Consultation outcome

Government response to the consultation on measuring instruments display requirements for ESAs

Updated 23 February 2026

Summary

1) The Measuring Instruments Regulations 2016 (MIR) play a vital role in protecting consumers and businesses, ensuring measuring instruments are accurate and reliable. Under MIR, manufacturers, importers and distributors have a legal obligation to ensure all regulated measuring instruments meet essential and specific requirements. These instruments must also undergo conformity assessment before they are placed on the market. As technology evolves and consumer behaviour shifts, it is important that legislation such as MIR is reviewed and updated, to ensure that it remains fit for purpose.

2) Through regular engagement with industry, the Government was made aware that the requirement in MIR for measuring instruments to be fitted with a meter with a physical, in-built, metrologically controlled display ^{[footnote 1]} could act as a potential barrier to the rollout of low carbon technologies, such as Energy Smart Appliances (ESA). The requirement adds to production costs and may also be outdated given changing consumer behaviour.

3) While these concerns were originally raised in relation to Electric Vehicle Smart Charge Points (EVSCPs), the Government decided to seek views on the requirement in relation to all ESAs. This includes, for example, private and public electric vehicle charge points, heat pumps and Battery Energy Storage Systems (BESS).

4) The Government launched a public consultation on 28 May 2025 to gather the views of industry, manufacturers, consumers, and all other interested persons on the current display requirements of the MIR, particularly in relation to ESAs. The scope of the consultation applied to Great Britain only, ran for a period of 10 weeks and closed on Tuesday 4 August 2025. It received 42 responses.

5) The Government has analysed all consultation responses received, and reviewed the different perspectives offered on the physical in-built display requirement in MIR.

6) After careful consideration, the Government has decided to amend, for Great Britain only, the essential requirements in MIR (paragraph 10.5 of Schedule 1A) to permit the use of a metrologically controlled remote display, such as a smartphone for example, as an alternative to in-built physical displays, for active electrical energy meters within ESAs. The Government plans to implement this change by laying a Statutory Instrument (SI) in 2026 with this change coming into force at the end of 2027.

7) The Government believes that this approach will remove a barrier to the rollout of ESA flexibility services by lowering production costs and better reflecting modern consumer preferences and expectations for monitoring their energy use. This will support the Government’s net-zero goals to deliver clean power by 2030. It will broaden accessibility to consumers’ ESA meter readings by enabling them to track their energy use in more ways, such as through a smartphone app. It will also open up new features that benefit consumers who engage in consumer-led flexibility (CLF) services, and support consumers in making greener and cheaper choices through adjusting their energy usage during peak periods.

8) Amending MIR in this way supports the Department for Energy Security and Net Zero’s (DESNZ) proposal to mandate that, from 1 January 2028, all ESAs in scope of the Phase 1 ESA Regulations must include a metrologically-controlled Class B active electrical energy meter, and comply with all of MIR’s requirements for such meters.

9) This would mean that, from 1 January 2028, all ESAs, whether or not they are used for trade ^{[footnote 2]}, must include a metrologically-controlled device meter (including a display whether physical or remote) and be conformity assessed. DESNZ launched a public consultation on its proposed regulations on 1 December 2025 and is seeking stakeholder views on whether all ESAs in scope of the Phase 1 ESA Regulations must be placed on the market with a MIR compliant Class B active electrical energy meter.

Read about the DESNZ SSES consultation.

Consultation responses overview

10) The consultation ran from 28 May to 4 August 2025 and received 42 responses.

11) Out of the responses analysed, we identified 29 as being from businesses, 7 from trade associations and 6 from consumers, charities and other organisations.

12) The consultation was published on GOV.UK and respondents could submit responses in various ways. 24 responses were submitted via Qualtrics, an online digital platform, and 18 were received via email at measuringinstrumentsconsultation@businessandtrade.gov.uk.

13) The consultation contained both open and closed questions. All questions were optional to respond to, and answer methods were a mixture of multiple-choice questions and free text boxes, allowing respondents to provide a full range of views. All comments and evidence submitted by respondents were considered during analysis.

