Solution, as applicable.
The Market Facilitator shall update the Change Register to reflect the new Proposer and/or Alternative Proposer and notify its Change Mailing List.
Where an Interested Person identifies an issue, problem, defect, or potential improvement with the Market Facilitator Rules but is unsure how or whether to progress the concern, or wishes to explore possible solution options, an Issue should be raised. This pre-change process is intended to assist in framing the issue(s) or defect(s) and identifying potential CPs. It may also be used to help explore Delivery Plan Change Opportunities, for example.
Where necessary, the Market Facilitator shall prioritise Change Proposals and Issues in accordance with the following criteria, and shall take into account the views of the Proposer when applying those criteria:
Alignment with the Delivery Plan objectives – includes being able to demonstrate a link to the Delivery Plan;
Implementation costs – considering the cost and feasibility of implementing the Change Proposal, including the likely implications for stakeholders (e.g., process changes, potential system impacts, cross-code changes, and industry resource requirements such as workgroup meetings);
Importance – includes the perceived value, criticality, and risks to industry and consumers (e.g., interactions with, or enabling of, financial, regulatory, licence, or compliance obligations; cost implications for stakeholders), taking account of any written guidance provided by the Authority; and
Time-sensitivity – includes cases where Change Proposals require expedited consideration. Complexity, importance, and implementation timescales shall all be factors in assessing time-sensitivity.
Prioritisation shall determine the pace at which Change Proposals and Issues are progressed. Each Change Proposal or Issue shall be assigned one of the following priority categorised:
Low priority – Change Proposals or Issues that will be parked and considered in subsequent Delivery Periods;
Standard priority – Change Proposals or Issues to be progressed in accordance with standard timelines and resourcing; or
High priority – Change Proposals or Issues requiring accelerated assessment and delivery.
The Market Facilitator shall consult the SAB on its prioritisation, providing its rationale, and keep the prioritisation assessment under review at least bi-annually.
The Market Facilitator shall publish its prioritisation, including its assessment against the Prioritisation Criteria, on the Elexon Website and shall inform the Proposer of the outcome of that prioritisation.
The Market Facilitator shall inform each Proposer of the prioritisation of their CP or Issue. Progressions Plans shall be developed in accordance with the priority categorisation determined under paragraph 3.4.2 for each CP or Issue.
The Market Facilitator shall refuse submission of an Issue or Change Proposal where:
The Proposal Form is incomplete or insufficiently clear, including their interest in raising the Change Proposal or Issue;
The subject matter is materially the same as, or could reasonably form part of, an existing open Change Proposal or Issue, or is substantially similar to a Change Proposal or Issue rejected within the last six months;
The Change Proposal or Issue concerns matters outside the scope of the Market Facilitator Arrangements;
The Proposed Solution does not address the issue or defect described; or
The information provided is insubstantial or frivolous.
The following Change Objectives shall guide the Market Facilitator in deciding whether to approve or reject a Proposed Solution or any Alternative Solutions. Before making a decision, the Market Facilitator must assess whether the Proposed Solution or any Alternative Solutions better facilitate these Change Objectives compared to the current baseline.
The Change Objectives shall also be applicable when developing and evaluating Alternative Solutions.
The Change Objectives are to:
Reduce barriers to entry and participation in Flexibility Markets;
Promote efficient, economic, coordinated and transparent operation of Flexibility Markets;
Encourage competition at any stage of the flexibility process, including procurement, operations and reporting;
Facilitate and ensure compliance with relevant legally binding decisions, guidance or legislation, including but not limited to the Electricity Balancing Guideline (EBGL), and related licence conditions of System Operators;
Deliver benefits to both current and future consumers and the environment; and
Enhance efficiency in the implementation and administration of the Market Facilitator Arrangements.
To be recognised as a Proposer, an Interested Person (other than the Authority, the National Energy System Operator (NESO), Distribution Network Operators (DNOs), BSC Parties, or the Market Facilitator) must, when submitting a Change Proposal or Issue, provide a brief statement explaining the nature of their interest in the Market Facilitator Arrangements. The Authority, NESO, DNOs, BSC Parties, and the Market Facilitator shall be deemed to have a legitimate interest in the Market Facilitator Arrangements for the purposes of acting as a Proposer. An Interested Person shall only be eligible to act as a Proposer where they can demonstrate such an interest.
The Proposer shall retain ownership of their Proposed Solution. Accordingly, only the Proposer, or a person formally delegated by them, may determine the final form of that Proposed Solution prior to its submission for decision in the Decision Phase. The implementation of the Proposed Solution shall remain subject to the outcome of the Change Proposal process, the decision of the Market Facilitator, or any subsequent appeal process. The same provisions shall apply to an Alternative Proposer in respect of any Alternative Solution.
Any Interested Person, including the Market Facilitator, shall have the right to raise an Alternative Solution, that must address the issue or defect identified in the Proposal Form.
To formally submit an Alternative Solution, the Interested Person must complete the relevant parts of the Proposal Form.
Each Alternative Solution shall remain owned by the person that formally submitted it, the Alternative Proposer. Accordingly, only the Alternative Proposer, or a person formally delegated by them, may determine the final form of that Alternative Solution prior to its submission for decision to the Market Facilitator.
