The Electricity Market Reform Settlement Company (EMRS) calculates the Final Consumption Levy (FCL)¹for each Supplier and Central Volume Allocation (CVA) Registrant based on BM Unit Demand volumes provided by Balancing and Settlement Code (BSC) systems and HH Metering System Metered Volumes received from Half Hourly Data Aggregators (HHDAs).

Elexon implemented P395 in November 2023 to adjust the data provided by BSC Systems to EMRS systems for the purpose of calculating FCL in accordance with BEIS^² and Ofgem’s^³ ‘Upgrading our energy system: smart systems and flexibility plan’. The plan clarified that FCL should not be charged in relation to import to generators which falls outside the definition of ‘supply’ in the Electricity Act. P395 incorporated the interim solution implemented by EMRS on behalf of the BSC in February 2019 (for SVA sites where there is no Final Demand present). This workaround ensured that Suppliers did not receive additional charges in relation to the EMR supported schemes.

The electricity consumed by Generation and / or Storage Facility Assets operated by a Generation License holder should not be subject to FCL. An Import Supplier or CVA Registrant can submit a Declaration under the BSC^⁴ to exclude FCL declared metered volumes from the total chargeable Supplier Demand. The FCL will then be calculated based upon a ‘BM Unit Chargeable Demand’ rather than ‘BM Unit Gross Demand’.

The Assets could be connected to the Transmission System or a Distribution System. The declaration process includes Assets registered in the Central Meter Registration Service (CMRS) and Assets metered by Half Hourly Metering Systems registered in the Supplier Meter Registration Service (SMRS).

EMR AMSID Declarations require the inclusion of an AMSID Pair for each Asset that they want to be used in the calculation of the BM Unit Chargeable Demand. As a result, each Asset must be registered in accordance with BSCP602^⁵, sections 2.9 – 2.11.

Once a Declaration has been successfully processed, BSC Systems will derive the chargeable and non-chargeable Import (for FCL purposes) and pass this information to EMRS via the SAA-I042^⁶. For the avoidance of doubt, import values for Settlement Purposes will not be amended.

What Assets can I register to be exempt from FCL?

Suppliers or CVA Registrants of Generation and / or Storage Facility Assets whose Import falls outside the definition of ‘Supply’ in the Electricity Act can make one of three types of declaration to exclude these assets from FCL.

CVA BM Unit Declaration – where there is no Final Demand at a CVA-connected site, the CVA Registrant will be required to declare the relevant CVA BM Unit as exempt from FCL.

Note that BSC Systems cannot calculate BM Unit Chargeable Demand for CVA sites where there is Final Demand present. In this scenario, the Final Demand would need to be supplied through a separate CVA BM Unit (or SVA MSID if appropriate and Distribution connected).

MSID Declaration – where there is no Final Demand at a SVA-connected site, the Supplier will be required to declare the Import MSID(s) for each site as exempt from FCL. The declaration must also include the Export MSIDs.
EMR AMSID Declaration – where there is Final demand at a SVA-connected site , Suppliers will be required to register each Generator and Storage Facility as a (behind the Meter) Asset (if not already registered by another Party) in order to obtain an AMSID Pair for each⁷. The proportion of Imports that should be deemed non-chargeable will be calculated in accordance with the On-Site Energy Allocation Methodology Document. The following diagram gives an example of a SVA Final Demand site and the Assets that would need to be registered as AMSID Pairs and included in the declaration.

How do I submit an FCL Exception Declaration?

An FCL Exemption Declaration should be submitted by a Category A or F Authorised Signatory through the Elexon Self-Service Gateway (Elexon Kinnect Customer Solution).

BSCP602 contains forms BSCP602/04, /05 and /06 which can be used to submit the declaration ONLY if the Self-Service Gateway (Elexon Kinnect Customer Solution) is unavailable.

Where an EMR AMSID Declaration is being made, the AMSID Pairs need to be created by registering the assets (if not already registered by another Party) within the Self-Service Gateway (Elexon Kinnect Customer Solution) first, and then a declaration can be made using the allocated AMSID Pairs. For guidance on registering AMSID Pairs, see Wider Access Guidance For Virtual Lead Parties (VLPs), Asset Metering VLPs and Suppliers.

Withdraw EMR Declaration

If the Supplier stops being appointed to the Import MSID or if the Asset(s) at the site are no longer operated by a Generation Licence holder you need to withdraw the Declaration. You can do this by adding an Effective To Date to the latest valid record of the declaration through the Self-Service Gateway (Elexon Kinnect Customer Solution). Note that the Effective To Date cannot be in the past. Please contact the BSC Service Desk to request the declaration's withdrawal if the Effective To Date is in the past or if the declaration has additional versions with an Effective From Date in the future.

The Self-Service Gateway (Elexon Kinnect Customer Solution) will automatically withdraw a declaration on the date that a BM Unit or AMSID Pair expires or the associated Registrant or Supplier withdraws from the Market.