Summary of consultation response analysis

14) The results of our analysis showed that 87% of all respondents were in favour of amending the physical display requirement in MIR to allow for a remote display option for active electrical energy meters in ESAs.

15) Respondents can be broken down into the following categories:

Respondent type	Number of responses	Percentage of total responses
Industry [footnote 3]	29	69%
Trade Associations	7	16%
Consumers	2	5%
Charities	2	5%
Other	2	5%

16) Industry responses broadly supported the Government’s proposal to allow remote displays for active electrical energy meters in ESAs, recognising benefits such as reduced manufacturing costs and improved commercial viability. However, there is reluctance to extend this beyond ESAs to boundary and utility meters, with concerns cited including the need for there to be physical displays on these devices for repairs, testing, commissioning, and potential dispute resolution complexities.

17) Industry noted that physical displays are the most expensive component when manufacturing a new meter, so removing them could lower costs for them and consumers alike. The potential for positive consumer impacts was also highlighted, particularly for those who may struggle to access a physical meter on a device, or those with disabilities. However, it should be noted that most feedback on this issue came from industry stakeholders rather than consumer groups.

18) Concerns were also raised by consumer groups and charities about digital exclusion, especially for individuals lacking the necessary technology or experience, and those with learning or cognitive disabilities who may find physical displays easier to use.

19) Respondents agreed that safeguards in the MIR are generally acceptable but require enhancements, particularly around cybersecurity to prevent tampering and ensure metrological accuracy.

20) Views on implementation timelines varied, however, the majority of respondents preferred a 12-month implementation time frame to adjust to the new changes being proposed for display requirements.

Public charge points (PCPs)

21) This consultation sought views on removing the physical display requirement under MIR for the meter in public charge points. We are not considering placing any requirements on charge point operators regarding the in-built display or the app for the charge point itself.

22) We received a small number of responses from PCP manufacturers who agreed with the consensus of amending the display requirement in MIR to permit the use of remote displays, which should also include PCPs. As we heard limited views on this topic, we intend to carry out further targeted stakeholder engagement to inform a policy position on this.

23) A limited number of respondents raised accessibility concerns for consumers at PCPs for example, drivers being prevented from charging at a PCP because the charge point did not provide a suitable payment method.

24) Similarly, PCP and EV suppliers noted the need for accessible charge points for disabled users and those who benefit from driving a subsidised EV vehicle under the Motability Scheme. Some respondents outlined that in-built physical displays on charge points pose challenges for wheelchair users who need lowered screens. They suggested that remote displays offer benefits such as technology to assist blind or partially sighted users which can also allow wheelchair users to view information without leaving their vehicles, supporting accessibility.

25) Whilst accessible EV charge points are outside the scope of this consultation, we recognise their importance. The Government will take into account accessibility and digital inclusion as part of its obligation to consider equality and prevention of discrimination against individuals with disabilities, when creating future legislation.

Question by question analysis

Question 1: Remote display for ESAs

Q1A Do you support amending the physical display requirement to allow a remote-only option for ESAs within scope of the MIR? (YES/NO).

Q1B Please provide reasons for your answer.

• 87% Yes to amending the physical display requirement to allow a remote-only option for ESAs
• 13% No to amending the physical display requirement to allow a remote-only option for ESAs

Q1 Summary of response

26) Overall, 87% of respondents were in favour of removing the physical in-built display requirement in MIR for ESAs. They explained that the proposed change would modernise energy sector practices by enabling cloud-based or direct transmission of usage data, improving accuracy and supporting flexibility services for consumers. Removing the requirement for in-built displays would also reduce manufacturing costs, simplify product design, and align with how consumers already use digital tools to manage their energy.

27) However, some raised a few concerns about a remote-only approach for accessibility and inclusivity. Not all consumers own smartphones or have reliable internet, and some rely on physical in-built displays for clarity and confidence in billing. Some respondents suggested that removing manual readout options could disadvantage low-income households and less technologically proficient users, especially in areas with poor connectivity. Industry maintained that ensuring equitable access to energy data remains essential for fair and transparent energy monitoring, and any changes should consider the impact on people with protected characteristics.