No more than three Alternative Solutions, in addition to the Proposer’s Proposed Solution, may be raised.
If more than three Alternative Solutions are submitted, the Market Facilitator shall determine which three to progress, taking into account:
an assessment of the costs and benefits, so far as is possible and reasonable;
an assessment of the solution against the Change Objectives; and
the advice of the SAB.
If the Alternative Proposer of an excluded Alternative Solution disagrees with the Market Facilitator’s decision, and the SAB also supported the excluded Alternative Solution, the Alternative Proposer shall have the right to appeal to the Authority.
Appeals on an Alternative Solution shall be made in writing to the Authority in accordance with the timescales, criteria and process set out in the Governance Framework Document following the Market Facilitator notifying its decision, via the Change Mailing List, that it has rejected one or more Alternative Solutions against the recommendation of the SAB.
Alternative Solutions must meet the Validation Criteria and be demonstrably better than the Proposed Solution when assessed against the Change Objectives.
Alternative Solutions shall be assessed and developed in the same way as the Proposed Solution.
Workgroups shall not own Alternative Solutions, although Members of a Workgroup may raise an Alternative Solution in their own right.
The Market Facilitator may establish a Workgroup for a specific Change Proposal or to assess multiple Change Proposals, where the subject matter falls within a particular area of expertise.
Each Workgroup shall normally comprise at least five Workgroup Members (including the Proposer), selected by the Market Facilitator based on relevant expertise and/or experience required for the assessment of a Change Proposal(s).
The Market Facilitator shall provide a Workgroup Chair, responsible for facilitating discussions and ensuring the Workgroup discharges its Terms of Reference, and a Technical Secretary who shall record the key discussions, actions, and decisions of the Workgroup.
The Market Facilitator may limit the number of Workgroup Members in a Workgroup where the necessary expertise is already present and where there is concern that additional members could hinder the timely progression of the Workgroup’s activities.
Workgroups shall operate in accordance with the Workgroup Terms of Reference set by the Market Facilitator. The Market Facilitator may amend the Workgroup Terms of Reference from time to time, and may consult with the SAB. Each Workgroup Terms of Reference shall specify the Change Proposal Terms of Reference that the Workgroup is required to address.
The Proposer may appoint a representative to the Workgroup, who shall hold the Proposer’s responsibility for the duration of the Workgroup’s activities.
Each Workgroup Member shall:
Confirm in writing to the Market Facilitator that their employer has agreed to their participation in meetings and to undertake any additional work outside of meetings; and
Confirm in writing to the Market Facilitator that they shall act impartially and in the interests of the Market Facilitator Arrangements as a whole, and not promote the interests of their employer or of any specific person or class of persons.
The Market Facilitator may add Workgroup Members to the Workgroup as required during its course or invite attendees.
The Market Facilitator may remove or replace any Workgroup Member at any time, where it considers that the Member is unwilling or unable to fulfil their duties under the Workgroup Terms of Reference, or is deliberately or repeatedly disrupting the work of the Workgroup. The Market Facilitator shall notify the affected Member, stating its reasons.
Workgroup Members shall not be remunerated for their participation but may claim reasonable expenses incurred in the course of discharging their duties.
The Market Facilitator shall provide appropriate facilities, people, and support to each Workgroup to enable it to function effectively. It is expected that most Workgroup meetings shall be held virtually and shall only meet in person where necessary.
The Market Facilitator shall ensure that non-confidential details of the Workgroup Members, Workgroup Terms of Reference, Change Proposal Terms of Reference, and the timetable of meetings are published on the Elexon Website as soon as reasonably practicable.
The Market Facilitator shall set the Implementation Date for a Change Proposal in line with, but not limited to, the following considerations:
the Delivery Plan;
the complexity and urgency of the Change Proposal;
evidence gathered during the Assess Phase, including the information collected from any IA, Assessment Consultation, and advise provide by the SAB or a Workgroup, where applicable;
the impact of the Change Proposal on arrangements outside of the Market Facilitator Rules, such as System Operator licence conditions and the Electricity Balancing Guideline; and
the need to allow sufficient time, as set out by the Authority in the Governance Framework Document, for any Interested Person to appeal the Market Facilitator’s Decision before implementation.
For any Change Proposals impacting NESO’s licence conditions and/or any other legislative or licence obligations, the Market Facilitator shall work with NESO in accordance with the procedure set out in the Ways of Working Document to progress such Changes. This may include collaborating on assessing impacts, undertaking industry consultations, and setting the Implementation Date. The purpose of this coordination is to ensure alignment between any change processes that NESO is required to run and this Change Procedure, thereby facilitating the effective progression and implementation of such Change Proposals.
The Market Facilitator shall set a single Implementation Date for all System Operators in accordance with paragraph 3.10, and shall consult on that date as part of the Assessment Consultation. Where a System Operator considers that it may not be able to meet the Implementation Date, it shall seek a Derogation in accordance with paragraph 7.1.3, and shall inform the Market Facilitator of any such considerations as part of the Impact Assessment and/or the Assessment Consultation.
