The Energy Transition | UK government rules out pending applications process for CfD AR8

This week’s edition reports on the government's decision to drop the pending applications process for Allocation Round 8 of the Contracts for Difference scheme and Ofgem's consultation on a proposed central asset register.

Government rules out pending applications process for CfD AR8

The government has announced that the pending applications process will not apply for Contracts for Difference (CfD) Allocation Round 8 (AR8). The decision reverses a proposal included in the government's initial response to its consultation on refinements to AR8. 

The pending applications proposal would have allowed those applicants who have requested a tier 2 appeal to submit a sealed bid during the sealed bid window in three circumstances: where Ofgem had not yet reached its decision; where Ofgem had upheld a non-qualification decision but the timeframe to file an appeal at the High Court or Court of Session had not yet expired; or an appeal has been made to the High Court or Court of Session and the appeal has not been determined. 

By dropping the proposal, the government has ensured that the appeals process for all non-qualifying applications will conclude before the sealed bid window opens. AR8 will therefore not run to an expedited timeline. The government said it wants to ensure maximum competition and to allow participants sufficient time to prepare bids.

The National Energy System Operator (NESO) will publish its notice of auction on 19 November setting out the timings of the AR8 sealed bid window. The government will also publish the contract budget notice for AR8.

Ofgem consults on framework for a central asset register

Ofgem published a consultation on 12 October seeking stakeholder views on the proposed framework for a central asset register (CAR) to provide a "complete, consistent and trusted view" of assets across Great Britain. This builds on Ofgem's previous consultation on asset visibility published in December 2025 which expressed a preference for a centralised approach building on existing infrastructure.

Ofgem is now inviting respondents to provide views on the CAR framework. The consultation covers the outcomes the register should support, including usable and trusted asset visibility data, future-ready data infrastructure and improved national evidence for decision-making. It also addresses the priority use cases the register should enable, noting that, while a CAR could support a range of purposes including planning, policy and operational activities, it could not provide the same value.

The consultation considers the design and delivery principles the register should follow, the minimum functional requirements a CAR should support in terms of what it should be capable of rather than its detailed technical design, and the assessment criteria used to compare delivery options. Ofgem has identified two shortlisted approaches: Elexon's flexibility market asset registration model and ElectraLink's EMPRIS platform. 

The consultation is published alongside a draft impact assessment. Together, these will inform Ofgem's final decision on the preferred delivery model of a CAR.

Responses are welcome from all stakeholders and members of the public. Ofgem has particularly invited input from distribution network operators, the NESO, Elexon, ElectraLink and flexibility service providers. 

The consultation is open until 7 December. A final decision is expected to be announced in spring 2027, alongside a final impact assessment.

Luna Panella and Rani Mandalia, trainee solicitors at Osborne Clarke, assisted in writing this Insight.