Q1 Government response

28) The Government will seek to lay an SI in 2026, so that MIR is amended by the end of 2027 to permit the use of remote displays as an alternative to in-built physical displays for active electrical energy meters within ESAs.

29) The Government considers that amending the current essential requirements to allow for a remote display option will remove a barrier to the rollout of ESAs and the deployment of CLF services, by reducing production costs and aligning more closely with modern consumer practices around energy monitoring.

30) The number of ESAs placed on the market and in use in the UK is expected to increase significantly over the next five years. ^{[footnote 4]} These devices are key to enabling broader flexibility services and achieving electricity decarbonisation. Therefore, these changes will also help futureproof the regulations by aligning them with technological advancements and evolving consumer behaviour, helping avoid connection issues with other smart devices.

31) The Government understands concerns over digital exclusion. However, as of 2025, approximately 90% of people in the UK have access to mobile phones, with the vast majority using smartphones. ^{[footnote 5]} Trends have shown mobile phones are now used not just for communication, but also for entertainment, health tracking, shopping, and to increase productivity. Digital exclusion is discussed further below, with specific information on Government schemes that are directly designed to support affected individuals.

Question 2: Remote display for utility meters and others

Q2A Do you support amending the physical display requirement in MIR, to allow a remote-only option, for measuring instruments beyond ESAs, such as utility meters? (YES/NO)

Q2B Please provide reasons for your answer.

• 48% Yes to extending the physical display requirement beyond ESAs
• 52% No to extending the physical display requirement beyond ESAs

Q2 Summary of responses

32) Responses received to this question were mixed. 52% of responses disagreed with extending the physical display requirement in MIR beyond ESAs, and there were multiple reasons provided for and against.

33) Some industry respondents who were against extending the physical display requirement in MIR beyond ESAs, said that without a physical display on electricity utility meters there could be significant challenges in performing essential diagnostics and operational checks. Displays are currently used to identify faults quickly, confirm if a meter is live or if its battery has depleted, and verify whether essential components are functioning correctly. Physical displays were said to be critical during In-Service Testing (IST) ^{[footnote 6]} and accuracy checks, where engineers rely on visual feedback to confirm flow rates, power levels, and successful installation procedures.

34) Some industry respondents also suggested that removing physical in-built displays for electricity utility meters may disadvantage some consumers. Industry noted how electricity utility meters serve a broader and more critical role for consumers, particularly in ensuring billing accuracy and supporting prepayment functions. For customers, especially those using prepayment meters, physical displays are vital for checking balances, and monitoring energy usage without relying on apps or digital interfaces. They also facilitate consumers to enter credit directly into the meter via its physical display. This is crucial for those without reliable digital access or during connectivity issues. It was also suggested that energy suppliers need to follow other requirements to deploy utility meters with physical displays, which are set out in the Smart Metering Equipment Technical Specifications (SMETS).

Access the SMETS – Smart Energy Code website

35) Respondents who were in favour of extending the physical display requirement in MIR beyond ESAs, outlined that remote displays are more practical than physical ones, particularly where meters are installed in hard-to-access locations like basements or outside properties. Removing the requirement to have a physical in-built display would also streamline conformity assessment processes by simplifying both the design and testing processes. Remote displays would also be in scope of the conformity assessment procedure in MIR and could also reduce the number of physical elements subject to conformity checks. This would allow manufacturers to focus assessments on core metering functions like accuracy, data integrity, and secure communication protocols. This can lead to faster certification timelines, lower production costs and consequently, a faster rollout of ESAs. For industrial and commercial meters, respondents noted how remote communication is already standard practice, though local access to the physical meter remains essential for fault diagnostics.