The Market Facilitator shall establish and maintain a register of all its current and past Change Proposals and Issues, known as the Change Register.
The Market Facilitator shall maintain and publish the Change Register on the Elexon Website. The Change Register shall be updated at least weekly.
The Change Register shall contain at least the following fields:
details of each Change Proposal and Issue, including the title and unique identifier, name of the Proposer, the date the Change Proposal or Issue was raised, and a brief description of the Change Proposal or Issue (defect and solution);
a brief summary of the latest status of the Change Proposal or Issue;
prioritisation scoring;
prioritisation category and rationale;
whether the Change Proposal was treated as urgent;
related Change Proposals or Issues (e.g. where a Change Proposal has originated from a previous Issue);
the Progression Route for the Change Proposal;
Progression Plan details for the Change Proposal or Issue;
the Published Date for the Market Facilitator Rules to be changed as part of the CP; and
the decision (approved or rejected) for a Change Proposal.
The Market Facilitator shall provide, free of charge, advice and assistance to any Interested Person, consistent with its role of supporting the progression of Change Proposals or Issues. This shall include:
assistance with the development of Issues and Change Proposals, and/or exploring other potential remedies to address matters raised;
explaining the operation and effect of this Change Management Procedure; and
acting as a ‘critical friend’ by providing constructive challenge, guidance, and support throughout the change process. This includes helping to frame issue statements, develop robust proposals, and ensure that submissions are clear, evidence-based, and capable of being effectively assessed.
The Market Facilitator shall determine the most appropriate Progression Route for gathering the information and evidence needed to support the decision on the CP and to develop the relevant amendments to the Market Facilitator Rules.
There are five possible Progression Routes for a Change Proposal:
Assessment by the Market Facilitator (without a Workgroup);
Assessment by a Workgroup;
Direct to Assessment Consultation;
Housekeeping; or
Urgent.
The Market Facilitator, in consultation with the SAB, Proposer and any Alternative Proposers, shall set out in the Progression Plan the key steps required to complete the assessment of the Change Proposal, so that it may proceed to the Assessment Consultation.
Change Proposals requiring assessment by the Market Facilitator, without a Workgroup, are those where the Proposed Solution or any Alternative Solutions are not yet fully developed at the time of submission, but where the Proposer, any Alternative Proposers, or the Market Facilitator does not require additional support to further develop or assess them.
Under this Progression Route, the Market Facilitator shall work directly with the Proposer and any Alternative Proposers so that it is ready for Assessment Consultation. Following completion of the Assessment Consultation, the Market Facilitator shall finalise its assessment and prepare the draft Assessment Report for presentation to the SAB in accordance with paragraph 6.4.2.
Change Proposals requiring assessment by a Workgroup are those where the Proposed Solution or any Alternative Solutions are either not yet developed or do not adequately address the issue or defect identified in the Proposal Form at the time of submission, and where the Proposer, any Alternative Proposers, and the Market Facilitator agree that further assessment by a Workgroup is required to develop and assess the Proposed Solution or any Alternative Solutions, and where such information cannot reasonably be obtained through the Assessment Consultation or an IA.
The purpose of a Workgroup Assessment is to support the Proposer of the Proposed Solution and any Alternative Proposer’s of any Alternative Solutions to develop the optimal solution for the issues identified in the Proposal Form. The Workgroup shall support the development and assessment of the Change Proposal by:
Discharging its Workgroup Terms of Reference;
Providing its expertise and advice on the Change Proposal;
Supporting Market Facilitator in drafting and reviewing changes to the Market Facilitator Rules (the legal text) for the Proposed Solution or any Alternative Solutions;
Providing its views on whether the Proposed Solution or any Alternative Solutions should be approved or rejected as assessed against the Change Objectives;
Providing its views on implementation lead times; and
Providing its views on whether any changes are required following the Assessment Consultation.
Once the Workgroup has finished developing and assessing the Proposed Solution and any Alternative Solutions, the Market Facilitator shall issue the Assessment Consultation. The Market Facilitator shall include the key points and outcomes from Workgroup discussion into the Assessment Consultation.
Following the Assessment Consultation, the Market Facilitator shall gather Workgroup views on the Assessment Consultation responses and whether the Workgroup believes any changes should be made to the Proposed Solution or any Alternative Solutions, together with its reasons and whether its views on the Change Proposal have changed.
Upon completion of the Workgroup’s assessment, the Market Facilitator shall promptly prepare the draft Assessment Report to gather Stakeholder Advisory Board’s feedback and views on the Change Proposal in accordance with paragraph 6.4.
The Market Facilitator may submit a Change Proposal directly to Assessment Consultation where the Proposed Solution is fully developed at the time of submission, including the proposed changes to the Market Facilitator Rules.
Where the Market Facilitator progresses a Change Proposal directly to the Assessment Consultation, it shall do so by publishing the Assessment Consultation in accordance with paragraph 6.2.
A Housekeeping Change Proposal is a Change Proposal that meets the definition set out in paragraph 4.5.3 and shall proceed from the Raise Phase directly to the Decision Phase.
