Ofgem decides on transforming the Connections Experience
Background
On 25 September 2026, Ofgem published Transforming the Connections Experience (“Decision”) {1}, setting out decisions and next steps arising from themes 2–5 and 7 of its connections end-to-end review. The Decision builds on consultations published in November 2024 and December 2025 and extensive stakeholder engagement throughout 2026. It applies to larger connections across distribution, transmission and NESO licences. {2}
Stakeholder feedback identified the following concerns: the connections process is difficult to navigate, service standards are inconsistent, connection offers lack clarity, customers have limited visibility of progress, and insufficient accountability for delays. The Decision sits alongside the separately published Transforming Connections Data document (formerly theme 1) {3} , as well as ongoing work on Demand Connections Reform, strategic planning and the ED3 price control. Theme 6 (smaller connections) is being taken forward on a separate track. While the primary focus is on DNOs, transmission owners (“TOs”) and NESO, Ofgem notes that further policy development is required for IDNOs and ICPs, and a separate IDNO regime review with a call for input will follow.
Minimum Requirements Across the Connections Journey
A central element of the Decision is the introduction of minimum requirements at each stage of the connections journey, delivered through a combination of prescriptive and principles-based licence conditions, supplemented by Ofgem guidance.
Pre-application and Application
Ofgem will introduce a prescriptive licence condition requiring network companies to acknowledge and respond to pre-application enquiries within a fixed timeframe (to be determined with industry). A single pre-application engagement meeting will be available on request within a fixed timeframe, though Ofgem will not mandate separate connection surgery requirements. Readiness criteria for applicants are to be explored.
At the application stage, standardised application checklists setting out mandatory, conditional and optional information fields will be introduced via guidance, though no single mandated template will be imposed. A principles-based licence condition will require network companies to support informed, right-first-time applications. A prescriptive licence condition will require a designated point(s) of contact from the point a complete application is accepted throughout the connections journey.
Connection Offers
A prescriptive licence condition will require a minimum set of “core” offer content for all larger connections, comprising: connection date, point of connection, capacity, design, voltage, charges, acceptance period and expiry date, technical requirements, customer obligations and milestones, and terms and conditions. For defined categories of larger projects, “enhanced minimum content” will additionally be required, including: dependencies and assumptions; cost breakdowns; milestones; slippage triggers; the split between contestable and non-contestable works; firm versus non-firm connection arrangements and any curtailment provisions; DNO/TO/NESO interfaces; and a named contact. Guidance will address non-standard projects.
Principles-based licence conditions will require transmission–distribution coordination and ensure that offers are clear, transparent and factually correct, without purporting to eliminate genuine uncertainty. For transmission connections, NESO will be responsible for offer content, with NESO–TO arrangements to be developed.
Post-offer, Acceptance and Post-acceptance
Complexity-tiered response windows will be introduced for clarificatory questions and error correction, together with a transparent change-control process for material changes. The existing CUSC three-month acceptance period will not be altered. A principles-based licence condition will require consistent acceptance procedures, with guidance on post-acceptance communications. Counter-signature expectations are to be developed, though no universal timeframe is being imposed.
Post-acceptance, network operators will be required to notify customers of material changes within a fixed timeframe and to maintain version control and change logs. Defined processes and timelines will apply to agreement-to-vary and restated-document change requests. An initial response to formal queries must be provided within a fixed timeframe. Proactive progress updates will be triggered by milestones, delays, material changes, unresolved queries, and meetings on request.
Delivery and Monitoring
A kick-off meeting will be available on request within a flexible timeframe. Network operators must maintain a detailed design, delivery and commissioning programme, make outage planning arrangements, and provide transparency on survey works (though no prescribed timeframe for surveys is imposed).
Monitoring will be delivered via the ED3 Larger Connections Customer Satisfaction Survey (“LCCSS”) and Connections Annual Reports (“CARs”). Notably, a reward element will be added to the existing penalty-only LCCSS incentive. Treatment of the target percentage of works completed by the estimated completion date is left to code modifications.
Ambitious Connection Offers
Ofgem will introduce a new principles-based obligation requiring network operators to provide ambitious yet achievable connection offers. The Decision adopts a working definition: “An ambitious offer is one that reflects the earliest realistically deliverable outcome, taking account of reasonable customer expectations.” This is expressly not the earliest technically conceivable date; Ofgem recognises that, if delivery accountability obligations are strengthened, overly aggressive targets could incentivise conservative dating. The risk of conservative dates is addressed through the ambition obligation itself.