Q2 Government response

36) At this stage, we are not progressing with these changes for utility meters. Unlike the clear consensus in favour of remote-only displays for ESAs, responses on utility meters were very mixed. It is therefore important to explore this further in due course, ensuring that all stakeholder perspectives are fully considered before any decision is made.

37) The Government intends to consult on whether it would be appropriate to adopt similar changes in GB to those being considered by the EU under the EU’s proposed Targeted Technical Amendment (TTA) to amend the Measuring Instruments Directive (MID). This would also be an opportunity to explore a number of other considerations for amending MIR, including whether to permit remote displays for electricity utility meters and whether to bring Direct Current (DC) meters into scope of MIR for the first time.

Read the proposed TTA to amend the MID – Europa website

38) The Government recognises the need to balance the pursuit of technological innovation with consumer protection and operational integrity. Any move toward remote-only access beyond active electrical energy meters within ESAs must be done in a manner which maintains reliability, transparency and inclusivity.

Question 3: Impact on business

Q3A In your view, how would permitting a remote-only display for ESAs in scope of MIR impact businesses? (Positively / Negatively / Other)

Q3B Please provide reasons for your answer.

• 92% Positive impact to businesses
• 8% Negative impact to businesses

Q3 Summary of responses

39) The majority of industry respondents explained that removing the requirement for physical in-built displays on ESA meters would deliver regulatory and commercial efficiency. Respondents suggested it would reduce manufacturing costs, simplify product design, and support faster innovation in the smart appliance sector. Industry mentioned that aligning the UK’s MIR with any future changes made to the MID would also ease compliance costs and help facilitate the distribution of their products to both UK and European markets, as they would not need to make devices conform to two different sets of regulations (one for GB and another for NI and the EU).

40) Additionally, respondents said not requiring physical displays contributes to environmental sustainability by reducing plastic and electronic waste, while enabling more consumer-friendly energy solutions. This also promotes the Government’s objectives in the Clean Power Action Plan which sets out a pathway to delivering a secure, affordable and decarbonised electricity system by 2030 by identifying key hurdles and actions to unlock progress across sectors.

Read the Clean Power Action Plan.

41) Industry did also note some potential negative impacts. Removing physical displays from existing models to utilise the remote display option could increase operational complexity for installers and engineers, as well as complicate dispute resolution. This could consequently lower consumer trust in businesses, particularly during power outages or app failures, and disadvantage those without access to digital tools. Industry also suggests that the absence of a physical display interface could raise compliance risks under consumer protection regulations and lead to higher costs and reputational challenges for suppliers.

Q3 Government response

42) The Government recognises that, overall, respondents said that amending the essential requirements of the MIR to allow for remote-only displays for active electrical energy meters within ESAs would have a positive impact on business. These changes, once implemented, could also align MIR more closely with the EU’s proposed TTA to amend the MID. The Government acknowledges respondent’s views that alignment between the MID and the MIR could help ease cross-border compliance and reduce regulatory divergence for businesses operating in both the UK and EU markets. The Government will continue to engage with stakeholders on this matter once the EU’s draft TTA is finalised.

43) Given these considerations, the Government agrees that the benefits of a remote-only display option for active electrical energy meters in ESAs outweigh the disadvantages, but any regulatory changes must carefully balance the needs of consumers and operational stakeholders.

Question 4: Impact on consumers

Q4A In your view, how would permitting a remote-only display for ESAs in scope of MIR impact consumers? (Positively / Negatively / Other)

Q4B Please provide reasons for your answer.

• 77% Positive impact on consumers
• 23% Negative impact on consumers

Q4 Summary of responses

44) Industry respondents said permitting a remote-only display for ESAs in MIR would positively impact most consumers by aligning with modern consumer behaviour. Many users already rely on apps and digital platforms to monitor energy consumption, and remote displays can enhance accessibility, especially for those using assistive technologies or with meters in hard-to-reach locations. This approach reduces hardware costs, supports environmental sustainability, and encourages broader adoption of ESAs, helping to meet flexibility goals under the Clean Power Action Plan.