Following notification of the Market Facilitator’s decision to approve a Housekeeping Change Proposal, a 10 Working Day objection window shall open, during which any Interested Person may object to the treatment of the Change Proposal as a Housekeeping Change Proposal. Any objection must be accompanied by reasons. Where the Market Facilitator receives reasonable and substantiated objections, the Change Proposal shall proceed to the Assess Phase, following re-evaluation of the Initial Assessment by the Market Facilitator in accordance with 5.3.
A Housekeeping Change Proposal shall:
Address the correction of manifest or minor errors, inconsistencies, typographical errors (including, without limitation, punctuation, spelling, or incorrect capitalisation), incorrect cross-referencing, or removal of redundant text within the Market Facilitator Rules; and
not have any material impact on the Market Facilitator Rules or on stakeholders, such that no stakeholder is required to act differently as a result of the change.
Any Interested Person may raise a Housekeeping Change Proposal. However, it is expected that the Market Facilitator will normally raise Housekeeping Change Proposals as part of its responsibility to maintain the Market Facilitator Rules.
The Market Facilitator may refuse to accept a Change Proposal as a Housekeeping Change Proposal where it determines that the criteria in 4.5.3 have not been met. In such circumstances, it shall notify the Proposer in writing, setting out reasons for refusal and, where possible, offering assistance to address the issues so that the Change Proposal may be resubmitted.
A Proposer may request that a Change Proposal be treated as urgent at the time of submission to the Market Facilitator or at any time before the publication of the Assessment Report.
The Market Facilitator shall determine whether a Change Proposal is to be treated as an Urgent Change Proposal. Each request shall be considered on its merits on a case-by-case basis, with reference to the Urgency Criteria published by the Authority.
Before determining urgency, the Market Facilitator shall seek the views of the SAB on whether the Change Proposal should be treated as urgent. The SAB Chair may determine how best to gather such feedback in accordance with the SAB Terms of Reference, including holding an ad-hoc meeting or gathering feedback via email.
Where the Market Facilitator determines that a Change Proposal meets the Urgency Criteria, it shall adhere to the standard Change Management Procedure so far as reasonably practicable, but may shorten or omit activities, consultations, IAs, and other steps as it deems necessary in order to meet the urgency.
Issues are out of scope of the urgency process. Where a matter is considered urgent, a Change Proposal must be raised.
The Market Facilitator shall notify via the Change Mailing List and the SAB, of its decision regarding an Urgent Change Proposals, including the justification by reference to the Urgency Criteria.
The purpose of this phase is to assess whether the Change Proposal meets the Validation Criteria, to prioritise it in accordance with paragraph 3.4 (where necessary), and to determine its Progression Route and Progression Plan in consultation with the SAB, setting these out in the Initial Written Assessment Report.
The Proposal Form shall require the Proposer to provide certain information, including but not limited to the items listed below, which the Market Facilitator shall validate in accordance with the Validation Criteria in 3.5:
a description, in reasonable detail, of the proposed change to the Market Facilitator Rules, including the issue or defect to address and the Proposed Solution/high level description of Solution, together with the expected benefits and desired outcomes;
the Proposer’s interest in the Market Facilitator Arrangements, where applicable in accordance with 3.7.1.
an indication of the parts of the Market Facilitator Rules that would require amendment, and, where possible, the potential impacts of those Changes on System Operators and other stakeholders;
the reasons why the Proposer believes that the Change Proposal would better facilitate achievement of the Change Objectives;
the Proposer’s assessment of the Prioritisation Criteria, including the supporting rationale; and
where relevant, an indication of the wider impacts of the proposed Change Proposal, including (but not limited to) impacts on other Industry Codes, the Electricity Balancing Guideline, System Operator licence conditions or any other legal or legislative obligations on System Operators or stakeholders.
The Market Facilitator shall work with the Proposer to develop the Progression Plan and the most appropriate Progression Route.
Where the Market Facilitator accepts the submission of a Change Proposal, it shall:
assign a unique identifier to that Change Proposal; and
record the Change Proposal on the Elexon Website and in the Change Register, and notify via the Market Facilitator Mailing List of its Progression Route and Progression Plan, including any prioritisation applied in accordance with paragraph 3.4.
Acceptance and publication under this paragraph shall mark the point at which the Change Proposal is formally raised under this Procedure.
Once a Change Proposal has been formally raised in accordance with paragraph 5.2.3, the issue and defect identified within it shall be treated as fixed and may not be altered.
The Market Facilitator shall begin executing the Progression Plan after it has determined and published the Progression Plan on the Elexon Website.
The Market Facilitator shall reject the submission of a Change Proposal where it fails under one or more of the Validation Criteria set out in paragraph 3.5 above. If a Change Proposal is rejected at this stage, the Market Facilitator shall notify the SAB and the Proposer, providing the rationale for its decision. The Market Facilitator shall work with the Proposer to address the reasons for rejection, where appropriate.
In setting the Progression Plan, the Market Facilitator shall take into account the complexity, urgency, and nature of the Change Proposal and:
indicate whether an IA is required in accordance with 3.9 and, if so, the proposed duration; and
indicate how long it intends to issue the Assessment Consultation for.
The Proposer, or Alternative Proposer, shall have the right to request that the Market Facilitator act as their representative at any stage of the entire Change Process.
