Enhanced data sharing in the UK: Smart Data schemes and the UK’s Modern Industrial Strategy 2025

On 23 June 2025, the Secretary of State for Business and Trade presented the UK government’s Modern Industrial Strategy to Parliament (the “Industrial Strategy”). The Industrial Strategy is a 10-year plan setting out the government’s key initiatives for boosting business investment and making the UK a global leader in innovation and sustainable growth.

Publication of the Industrial Strategy came a few days after the Data (Use and Access) Act (the “DUA Act”) received Royal Assent. The DUA Act is intended by the UK government to enhance the UK’s digital strategy and unlock the use of data, harnessing its capabilities to boost public services and contribute to the UK economy.

A flagship part of the DUA Act is the provisions that will enable the government to introduce Smart Data schemes in the UK. Smart Data schemes establish a framework for sharing of customer data held by service providers (upon a customer’s request) with authorised third-party providers who will then be able to use the data to provide services to the customer.

In this Law-Now article we look at the government’s plans set out in the Industrial Strategy to increase access and sharing of data in the UK through Smart Data schemes under the DUA Act and other data-sharing initiatives.

The UK’s Modern Industrial Strategy 2025: capitalising on the value of data

A key focus area of the Industrial Strategy is capitalising on the value of data, harnessing both public and private sector data to increase productivity growth. The Industrial Strategy recognises data as one of the UK’s unrealised growth assets, increasingly underpinning innovation and productivity in all sectors. However, the government believes that data is currently too siloed, fragmented or is underused in the UK and the Industrial Strategy sets out the ways that the government intends to take action to overcome barriers to data access and data sharing and unlock the value of data across the UK economy.

New Smart Data schemes and other data-sharing initiatives

The introduction of the DUA Act is one way that the government can be seen to be taking action to overcome current barriers to data access and data sharing across the public and private sectors. However, the Industrial Strategy sets out a number of other initiatives that the government is intending to take with respect to Smart Data schemes and increasing access to data across the UK:

• Investing £36 million to support new Smart Data schemes. The government says that it will progress proposals for Smart Data schemes in the energy and financial services sectors, and explore opportunities for schemes in other sectors, including transport, digital markets and property.
• Accelerating progress on Open Finance through the FCA’s Smart Data Accelerator, which will facilitate the testing of uses cases and help shape policy for Open Finance. The government intends to work with the FCA to set out its Open Finance roadmap by March 2026. (Details of these plans are in the Financial Services Growth and Competitiveness Strategy, which was published on 16 July 2025.)
• Developing a new Smart Data scheme for the property sector that is intended to improve data-sharing across the real-estate industry. The sector plan for Professional and Business Services states that such a Smart Data scheme could support data sharing by conveyancers, surveyors, estate agents, local authorities, and housing providers, streamlining transactions as well as boosting productivity and growth.
• Looking to improve access to public and private data sets through Smart Data schemes to enable the future growth of the management consulting sector.
• Committing to spend up to £12 million in UK data sharing infrastructure initiatives from April 2026. The government says that inspiration for this has been taken from the Common European Data Spaces and these initiatives will seek to coordinate approaches to governance, legal considerations, regulations, data interoperability, security, and trust across a variety of key sectors.
• Introducing a new National Data Library, backed by over £100 million of government funding that is intended to bolster the UK’s AI sector by providing access to public data sets.
• Establishing a Creative Content Exchange (CCE) to be a trusted marketplace for selling, buying, licensing, and enabling permitted access to digitised cultural and creative assets (which was set out in the government’s AI Opportunities Action Plan). This is intended to provide access to copyright-cleared assets for the purpose of developing AI models.

Consultation on developing an energy Smart Data scheme

In 2025, the Department for Energy Security and Net Zero carried out a public consultation on introducing an energy Smart Data scheme. The government has previously said that it wants to support customers to make informed choices about their energy needs in what is an increasingly complex market. They believe that an energy smart data scheme could be one route to delivering this aim. The consultation identified a number of potential use cases for an energy-sector Smart Data scheme, including: streamlining carbon reporting for businesses by allowing easier data sharing; data sharing to improve accuracy of EV charging point information for customers; providing energy usage information to price comparison services to help customers find suitable tariffs based on actual use; providing access to energy usage with information about customer properties to allow tailored decarbonisation recommendations; and providing energy use information to allow targeted support to vulnerable customers. The consultation closed on 10 March 2025. The government’s response and proposals for next steps were published on 23 July 2025 and confirmed that the government will continue to work over the course of 2025 to consider whether to introduce an energy smart data scheme, and to identify and cost options on scheme design and implementation to support a potential consultation on detailed proposals.

Toolkit on commercialising industrial data

The regulatory landscape relating to access and use of industrial data is undergoing a significant change, with legislators in the UK and other jurisdictions, such as the EU, introducing new rules intended to enable businesses to capitalise on the value of such data and create economic growth. The continuing growth of digital transformation and the recent rapid adoption of IoT and AI technologies creates enormous potential to gain insights from data, to enhance decision-making, improve efficiency, reduce operating costs and grow productivity.

Businesses need to ensure that they are aware of the different regulatory regimes for each market in which they operate, not just to ensure compliance with new rules, but to take advantage of the opportunities that these changes create for commercialising industrial data.

To support clients with navigating the evolving industrial data landscape, we have created a Toolkit for commercialising your data. The Toolkit provides our insights on commercialising industrial data, including trends in data commercialisation, the developing legal and regulatory landscape, and steps for implementing a successful data strategy.

Access to our Toolkit on Commercialising your data is available here.

Next Steps

Look out for future Law-Now updates on Smart Data schemes and the UK’s data-sharing initiatives.

If you would like to discuss this article or how these developments may impact your business, please contact one of the listed lawyers or your usual CMS contact.