45) However, respondents acknowledged that some consumers, particularly those who are digitally excluded or prefer direct interaction with their meter, may face challenges. The absence of a physical display could reduce transparency and limit trust in remote data for some users.

Q4 Government response

46) The Government acknowledges that permitting a remote-only display option in MIR for active electrical energy meters within ESAs would benefit many consumers.

47) The Government also recognises concerns around digital exclusion which are addressed further at Paragraphs 54-59 below. On accessibility, the Government acknowledges the importance of inclusive design principles to ensure all persons, particularly those with protected characteristics, can interact with their ESA meters to understand their meter readings.

48) To address these concerns, the Government will engage with consumer advocacy groups and other relevant stakeholders to identify further mitigations.

Question 5: Challenges or barriers for consumers

Q5A Could allowing the option of a remote-only display for ESAs create any barriers or challenges for consumers using or accessing those products? (YES/NO)

Q5B Please provide reasons for your answer.

• 55% Yes to creating challenges for consumers accessing products
• 45% No to creating challenges for consumers accessing products

Q5 Summary of responses

49) Overall, 55% of respondents thought that allowing remote-only displays for ESAs could create barriers for certain consumer groups, particularly those who are digitally excluded.

50) Digital exclusion refers to the inability of individuals to access or effectively use digital technologies, often due to lack of internet connectivity, suitable devices, or digital literacy. Digital exclusion which often affects older adults, disabled individuals, and low-income households, is linked to poverty and poor health.

51) These groups may struggle to monitor their energy usage or be unable interact with their smart appliances effectively, due to lack of digital literacy. The absence of a physical display could also reduce transparency and trust, as consumers would not be able to directly verify usage or performance data without relying on third-party systems.

52) Industry members also suggested that operationally, remote-only models may complicate troubleshooting particularly during power and communications outages or app failures. While digital interfaces offer flexibility and align with broader trends, industry advocated that strong safeguards – such as inclusive design, fallback access options, and hardware-based override functions – are essential to ensure that all consumers can use and benefit from ESAs without being disadvantaged (see paragraph 68).

53) Without mindful implementation of a remote display option, industry suggested these proposals risk widening inequalities and undermining confidence in smart technologies, limiting access to ESA benefits.

Q5 Government response

54) The Government acknowledges that permitting remote-only displays in MIR for active electrical energy meters within ESAs could present some challenges for certain consumer groups.

55) Particular consideration is needed for those individuals whose are at risk of being digitally excluded, have limited internet access or lack confidence when using smart technology, as they may face additional barriers in monitoring their energy usage and interacting with ESAs.

56) To mitigate any barriers for those who may be at risk of digital exclusion, the Department for Science, Innovation and Technology (DSIT) published the Digital Inclusion Action Plan: First Steps in February 2025, which outlines the Government’s strategy to improve internet access and digital literacy among vulnerable groups. Key initiatives include the Digital Inclusion Innovation Fund, which supports local authorities and charities in reaching digitally excluded populations such as older adults, low-income households, and disabled people.

Read the Digital Inclusion Action Plan: First Steps policy paper.

Read about the Digital Inclusion Innovation Fund.

57) DSIT is also working with the Digital Poverty Alliance to refurbish and redistribute surplus government laptops, and has secured pledges from companies like Google, BT, and Vodafone to provide digital skills training and donate connectivity and devices. The plan emphasises local delivery, empowering mayors and community leaders to tailor solutions to regional needs. It is structured around four pillars: opening up opportunities through skills, tackling data and device poverty, breaking down barriers to digital services, and building confidence through community-led support.

Read about the Digital Poverty Alliance. – DPA website

58) The Government’s proposal to amend the physical display requirement in MIR for active electrical energy meters within ESAs will allow industry a choice to supply ESAs with or without displays, based on consumer preference. If there is a demand for ESAs with physical displays, then industry can supply meters with displays to those that need it most. If not, then we would expect that consumers can still use a local display such as a phone, PC or tablet.

59) Other safeguards for ESAs are addressed further in response to Question 6 below.