The Market Facilitator may refuse to act as the representative of a Proposer, or Alternative Proposer, including (without limitation) where it does not consider that the Change Proposal would facilitate delivery of the Delivery Plan or achievement of the Change Objectives.
For each Change Proposal accepted by the Market Facilitator in accordance with paragraph 5.2.3, an Initial Assessment shall be undertaken in accordance with the requirements of this paragraph 5.3.
The initial assessment by the Market Facilitator shall include an initial determination of:
the Progression Route that the Change Proposal will follow;
the Progression Plan that the Change Proposal will follow, which shall include the expected period of time the Assessment Consultation and any IA will be issued for;
whether a mandatory IA for System Operators will be required, and if so, the reasons for requiring it; and
the Change Proposals Terms of Reference.
The Market Facilitator shall prepare an Initial Written Assessment Report capturing its initial assessment of the CP.
At the next available SAB meeting, the Market Facilitator shall seek the SAB’s views on its initial assessment, as detailed in the Initial Written Assessment Report and any prioritisation applied, for feedback and advice. The Market Facilitator shall invite the Proposer to present their Change Proposal at that SAB meeting. Any feedback received may result in amendments to the prioritisation, the Progression Plan, or the Progression Route. The SAB Chair may determine how best to gather such feedback in accordance with the SAB Terms of Reference.
The Market Facilitator shall publish the Initial Written Assessment Report on the Elexon Website.
The Market Facilitator may amend the Progression Plan and Progression Route as circumstances change, for example, for example, in response to advice from the SAB or other material developments, and shall provide justification for any such amendments.
The purpose of this phase is to finalise the Proposed Solution and any Alternative Solutions so that their costs and benefits can be evaluated in sufficient detail to enable an informed decision on whether the change should be approved or rejected, as judged against the Change Objectives.
The outcome of the Assess Phase shall be an Assessment Report, which shall inform the Market Facilitator’s decision as to whether a Proposed Solution or any Alternative Solution is to be approved. The Assessment Report shall include, to the extent applicable:
Description and solutions – a description of the issue(s) the CP seeks to address, together with the Proposed Solution and any Alternative Solutions developed to resolve those issue(s), including how each option would better facilitate achievement of the Change Objectives.
Draft legal text – the draft legal text (or procedural amendments) to the Market Facilitator Rules required to give effect to the Proposed Solution or any Alternative Solutions.
Impacts, costs, and timelines – the impacts of the Proposed Solution and any Alternative Solutions on the Market Facilitator Rules and affected parties, together with the estimated costs of implementation and ongoing operation, and the time required for design and delivery. This shall include the proposed Publish Date and Implementation Date for the Market Facilitator Rules, and any associated Implementation Monitoring requirements.
Legal and regulatory impacts – whether, and to what extent, the Change Proposal would require amendment to, or have any impact on, any relevant legal, regulatory, or licence-based arrangements, including (but not limited to) the Electricity Balancing Guideline (EBGL).
Impact Assessments (IA) – the outcome of any IA(s) undertaken to support the development and assessment of the Proposed Solution and any Alternative Solutions.
Specialist analysis – details of any assessment or analysis carried out by an external specialist or consultant, together with the rationale for commissioning such work.
Stakeholder views – a summary of the views submitted by any workgroup, respondents to consultation, including views on the Change Objectives, and how these views have been taken into account and any resulting amendments to the Proposed Solution or any Alternative Solutions.
SAB views – the views and advice of the Stakeholder Advisory Board, including its recommendation on whether the Change Proposal should be approved or rejected, as assessed against the Change Objectives.
Market Facilitator views – the Market Facilitator’s rationale and minded-to position on whether the Proposed or any Alternative Solutions should be approved or rejected, as presented to the SAB, including, where relevant, any reasons for deviating from the advice or recommendations of the Stakeholder Advisory Board.
Any other matters – any other matters which the Market Facilitator reasonably considers relevant to the assessment of the Change Proposal.
At any stage during the Assess Phase, the Market Facilitator may prepare an interim report setting out its provisional findings in respect of the matters required for the Assessment Report. The Market Facilitator may present such a report to the SAB to seek feedback that may aid the further development and assessment of the Change Proposal via the appropriate Progression Route.
The Market Facilitator may commission additional analysis, engage external specialists, or procure any other services or assistance it considers necessary to support the development or proper assessment of a Change Proposal. Where the cost of such services is likely to exceed £300,000, the Market Facilitator shall seek the views of the SAB on whether to proceed, and in giving its views the SAB may consult with the Authority.
The Market Facilitator shall conduct an Impact Assessment (IA) to gather evidence and information to support its decision-making during the Assessment Phase. The IA shall collect information on, among other things, the impacts, costs, and benefits associated with implementing and operating the Proposed Solution and any Alternative Solutions. The scope and depth of the IA shall be determined by the Market Facilitator, having regard to the magnitude, complexity, and potential impacts of the Change Proposal, such that more significant Changes are likely to require a more comprehensive IA.