If BSCCo identifies or is informed that the Asset should not be exempt from FCL, we will withdraw the declaration by end dating it. An email notification of such will be sent to the associated CVA Registrant or Supplier.

Change of Supplier / CVA Registrant

If there is a change of Supplier for an import MSID that is used in an AMSID or MSID declaration the old Supplier must withdraw the declaration by end dating its latest valid record within the Self-Service Gateway (Elexon Kinnect Customer Solution).

If BSCCo identifies that there has been a change of Supplier for an import MSID used in an AMSID or MSID declaration, BSCCo will withdraw the declaration by end dating it.

If there is a change of CVA Registrant for a BM Unit that is used in an EMR CVA BM Unit declaration the old CVA Registrant must withdraw the declaration by end dating its latest valid record within the Self-Service Gateway (Elexon Kinnect Customer Solution).

If BSCCo identifies that there has been a change of CVA Registrant for a BM Unit used in an EMR CVA BM Unit declaration, BSCCo will withdraw the declaration by end dating it.

The new Supplier or CVA Registrant needs to wait until the date that they become responsible for the Import MSID or CVA BM Unit respectively relating to the Asset before they can apply for an EMR Declaration using the same process and system as a new declaration. Any Existing declarations need to be withdrawn by the old Supplier or CVA Registrant before the new Supplier or CVA Registrant can submit their declaration.

Change of HHDA for MSID Declarations and EMR AMSID Declarations

Note that there is no Change of HHDA for CVA BM Units as all Metered Data is collected by the Central Data Collection Agent (CDCA).

If there is a Change of HHDA for an Import MSID in an MSID Declaration, or for an Import or Export MSID included in an EMR AMSID declaration, please let us know through a BSC Service Desk call. We obtain the HHDA from the Electricity Enquiry Service (EES) when the declaration is first validated. At the moment we don’t regularly refresh EES data but we will refresh the HHDA when we are made aware of a change though notification by the Supplier or through a system notification when data is not received from the old HHDA (due to it no longer being the HHDA).

Transfer of MSIDs from EMRS Interim Solution

The EMRS interim solution held a number of MSIDs for SVA sites where no Final Demand is present that were exempt from FCL. These MSIDs were transferred into BSC systems as part of Modification P395 on 2 November 2023 as FCL MSID Declarations. These declarations had an Effective From date of 2 November 2023.Prior to that date the FCL would have been determined by the EMRS Interim solution.

The EMRS system will no longer use the data it had stored to prevent duplication of exclusions in future.

Completing the Self-Service Gateway (Elexon Kinnect Customer Solution) fields or BSCP602/04, 05 or 06 form

An FCL Exemption Declaration should be submitted by a Category A or F Authorised Signatory through the Elexon Self-Service Gateway (Elexon Kinnect Customer Solution).

BSCP602 contains forms BSCP602/04, /05 and /06 which can be used to submit the declaration ONLY if the Self-Service Gateway (Elexon Kinnect Customer Solution) is unavailable.

Where an EMR AMSID Declaration is being made, the AMSID Pairs need to be created by registering the assets within the Self-Service Gateway (Elexon Kinnect Customer Solution) system first, and then a declaration can be made using the AMSID Pairs. For guidance on registering AMSID Pairs, see Wider Access Guidance For Virtual Lead Parties (VLPs), Asset Metering VLPs and Suppliers.