Question 6: Safeguards

Q6A If the option of remote-only displays were permitted, do you think the existing safeguards in the MIR (e.g. maximum permissible error (MPE) limits, conformity assessments etc.) would be sufficient to ensure consumers and manufacturers are protected against inaccurate meter readings? (YES/NO)

If NO, what additional safeguards do you believe should be mandated for meters using remote-only displays?

Q6B Please provide reasons for your answer.

• 55% Yes to having adequate safeguards
• 45% No to having adequate safeguards, or suggested additional safeguards as recommendations (see below)

Q6 Summary of responses

60) Industry respondents were of the opinion that the existing safeguards in the MIR, such as maximum permissible error (MPE) limits and conformity assessment, are generally robust and effective for ensuring measurement accuracy.

61) However, some respondents thought that permitting remote-only displays may introduce new risks that may not be fully addressed by these standards alone, and that the Government should consider bolstering the available safeguards to ensure the smooth rollout of ESAs.

62) Without a physical display, industry noted that consumers and suppliers lose a direct means of verifying meter functionality, which could undermine trust and complicate fault diagnosis, especially during outages or disputes. Industry suggested that to mitigate these risks, additional safeguards for the remote display, such as data encryption and tamper-proofing, should be considered.

63) To ensure fairness, security, and accessibility in remote metering, industry representatives were of the view that data must be encrypted and tamper-proof during transmission, with direct access to the data restricted to only authorised users and supported by audit trails. Where physical displays are absent, secure fallback options such as web portals or local overrides should enable verification during outages or disputes.

64) Industry stated that remote interfaces must also be inclusive, supporting assistive technologies, multilingual functionality, and user-friendly design. They suggested that consumer protection frameworks should be updated to ensure transparency, facilitate dispute resolution, and maintain minimum service standards in remote-only display models.

Q6 Government response

65) The Government agrees that the existing safeguards in MIR are generally robust and effective to ensure the accuracy of measuring instruments, which protects consumers and manufacturers. The Government will consider further when developing the amendment to the legislation to ensure existing safeguards in MIR work effectively for remote displays.

66) The Government also agrees that it will be necessary to ensure that core meter functions, such as accuracy of readings, can be maintained if the device’s internet connection, apps or cloud services fail.

67) Many of the suggestions for additional safeguards made by industry will be provided for by DESNZ’s Smart Secure Electricity Systems (SSES) Programme: first phase energy smart appliances regulations. DESNZ launched their consultation on these draft regulations on 1 December 2025.

Read about the DESNZ SSES consultation.

68) The SSES programme and the First Phase ESA Regulations will introduce measures that aim to ensure consumer protection, system security, and regulatory compliance whilst the UK transitions to a smart, flexible energy system. Examples of some of the existing and future safeguards in MIR and the ESA Regulations are:

a. Accuracy standards: Paragraph 10 to Schedule 1A of MIR requires that all regulated measuring instruments are fitted with a metrologically controlled display as the reading of this display serves as the basis for the price to pay. When MIR is amended the requirement for any display to be metrologically controlled, whether it is physical or remote, will be retained.

b. Mandatory cybersecurity and data protection standards: As set out in Regulation 16 of the draft ESA Regulations, from 1 January 2028, all ESAs must meet minimum cybersecurity and data protection requirements (ETSI EN 303 645) to prevent hacking and remote manipulation that could disrupt functionality or impact the grid.

c. Connectivity disruption: In order to protect consumers from connectivity issues, Regulations 9 and 11 of the draft ESA Regulations set out certain requirements to ensure resilience in connectivity scenarios. The regulations will include a requirement that ESAs must remain capable of carrying out their primary function, even if it ceases to be connected to a network.

d. Tamper proofing: Both MIR and the ESA Regulations will seek to protect consumers from having their devices hacked, including those with a remote display. Paragraph 8 to Schedule 1A of MIR sets out that meters cannot be influenced by other devices and any hardware and software must be secured. This requirement will be applied to ESAs with remote displays. Furthermore, Regulations 16, 17 and 25 of the draft ESA Regulations provide that devices must have in-built protection against physical damage, unauthorised access and cyberattacks, including by compliance with ETSI EN 303 645.

e. Digital exclusion safeguards: The Government will work with industry to develop best practice in regard to the accessibility of remote displays. This will include making sure that devices are modelled in line with inclusive design principles (an example of this may be having a remote display / smartphone app that is screen reader compatible so it is accessible for those who are visually impaired).