During the IA process, the Market Facilitator shall issue a public invitation via the Change Mailing List, and published on the Elexon website, to invite information on the potential impact of a proposed Change Proposal on their organisations, covering both implementation activities and ongoing operations. Participation shall be voluntary, except where the Market Facilitator requires System Operators to participate. Where System Operators are required to provide an IA, the Market Facilitator shall justify the requirement.
The Market Facilitator shall determine whether to issue an IA as part of the Assessment Consultation or as a separate exercise.
The information provided in an IA shall be used in evaluating a Change Proposal, including its assessment against the Change Objectives, to inform the decision on whether to approve or reject the Change Proposal. Non-confidential versions of the IA shall be published by the Market Facilitator. Anonymised summaries of confidential responses may also be published, provided that such summaries do not enable the responder to be identified. Confidential responses shall be provided to the Authority to support any appeal, or otherwise upon request.
The IA may request the following information (non-exhaustive list) on the impact of implementing and then operating the Proposed Solution or any Alternative Solutions from stakeholders:
The impacts on their organisation;
The estimated costs;
The expected benefits or disbenefits;
The time required to implement;
Any other impacts that should be brought to the Market Facilitator’s attention;
Any differences in the above between Alternative Solutions and implementation options; and
Any suggestions for better solution(s) than those proposed, including rationale.
The NESO shall inform the Market Facilitator, via any Impact Assessment, where it considers that a Change Proposal may, or will, require it to undertake additional consultation or design activities to implement the Change Proposal, including an estimate of the time required to do so.
A Change Proposal shall be issued for Assessment Consultation once the Market Facilitator considers it to be sufficiently developed, including the preparation of draft legal text and completion of all other information required under paragraph 6.1.2, except for those elements intended to be explored through the consultation itself, for the purpose of seeking views from Interested Persons and stakeholders on the Proposed Solution and any Alternative Solutions, including their impacts, costs, benefits, and implementation considerations.
Each Change Proposal (except Housekeeping Change Proposals) shall be issued for an Assessment Consultation that seeks views on the matters set out in 6.1.2 The consultation period shall be determined by the Market Facilitator, having regard to the complexity of the Change Proposal.
The Market Facilitator may determine that it is necessary to issue Change Proposals for more than one IA or Assessment Consultation, for example, where a Proposed Solution or any Alternative Solutions have materially changed.
An IA may form part of the Assessment Consultation or may be issued in advance of it. The IA is intended to inform the development of solution options, Implementation Dates, and views on whether the Change Proposal should be approved or rejected.
Where the Market Facilitator considers that a potential change to the Flexibility Market Rules may impact the National Energy System Operator’s other legal obligations, it may invite the Authority, as part of the Assessment Consultation or separately, to share any provisional opinion or guidance. Any provisional view provided shall only be shared with those whom the Authority stipulates.
Following the closure of the Assessment Consultation, the Market Facilitator shall publish all non-confidential responses within five Working Days. Confidential responses shall not be published; however, anonymised summaries of confidential responses may be published, provided that such summaries do not enable the responder to be identified. Confidential responses shall be provided to the Authority to support any appeal, or otherwise upon request.
Following completion of the Assessment Consultation, and subject to the need for any further assessment (including by a Workgroup), the Market Facilitator shall produce a draft version of the Assessment Report.
The draft Assessment Report shall be presented to the SAB for its views on the Change Proposal and shall be published on the Elexon Website in advance of the SAB meeting.
Following consideration of the SAB’s views on the draft Assessment Report, the Market Facilitator shall determine whether to submit the Change Proposal for further assessment (in which case it shall revise the Progression Plan and Route) or to progress the Change Proposal to the Decision Phase.
Where the Market Facilitator decides to progress the CP to the Decision Phase, it shall publish the Assessment Report, incorporating the SAB’s views, on the Elexon Website within five Working Days of the receiving the SAB views in accordance with 6.4.2.
The purpose of the Decision Phase is for the Market Facilitator to determine whether a Proposed Solution or any Alternative Solution shall be approved and implemented or rejected and closed.
Subject to paragraph 7.1.3, the Market Facilitator shall decide whether to approve or reject a Proposed Solution or any Alternative Solution, and, where a valid Derogation request has been submitted in accordance with paragraph 8.3, may also decide whether to approve any associated Derogations, based on the information set out in the Assessment Report.
Where a Proposed Solution or any Alternative Solution is approved and requires further development or consultation by the NESO in order to implement it, the Market Facilitator shall, where possible, reflect this in the Implementation Date following engagement with NESO. Where it is not possible to accommodate this within the Implementation Date, the Market Facilitator may agree an appropriate Derogation for NESO as part of the Market Facilitator Decision.
The Market Facilitator shall publish its decision in a Decision Report that must contain:
The Market Facilitator’s decision on whether or not the Proposed Solution or any Alternative Solution should be implemented, as justified against the Change Objectives;
The rationale for deviating from the SAB’s recommendation on whether to approve the Proposed Solution or any Alternative Solution, where applicable;
The Publish Date of any Proposed Solution or Alterative Solution; and
The Implementation Date of any Proposed Solution or Alternative Solution, taking into account any impacts identified in the Assessment Report, including on the Electricity Balancing Guideline (EBGL) and other regulatory dependencies and constraints.