Field	Guidance
EMR Declaration Type:	Choose one from: MSID Declaration EMR AMSID Declaration CVA Declaration
Common Fields
Declaration Id / Reference	If you are completing the declaration through the Self-Service Gateway (Elexon Kinnect Customer Solution), the declaration Id is a value generated and assigned by the system to identify the Declaration. It is generated once the initial version of the Declaration is submitted. It is in the form of EMR-nnnnn e.g. EMR-00001. If you complete the form in BSCP602/04, 05 or 06, you should define a unique EMR Declaration Reference, which will be replaced by a reference in the form EMR-nnnnn when the details are entered into the Self-Service Gateway (Elexon Kinnect Customer Solution) by the Supplier Volume Allocation Agent (SVAA).
Postcode	The postcode of the facility as registered with Ofgem as a Generation Licence Holder
Declaration Effective From Date	Date from which the Declaration should be applied. This must be at least 10 Working Days after the submission of the declaration for new declarations. For declaration revisions this must be at least 5 Working Days after the submission of the revision.
Licensee Company Name	Company Name as registered with Companies House and with Ofgem as a Generation Licence holder. If the Company name is more than 30 characters, please truncate the name to 30 characters.
Licensee Company number	Company Number as registered with Companies House
Facility Name	You define the name of the Facility. It must be unique for a Supplier or CVA Registrant
Facility Category	Either Generation or Storage
Version	This field is only shown in the Self-Service Gateway (Elexon Kinnect Customer Solution) after the Initial Version of the Declaration is submitted, e.g EMR-00001-1. If the declaration is updated, the version number will be incremented.
Declaration Status	This field is only shown in Self-Service Gateway (Elexon Kinnect Customer Solution) after the Initial Version of the Declaration is submitted. Draft – the record is saved but needs further information to be added by the applicant or the Declaration needs to be submitted by an Authorised Signatory. Pending Validation – the record has been submitted by the Applicant and is awaiting validation by the SVAA Valid – Declaration Valid and data will be sent to EMRS from the Effective From Date to its Effective To Date to exclude the Facility(s) from FCL. Rejected – the SVAA has found a discrepancy in the information provided and rejected the declaration. The Declaration can be resubmitted with the error corrected. Whilst Rejected, the Facility(s) will be subject to FCL. Withdrawn – The record has been automatically withdrawn because the latest declaration record has expired, or because the related Role, BM Unit or AMSID has expired. Superseded - A valid declaration record that is not the latest has expired.
Submitter	This field is only shown in the Self-Service Gateway (Elexon Kinnect Customer Solution) after the Initial Version of the Declaration is submitted. The Category A or F Authorised person who submitted or will submit the declaration
Approval Date	This field is only shown in the Self-Service Gateway (Elexon Kinnect Customer Solution) after the Initial Version of the Declaration is submitted. The date that the SVAA validated the application
Effective To Date	This field is only shown in the Self-Service Gateway (Elexon Kinnect Customer Solution) after the Initial Version of the Declaration is submitted. The last date that the Declaration record is valid.
Initial / Revised Declaration indicator	This field is only on the BSCP602/04, 05 or 06 form. Use initial (I) if it is the first time the Declaration is being made. Use revised (R ) if it is an update to an existing Declaration.
Final Demand Indicator	This field is only on the BSCP602/04, 05 or 06 form. Must be “Y” for an EMR AMSID Declaration Must be “N” for a CVA BM Unit Declaration Must be “N” for an EMR MSID Declaration
CVA BM Unit Declaration
CVA BM Unit	CVA BM Unit Id
Role	Either Supplier or Generator
MPID/BSC Party ID	If the value selected in Role is Supplier, the system will show the MPID field. If the value is Generator the system will show the BSC Party ID field. The fields identify the Declarant.
MSID Declaration
MPID	The Market Participant ID for the Supplier (can be selected from a picklist) in the Self-Service Gateway (Elexon Kinnect Customer Solution)
Import MSID	The unique market wide reference for an Import Metering System. Also known as Metering Point Administration Number (MPAN)
Export MSID	The unique market wide reference for an Export Metering System. Also known as Metering Point Administration Number (MPAN). Note that the Export and Import MSIDs do not have to be registered to the same Supplier. In this case, the declaration needs to be completed by the Import Supplier who will need to enter the Export SVA MSID but does not need to identify the Export Supplier.
GSP Group	The GSP Group within which the Facility(s) are connected (_A, _B, _C, _D, _E, _F, _G, _H, _J _K, _L, _M, _N or _P).
EMR AMSID Declaration
MPID	The Market Participant ID for the Supplier (can be selected from a picklist in the Self-Service Gateway (Elexon Kinnect Customer Solution)
Import MSID	The unique market wide reference for a Metering System. Also known as Metering Point Administration Number (MPAN). The SVA site must have at least one Import and one Export MSID. If there is more than one Import MSID, they must have the same Supplier, but a different Supplier may be responsible for the Export.
Export MSID	The unique market wide reference for a Metering System. Also known as Metering Point Administration Number (MPAN). The SVA site must have at least one Export SVA MSID.
GSP Group	The GSP Group within which the Facility(s) is connected (_A, _B, _C, _D, _E, _F, _G, _H, _J _K, _L, _M, _N or _P).
SVA Site Id	Auto populated field in the Self-Service Gateway (Elexon Kinnect Customer Solution)
Import AMSID	You must register your asset first to obtain the AMSID Pair before you can add it to your declaration unless it has already been registered by another Party. Note that although you obtain an AMSID Pair, you only need to specify the Import AMSID in the declaration.

Need more information?

For other information please contact the BSC Service Desk at bscservicedesk@cgi.com or call 0370 010 6950

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No representation, warranty or guarantee is made that the information in this document is accurate or complete. While care is taken in the collection and provision of this information, Elexon Limited shall not be liable for any errors, omissions, misstatements or mistakes in any information or damages resulting from the use of this information or action taken in reliance on it.

1 Final Consumption Levies (FCL) are charges which recover the costs associated with schemes such as Contracts for Difference (CfD) and the Capacity Market (CM).

2 Department for Business, Energy & Industrial Strategy (now replaced by Department for Energy Security and Net Zero)

3 Office of Gas and Electricity Markets

4 BSCP602 paragraph 2.15

5 BSCP602: SVA Metering System and Asset Metering System Register’

6 The current BM Unit Gross Demand field in the SAA-I042 will be replaced with “BM Unit Chargeable Demand”

7 If the Generator or Storage Facility has already been registered as an asset by a Virtual Lead Party, the Supplier should use the existing AMSID Pair.

CONTENTS

Submission of declarations for exemption of non-final demand from final consumption levies

Background