GB tightens wholesale flexibility eligibility rules

New GB wholesale-market rules tighten eligibility for aggregated flexibility

New Balancing and Settlement Code rules took effect on 24 August, tightening which generation assets can participate through the wholesale-flexibility arrangements created by P415.

EVCP Info 25 August 2026 2 min read Updated 2 September 2026

Ofgem approved modification P511 after concerns that some generation assets could receive double remuneration and create mutualised compensation costs for consumers.

P415 opened wholesale markets to independent aggregation

P415 allows independent aggregators, known in the Balancing and Settlement Code as Virtual Lead Parties, to bring customer flexibility into the wholesale electricity market without being the customer’s electricity supplier.

That creates a route for flexible demand and other assets to earn value from changing their consumption or generation in response to market conditions.

P511 narrows eligibility for generation assets

P511 does not reverse P415. It introduces revised eligibility criteria intended to stop generation assets from participating in ways that could lead to double remuneration or compensation costs that are spread across other market participants.

Ofgem says the change was needed because some activity did not align with the original policy intent of P415.

This is upstream of smart EV charging

P511 is primarily aimed at generation participation, not EV charging.

Its relevance to charging is the market architecture behind aggregated flexibility. A charger responding to a cheap retail tariff is different from a portfolio of chargers being controlled by an aggregator and traded into wholesale or balancing markets.

As EV charging becomes a larger flexible load, the rules governing aggregator participation, settlement and compensation will increasingly affect the commercial models used behind managed charging services.