The Decision Report shall be published on the Elexon Website and, on the same day, notified via the Change Mailing List.
The Market Facilitator shall update the Change Register and inform the Proposer and any Alternative Proposers of its decision once it is published.
Interested Persons shall have the right to appeal the Market Facilitator’s decision made in accordance with 7.1.2, to the Authority, in accordance with the timescales, process and criteria set out in the Governance Framework Document. The assessment criteria and the possible resolution actions are determined and maintained by the Authority within its Governance Framework Document.
The Market Facilitator may, at any time prior to publishing the Decision Report, return a Change Proposal to the Assessment Phase where it considers that further analysis, consultation, or development is required in order to reach an informed Decision. In doing so, the Market Facilitator shall set out its reasons for returning the Change Proposal to the Assessment Phase in a revised Assessment Report, and may request additional Impact Assessments, convene further Workgroup meetings, or undertake other actions considered necessary to complete the Assessment Phase.
The purpose of this phase is for the approved solution to be implemented in accordance with the approved Implementation Date as detailed in the Decision Report.
The Market Facilitator and System Operators, as applicable, shall take appropriate steps to give full and timely effect to an approved solution in accordance with the Decision Report and the Implementation Date or any approved Derogation.
The Market Facilitator shall provide a report to the SAB where it appears, in the Market Facilitator’s opinion, that significant problems may arise, or have arisen, in the implementation of an approved solution.
Each System Operator shall notify the Market Facilitator in writing if it believes it will be unable to meet the Implementation Date, or any date specified under an approved Derogation, in accordance with paragraph 8.3 and the Implementation Monitoring Procedure.
The NESO shall undertake the necessary steps under the Electricity Balancing Guideline (EBGL), and any other applicable regulatory processes, to implement an approved Proposed Solution or Alternative Solution, and shall keep the Market Facilitator informed of its progress in accordance with the Implementation Monitoring Procedure.
Once a Change Proposal has been approved, the Implementation Date may only be amended by:
raising a new Change Proposal to amend the Implementation Date; or
direction of the Authority pursuant to an appeal under paragraph 7.1.7.
If an Implementation Date is amended after a decision has been made, the Market Facilitator shall notify the Change Mailing List and inform the Stakeholder Advisory Board (SAB).
For the Flexibility Market Rules, Derogations may, where permitted within the Flexibility Market Rules and subject to paragraph 8.3, be approved by the Market Facilitator.
Where permitted within the Flexibility Market Rules, the Market Facilitator may grant a Derogation from the application of a specific Flexibility Market Rule, in whole or in part, subject to this paragraph 8.3.
A Derogation may only be granted where the Market Facilitator is satisfied that:
the Derogation would not have a material adverse impact on the operation of the Market Facilitator Arrangements or the achievement of the Change Objectives;
the applicant has demonstrated that compliance with the relevant Flexibility Market Rule is impractical, disproportionate, or unnecessary in the circumstances; and
the Derogation would not unfairly disadvantage or discriminate against any other party.
A Derogation request may be submitted in relation to a Flexibility Market Rule that is either in force or proposed but not yet approved or published. Where the request relates to a proposed Flexibility Market Rule, the Market Facilitator may decide whether to approve or reject the Derogation as part of its decision under paragraph 7.1.2. In all other cases, the Market Facilitator shall determine the Derogation in accordance with this paragraph 8.3 after the relevant Rule has been approved and published.
A Flexibility Market Rule may, where expressly stated, allow for self-derogation by a System Operator. Where such a provision applies, paragraphs 8.3.7 to 8.3.9 of this Procedure shall not apply to that Derogation.
Where a System Operator exercises a self-derogation, it shall notify the Market Facilitator and provide the information specified in paragraph 8.3.6. The Market Facilitator shall record all such self-derogations in the Derogation Register. Where the Market Facilitator considers that a self-derogation does not meet the criteria in 8.3.2, it may reject the self-derogation or require its amendment, following engagement with the relevant System Operator and, where appropriate, consultation with the Stakeholder Advisory Board.
Any request for a Derogation, including a self-derogation exercised by a System Operator, shall include sufficient information to enable the Market Facilitator to assess the request against the criteria in paragraph 8.3.2. As a minimum, the information provided shall include:
the Flexibility Market Rules or paragraphs or sections from which Derogation is sought;
the reasons for seeking the Derogation;
the duration for which the Derogation is requested, including, where applicable the System Operator’s plan to return to full compliance; and
any supporting evidence demonstrating how the criteria in paragraph 8.3.2 are satisfied.
The Market Facilitator may consult with the Stakeholder Advisory Board, System Operators, or other stakeholders as it considers appropriate prior to making a decision on the Derogation Application.
The Market Facilitator shall determine whether to grant, grant subject to conditions, or refuse the Derogation and shall notify the applicant in writing of its decision, including reasons.
Where a Derogation is granted, the Market Facilitator shall specify:
the Flexibility Market Rules or provisions or sections from to which it applies;
the start and end date of the Derogation;
any conditions or reporting requirements; and
the circumstances in which the Derogation may be reviewed or revoked.
The Market Facilitator shall maintain and publish on the Elexon Website a Derogation Register of all Derogations, including self-derogations, detailing, without limitation, the information submitted in 8.3.9.
