2026-009 Legal Support for RIIO-3 Licence Modification Appeals

RIIO-3 is the third iteration of the network company price control framework established by Ofgem. The final policy decisions for RIIO-3 are set out in the RIIO-3 Final Determinations and will be implemented via licence modifications (due to be directed on 3 February 2026). The framework will govern the gas distribution, gas transmission and electricity transmission sectors from 2026 to 2031. Relevant stakeholders have a right of appeal to the Competition and Markets Authority (CMA) in respect of the RIIO-3 licence modifications.

The RIIO-3 price controls themselves are complex and, carry high appeal risk in certain areas. Given the volume of work associated with regulatory appeals, Ofgem's OGC team and Counsel (upon the latter's instruction) will need supplementary support from a legal supplier, making use of its expertise and prior experience of contentious work in the regulated sectors (e.g. energy, water, telecoms etc.). The scope of work is likely to (but not limited to) includes pre-appeals support, support in meeting statutory appeal and CMA deadlines, and day-to-day administrative and communication support.