12 January 2026
Our joint letter reflects something important: the gas sector is at its strongest when it collaborates. The current code arrangements have served the market well for many years, but they have also become increasingly complex, fragmented and can be difficult to navigate, particularly at a time when the energy system is undergoing rapid and profound change. Code Reform offers a once-in-a-generation opportunity to simplify this framework, increase digital integration, prepare our system for decarbonisation and through these improvements, enhance our ability to serve customers, including shippers and other code users.
To achieve this, the industry needs a Code Manager that delivers continuity, efficiency, impartiality, independence, and technical expertise from day one. That is why we welcome the collaborative approach set out in our letter, which brings together licensed Gas Transporters and established service providers to jointly design a model that is efficient, expert-led, demonstrably independent and delivers value for money for the industry.
Delivering expertise and efficiency through collaboration
Unlike the electricity codes, where responsibilities are more separate and segregated, the gas network codes cover a wider and more interconnected set of technical, commercial, operational, and digital functions. Much of this complexity sits within a few organisations that currently support the operation of the gas market, through long-standing licence obligations, governance arrangements, and delivery roles. Whilst recognising that the ultimate model and delivery arrangements remain subject to Ofgem’s assessment and decision-making, we believe a collaborative approach in proposing a Gas Network Code Manager will be beneficial to the industry and consumers.
Our letter to Ofgem recognises that reform must be delivered in a way that maintains system stability while enabling change. Harnessing the specialist expertise that already exists across the gas sector provides a clear route to doing this efficiently. It supports continuity of service, reduces the risk associated with transition and enables faster progress at a time when reform is urgently needed, while improving the experience and outcomes for governance participants.
An approach that builds on established capabilities allows the industry to:
- Maintain operational integrity during transition
- Avoid unnecessary duplication of systems, processes and knowledge
- Deliver reform at pace, without delaying benefits to consumers and the market
- Retain deep, industry-leading expertise built up over many years
- Provide stable governance through a period of significant regulatory and decarbonisation change
The industry is committed to ensuring that Code Reform is implemented in a way that is efficient and aligned with the needs of gas consumers in a rapidly evolving energy landscape.
A shared commitment to effective reform
The collaborative work described in our letter is focused on designing a Unified Gas Network Code Manager model that consolidates responsibilities, simplifies governance, and strengthens the link between code and system change. It also reflects a shared commitment to independence, impartiality, transparency, and sustained industry engagement, all of which are essential to long-term success. This approach is intended to enhance, not constrain, future governance options or regulatory discretion.
By working together, the gas sector can deliver a Code Manager model that is robust, expert-led, and capable of supporting the system through the changes that lie ahead. The joint approach we have set out demonstrates that the industry is ready to move forward constructively, and to work closely with Ofgem to deliver a reformed framework that works for all parties.
Further reading
Joint letter to Ofgem recommending a collaborative approach to code management.
Appointment of the Unified Gas Network Code Manager
White Paper on gas industry code reform and the critical role of a dedicated Code Manager.
Get in touch
If you have any feedback or questions on any of the above, please email us at communications@xoserve.com.
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