69) These capture most of the concerns raised by industry and regulatory bodies, but we will continue to work with DESNZ and industry and monitor the implementation of the ESA Regulations to ensure a remote only option is introduced with robust safeguards.

Question 7: Timing

Q7A If MIR was updated to allow ESAs to have remote-only displays, when should this change take place? i.e., how long should businesses and consumers be given to prepare before this change takes effect legally?

• a) As soon as possible
• b) 12 months’ notice
• c) 24 months’ notice
• d) Other (please state)

Q7B Please provide reasons for your answer.

Q7 Summary of responses

70) Views on implementation timelines varied, with 58% favouring 12 months and 42% preferring longer adaptation periods. Industry respondents who were in favour of shorter notice periods explained that they already had the digital infrastructure ready to fully move to remote displays. In contrast, respondents who were in favour of longer notice periods needed more time to build the technological infrastructure to support remote displays, and currently did not prioritise remote interfaces, or have much experience with this way of providing services.

Q7 Government response

71) The Government will seek to lay an amending SI to MIR in 2026 that will come into force by the end of 2027. We consider that this will offer enough time for industry to adapt to the changes. The amendment to MIR will introduce the option for meters in ESAs to contain a remote-only display, increasing flexibility for manufacturers. Importantly, ESAs that contain a meter with a physical display will continue to meet the essential requirements of MIR, meaning manufacturers are not required to alter existing models that are already compliant with the current MIR requirements.

72) DBT will work with DESNZ to ensure the changes to MIR – which permit the remote display option – are in place before 1 January 2028 which is when the relevant part of the ESA regulations will come into force. This sequencing aims to ensure that ESAs in scope of the ESA Regulations can have either a physical or a remote meter display and must meet MIR class B requirements, including accuracy and conformity assessment.

Question 8: Other views on MIR and the EU’s proposed updates to the Measuring Instruments Directive

Q8 Is there anything else that you think the Government should be considering at this stage in respect of MIR, including whether to implement domestically any of the EU’s proposed updates to the Measuring Instruments Directive, as set out in the draft Targeted Technical Amendment?

Please provide reasons for your answer.

Q8 Summary of responses

Alignment with EU proposed TTA to the MID

73) In January 2025, the European Commission published draft proposals for a TTA to the MID. MID continues to apply in Northern Ireland (NI) by operation of the Windsor Framework, therefore, any future changes to MID will be implemented in NI.

74) The TTA proposes to update the MID to reflect technological advancements and support the EU’s green and digital transitions. It expands the scope of the MID to include new categories of devices, such as electric vehicle supply equipment (EVSE), compressed gas dispensers (including hydrogen), thermal energy meters for cooling (e.g. air conditioning units), and direct current (DC) meters such as those used in EV fast charge points. It also modernises requirements for smart electricity and gas meters, including the option for remote-only displays.

75) Industry respondents mentioned that by permitting a remote display option for ESAs, this would align the MIR in GB with the EU’s proposed TTA to the MID. In due course, this would mean remote-only displays for ESAs would be permitted in two different markets, supporting business growth and easing trade barriers.

76) The TTA goes further than the Government’s current proposal. While our consultation focused on specifically changing the physical, in-built display requirement for ESAs, the EU plans to extend this to allow remote-only configurations for utility meters as well.

77) We expect the final version of the TTA to be published at some point in 2026. Industry has stated that alignment between the MIR and MID would simplify compliance for manufacturers operating across both markets, reduce design complexity, and eliminate the need for separate hardware variants, enabling more efficient product development and trade. Respondents also suggested that alignment would support business growth and would reduce administrative burdens, as they will be able to supply the same product to both the GB and EU markets.

