Insights

RIIO-3 Is Set. Delivering It Is the Hard Part

With the RIIO-3 Final Determinations published and the price control running from 2026 to 2031, the phase that consumed everyone’s attention, the settlement, is over. What replaces it is harder and less glamorous: delivering the commitments made in the plan, evidencing that delivery to the regulator, and doing it inside the allowances agreed. This is where a price control is actually won or lost, and it gets a fraction of the planning that the submission did.

By Christopher Fagan

The shift networks underestimate

Preparing a price control submission is an intense, well resourced effort with a clear deadline. Delivering it is a five year operational grind with commitments that are easy to lose track of, outputs that must be evidenced, and an allowance that does not flex when things cost more than assumed. The organisational energy that went into the plan rarely carries into delivery, and the gap between the two is where networks get into trouble with the regulator.

Where delivery goes wrong

Commitments without owners

A plan contains a large number of specific commitments. If each does not have a clear owner and a way of tracking progress, they drift, and the first time anyone assembles the full picture is when the regulator asks. By then the gaps are real and the time to fix them has gone.

Evidence assembled too late

Demonstrating delivery against outputs requires evidence produced as you go, not reconstructed at reporting time. Networks that treat regulatory reporting as an annual scramble rather than a continuous, controlled process spend the period firefighting their own returns.

The allowance treated as a budget, not a constraint

The allowance is fixed. Programmes that manage cost loosely in the early years find the constraint bites hard later, when the room to recover has gone.

What good delivery looks like

Every commitment mapped to an owner, with progress visible from the start of the period.
Evidence of delivery captured continuously, so regulatory reporting is a by product rather than a project.
Cost managed against the allowance from year one, with early warning when a trajectory is off.
Independent assurance for the board on whether the network is genuinely on track to meet its commitments, not just reporting that it is.

Why independence helps here

Regulatory delivery is exactly the situation where internal reporting drifts optimistic, because nobody wants to be the one flagging that a commitment is slipping. An independent view, reporting to the board rather than the delivery teams, surfaces those problems while there is still time and allowance to act. See independent programme assurance.

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Our consultants have worked across the energy networks and the regulatory environment they operate in. See energy and utilities and RIIO price control support, or get in touch.