Zenobe Energy submits BSC Modification P522 to introduce subsidy-adjusted Shadow Bid Price for Balancing Mechanism transparency

On 1 October 2026, Zenobe Energy raised BSC Modification P522, proposing a calculated subsidy-adjusted Shadow Bid Price to be published alongside the existing submitted Balancing Mechanism (BM) Bid Price. The Shadow Bid Price would be for information and scrutiny only, not altering the submitted Bid Price, NESO dispatch decisions, or BMU Settlement cashflows. The proposal is now progressing through Elexon's BSC modification assessment process, with the Panel considering Elexon's Initial Written Assessment on 8 October 2026 and recommending progression to Assessment Procedure via an industry Workgroup.

The mechanism would make visible the effect of subsidy/support schemes on BM Bid Prices, enabling greater comparison and scrutiny of pricing behaviour by subsidised generators without altering settlement outcomes. This addresses market transparency concerns around subsidy distortion in balancing bids, complementing related work under P462 but taking a non-settlement-altering, information-only approach that could inform future settlement reform debates.

P522 represents a targeted transparency intervention in the GB Balancing Mechanism, distinct from the more consequential P462 proposal which would alter settlement treatment of subsidised bids. By introducing a parallel 'shadow' price for information purposes, P522 lowers the barrier to industry acceptance (no cashflow or dispatch impact) while building an evidentiary base—drawing on P462's methodology for valuing support mechanisms—that could later support more substantive reform. The modification's current trajectory (Workgroup-led Assessment Procedure, two-stage consultation, and Panel reporting through May 2027) is a fairly standard BSC modification timeline, suggesting this is at an early but active stage of multi-stakeholder deliberation rather than settled policy. The interplay with P462 is a key dependency to monitor: outcomes or timing shifts in P462 could affect the shadow price methodology adopted here.

Balancing and Settlement Code (BSC) Modification Process

Workgroup Meeting 2 · 11 Nov 2026

Primary sources