How the change process works

Flexiblilty Market Rules are refined through an ongoing process based on stakeholder input, evolving market needs, and collaborative working groups. 

This page explains how changes are proposed, reviewed, approved, and implemented.

The flexibility market change process applies to all updates – whether creating, amending, or removing formal flexibility market documents and Flexibility Market Rules.

The process will be finalised before December 2025, following a consultation launched on 1 September 2025.

Phases in the change process

Every formal Change Proposal (CP) follows four main phases.

1. Raising a change

Validates the need and scope of a proposed change. This means:

• a proposed change or issue can be submitted by any person with a legitimate interest in the market facilitator arrangements but who is not bound by the Flexibility Market Rules
• we check it against validation criteria (such as completeness and scope)
• a progression route and plan are then agreed

Each proposal is assessed against clear objectives. To be approved, it must show how it delivers improvements compared to the current baseline.

Who can raise a change?

Any interested person can raise an issue or formal proposal if they have a clear interest in the flexibility market arrangements.

2. Assessment

Develops and tests the best solution through consultation. In this phase:

• the market facilitator completes an impact assessment to assess costs, benefits, and timelines
• stakeholders give feedback during consultation
• results are summarised in an assessment report

3. Decision

Determines whether the proposed solution should be approved or rejected. Specifically:

• the market facilitator reviews the assessment report and stakeholder feedback
• a decision report is published
• if the change affects the EBGL Article 18 terms, it is sent to the Authority for approval

4. Implementation

Puts approved changes into effect. In this final phase:

• the market facilitator and System Operators (SOs) make the agreed updates to rules and systems
• changes take effect on the agreed implementation date

The process is open and transparent, with active involvement from stakeholders at every stage.

The market facilitator’s role

• offers free advice, guidance, and challenge to help proposers develop strong, evidence-based changes
• maintains a public change register showing all proposals, their status, priority, and decisions

Stakeholder roles

• Proposing changes
• Owning your proposed solution
• Suggesting alternative options – others can suggest up to three alternative solutions to address the same issue
• Participating in workgroups that may be formed for complex changes, to help develop the best solution (with at least 5 experts)

Governance and oversight

This is provided by:

• Stakeholder Advisory Board (SAB) – provides advice on proposals, including timelines and progression routes, and recommends whether a change should be approved
• System Operators (SOs) – the National Energy System Operator (NESO) and Distribution Network Operators (DNOs) may take part in impact assessments to explain how a change would affect them
• Appeals – interested persons can appeal the Market Facilitator’s decision on a proposal to the Authority

The market facilitator decides how each change moves through the process based on its complexity and readiness. The route chosen helps stakeholders understand what will happen next and when they can provide input.

The different progression routes are:

• Assessment by the market facilitator – for proposals that need some development but don’t require a full workgroup
• Assessment by a workgroup – for complex proposals where expert input is needed to develop and assess the solution
• Direct to assessment consultation – for fully developed proposals that are ready for immediate stakeholder feedback
• Housekeeping – for small corrections or updates that don’t affect participants materially, these can move straight to decision phase with a 10-working-day objection window
• Urgent – for proposals that need fast-tracked consideration, with shortened timelines for assessment, consultation, and impact analysis

Prioritisation

When needed, Elexon prioritises proposals to manage delivery and help stakeholders understand which changes will be addressed first. In these circumstances, priority will be assessed as:

• High priority– requires fast assessment and implementation
• Standard priority – follows normal timelines
• Low priority – deferred for consideration in future delivery plans

Prioritisation is based on how well a change aligns with the delivery plan, implementation costs, its importance (value, criticality, and risk), and time sensitivity.