The Decision does not progress the previously considered energisation window as a separate mechanism. Ofgem considers that the risk of a backstop date being treated as the effective delivery date renders it unnecessary. Target and backstop dates remain good practice.
A standardised voluntary opt-in mechanism will be developed for customers seeking earlier or alternative connection opportunities, including flexible, non-firm or phased connections. Detailed design covering eligibility, allocation, queue interaction, safeguards, and DNO/TO/NESO responsibilities will be subject to further consultation.
Timely and Reliable Connections
Strengthened Guaranteed Standards of Performance
Ofgem regards the current Guaranteed Standards of Performance (“GSoPs”) as providing “token payments”, with values dating from the 2015 Regulations (inflation-updated in 2023). The Decision confirms that DNO GSoPs will be strengthened by raising all automated payment values irrespective of project value, with greater weight on delivery milestones of commencement, completion and energisation. Payments will increase with the length of delay, up to a cap. Ofgem will review whether the basis for GSoP obligations should shift from voltage to capacity, and will consider additional milestones and exemptions for matters outside DNO control. Project-value models have been rejected. GSoPs will not be extended to TOs.
Delay Liquidated Damages for Transmission
In transmission, delay liquidated damages exist under CUSC construction agreements and STC Schedule 9 but are predominantly set at £0.00 per day. Ofgem is minded to strengthen these arrangements with greater-than-zero values. Options under consideration include: a minimum value above zero (for example, a reasonable estimate of customer impacts, approximately 0.5% of project value, or a percentage of losses per day); and/or requiring NESO and TOs to explain delay damage arrangements before execution of a construction agreement. Ofgem cites international precedents including ISO New England (approximately 0.5% of project value) and North Rhine-Westphalia (€140,000 award).
Issues identified for further consideration include the distinction between controllable and non-controllable delays, caps on delay damage exposure, the role of NESO as the contracting party, and the avoidance of double penalisation. Ofgem indicates that a request for information may follow, and that implementation may proceed via System Operator – Transmission Owner Code (STC) modifications or other routes. A review of current delay damage arrangements is expected within three months. Delay damages will not be extended to DNOs.
Performance Visibility
Ofgem will introduce a performance visibility framework based on contextual scorecards and dashboards rather than simple league tables. This will be delivered through licence-based reporting obligations with accompanying guidance, drawing on existing data gathered through ED2, ED3 and RIIO-3 compliance reporting.
Dispute Resolution
Ofgem will conduct a full review of its determination guidance (last published in 2017) in 2027, to be the subject of a separate consultation. In the meantime, the Energy Networks Association is coordinating network-led workshops to standardise dispute processes around a set of principles: service level agreements at each stage, published escalation guides, deadlock letter criteria, escalation tiers, publication of anonymised dispute themes (potentially via CARs), reasoned decisions, multi-party case ownership, published process details (including in offer documentation), case management, and expedited handling for time-critical or strategically important disputes.
Implementation Timeline
Ofgem expects to finalise guidance in early 2027. Licence obligations will take effect either from summer 2027 (following statutory consultation) or will be aligned with the ED3 start date of April 2028. GSoP and deleay damage changes will follow a separate timetable reflecting the need for legislative and code modifications, with the intent to align with ED3. Working groups will convene in autumn 2026 and licence drafting will begin in late 2026.
Ofgem expects networks and NESO to adopt improvements voluntarily ahead of formal implementation.
Comment
This Decision marks a significant shift in the regulation of the connections process, moving beyond a purely timeliness-focused framework towards one that addresses the quality and content of the service customers receive at each stage. The layered approach combining prescriptive licence conditions for core minimum requirements with principles-based conditions for matters requiring professional judgement means that much of the detail will lie in yet-to-be-written guidance and in timeframes still to be determined with industry.
The principles-based licence conditions may raise questions of interpretation and enforceability. Network companies may be concerned that broadly framed obligations increase the scope for disputes, particularly where Ofgem’s expectations are articulated through guidance rather than binding licence conditions. Conversely, for developers, the enhanced offer content requirements and post-acceptance change-control duties should materially improve the bankability of connection offers and customers’ visibility of project progress.
The minded-to position on transmission delay damages above £0.00 per day could be significant for transmission-connected generators, storage operators and their investors. However, the design of the delay damage regime including questions of attribution of delay, caps, and NESO’s role as the contracting entity will be critical. The voluntary opt-in mechanism for earlier or alternative connections is a welcome innovation, but its effectiveness will depend on the safeguards and allocation methodology developed in subsequent consultation.
Although this is a decision document, it includes consultation questions on a number of points ahead of licence drafting and statutory consultation. The consultation closes on 6 November 2026.