The Market Facilitator may review, amend, or revoke any Derogation where the circumstances that justified it no longer apply, or where continued application would have an adverse impact on the Market Facilitator Arrangements. Before making any such decision, the Market Facilitator may seek the views of the Stakeholder Advisory Board (SAB) and shall take those views into account when determining its decision.
An Issue may be raised by any Interested Person or by the Market Facilitator where a defect, problem, or potential improvement is identified in the Market Facilitator Rules, but the appropriate resolution or next steps are uncertain.
The Issue must meet the Validation Criteria in 3.5, and upon accepting the submission of an Issue the Market Facilitator shall assign a unique identifier to the Issue and update the Change Register accordingly.
The Market Facilitator shall work with the Proposer to determine the best way to address the Issue, which can include the Market Facilitator’s assessment of the Issue or convening a group of relevant experts to advise on the Issue, known as an Issue Group.
If an Issue Group is required, the Market Facilitator shall convene the group and invite members to participate, in line with the Issue Terms of Reference set by the Market Facilitator.
The Market Facilitator may consult the SAB on the Issue and on its terms of reference.
Once the Issue Terms of Reference have been addressed, the Market Facilitator shall prepare an Issue Report and submit it to the SAB for feedback and advice. The SAB Chair shall determine how best to gather such feedback in accordance with the SAB Terms of Reference.
The recommendations in an Issue Report shall be non-binding.
The Market Facilitator shall publish the Issue Report on the Elexon Website and update the Change Register to reflect the Issue’s status.
The Proposer of an Issue may withdraw their Issue at any time before the publication of the Issue Report by notifying the Market Facilitator and providing its reasons in writing.
Upon receiving such notice, the Market Facilitator shall, as soon as reasonably practicable, notify the Change Mailing List that the Issue has been withdrawn. The date on which this notification is sent shall mark the opening of a 15 Working Day adoption window. In that notification, the Market Facilitator shall expressly invite Interested Persons to adopt the Issue.
Any adoption shall be on a first-come, first-served basis as notified by the Market Facilitator.
The Market Facilitator may itself choose to adopt the Issue.
The Market Facilitator and System Operators shall comply with the Market Facilitator Rules in accordance with the Governance Framework Document.
Guidance, which shall not be legally binding or require compliance under paragraph 10.1.1, may be included within the Market Facilitator Rules, provided that it is clearly identified as guidance, or published in separate documents, to assist in understanding the Market Facilitator Rules and the role of the Market Facilitator.
Guidance, whether included within the Market Facilitator Rules or published in separate guidance documents, and any document metadata may be updated by the Market Facilitator from time to time and shall not require a Change Proposal to add, amend, or remove it. The Market Facilitator shall, however, notify the Change Mailing List of any material updates and adhere to the version control requirements set out in paragraph 10.3.
The Market Facilitator shall maintain and publish a record of all Market Facilitator Rules that are subject to the change control processes set out in this document. This record shall be referred to as the Baseline Statement.
The Market Facilitator shall update the Baseline Statement each time a new version of the Market Facilitator Rules is published, to reflect the version and Publish Date of those Rules.
As a minimum, the Baseline Statement shall contain:
The title and unique identifier of each document that is in force, and of any obsolete documents;
The latest version of each document;
The Publish Date of that version; and
The Change Proposal or guidance update that resulted in that version of the document.
The Market Facilitator shall establish and maintain a document management system to control and record all versions of the Market Facilitator Rules.
All Market Facilitator Rules shall be subject to version control, with the initial version designated as 1.0, and all subsequent versions adhering to the following principles:
Updated to the next major version (e.g. v1.0 to v2.0) where the Market Facilitator Rules are being updated; or
Updated to the next minor version (e.g. v1.1 to v1.2) where the update does not impact the legally binding text, including updates to guidance, metadata, document properties or other supporting information.
The Market Facilitator shall create and maintain standardised:
Document templates.
A style guide for documents.
A style guide for digital publication.
A metadata catalogue.
There are two types of Market Facilitator artefacts:
Market Facilitator Governance Documents; and
Flexibility Market Rules.
A Change Proposal must be progressed and approved to add or remove a Market Facilitator Governance Document or a Flexibility Market Rule.
A master list of definitions can be found in the Market Facilitator Glossary.
The following definitions are specific to this Governance Document. These are supplemented by the definitions in the Market Facilitator Glossary. If there is an inconsistency between definitions, the definition in this document shall prevail.
FGD: Change Management Procedure - Amendment record
Annex 1: Associated meta-data
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1.1
The Publish Date and the Implementation Date for this Governance Document are as follows:
Term
Date
Publish Date
12 December 2025
Implementation Date
12 December 2025
The Publish Date and Implementation Date form part of the legal baseline for this Governance Document and shall be taken as the effective dates for the purposes of interpretation and version control.
In the event of any discrepancy between the dates stated above and those referenced in any accompanying publication, metadata, or communication, the dates recorded in this Governance Document shall prevail.
For the avoidance of doubt, the Implementation Date represents the date on which the obligations, rights, and procedures set out in this Governance Document take operational effect.