Heat pumps

78) Some Industry respondents noted that heat pumps operate under variable conditions, measuring thermal rather than electrical energy. Their dynamic behaviour and the use of Heat Cost Allocators could make uniform metering standards for all ESAs impractical. To prevent costly retrofits and delays for key decarbonisation technologies, industry said flexible, device-specific standards are needed to ensure accuracy and compliance. Industry said that a more flexible, device-specific approach is needed to ensure accuracy and feasibility without imposing excessive costs or delays.

Electromagnetic compatibility

79) One stakeholder asked the Government to consider electromagnetic compatibility (EMC) testing requirements and particularly how they relate to international standards. Another suggested that the different electromagnetic compatibility requirements between the EMC Directive and the MID [S(1] caused unnecessary duplication. Careful evaluation of real-world installation contexts is needed to ensure appropriate EMC compliance.

DC metering

80) Additionally, some respondents mentioned complications around DC metering, especially in emerging use cases involving co-located photovoltaic (PV) and Battery Energy Storage Systems (BESS). These setups often share an inverter but require separate metering on the DC side for operational and commercial reasons, such as subsidy eligibility for PV and ancillary service participation for BESS. The Government recognises that it may in future consider bringing DC Meters explicitly in scope of MIR, as the EU proposes to do in the MID via the TTA, as accommodating DC metering within regulatory frameworks will be essential for supporting flexible and future-ready energy infrastructure.

Q8 Government response

81) The Government welcomes the views from respondents and stakeholders on the broader regulatory landscape between GB and the EU and acknowledges several key areas were raised in response to this question.

82) The Government recognises that the EU’s TTA is yet to be published so is subject to change. Once the TTA is published and the Government has had the opportunity to consider the finalised proposals, DBT will consult to ensure stakeholder input is sought to consider potential amendments to MIR and explore any implications for the UK. It is also important to highlight that, through the PRAM Act, the Government now has the powers to amend UK product safety and metrology legislation previously derived from EU law -another significant step forward and a demonstration of our ability to act quickly on priority issues.

83) The Government will continue to monitor developments in the EU. The Government remains committed to considering the broader proposal presented within the EU’s TTA of the MID and will consider whether similar provisions may be appropriate for the GB market going forward, particularly if this reduces burdens to businesses who are operating in both markets.

Next steps

1. The Government has decided to amend the essential requirements in MIR to permit the use of a metrologically controlled remote display for ESAs. The Government proposes that these changes to MIR will come into force at the end of 2027.

2. To implement this change the Government will lay a Statutory Instrument (SI) in 2026. This will enable the option of remote-only displays for meters within new ESAs, including EVSCPs, and also facilitate the use of a remote display for public EV charge points, subject to further stakeholder engagement.

3. ESAs must comply with all relevant regulations before being placed on the market in Great Britain. This will include any obligations placed on ESA importers and manufacturers by the Regulations which DESNZ is currently consulting on.

4. DESNZ’s proposal is that ESAs in scope of the Phase 1 Regulations must meet all of the MIR requirements imposed on class B active electrical energy meters. ^{[footnote 7]} This will include all active electrical energy meters within ESAs in scope of the regulations needing to undergo conformity assessment and be conformity marked, to ensure accuracy for consumer payments under Consumer-Led Flexibility (CLF).

5. DBT will work with DESNZ to ensure alignment between changes to MIR and the application of all MIR class B requirements to ESAs in the Energy Smart Appliances (ESA) Phase 1 Regulations. DBT will work to ensure its amendments to MIR come into force before regulation 14 of the ESA Regulations 2026 comes into force, and that the cross-reference to MIR within the ESA Regulations 2026 includes the remote display option, rather than the previous requirement for a physical, in-built display.

6. OPSS will enforce both MIR and the ESA Regulations when the changes come into force, in accordance with its proportionate, risk-based Enforcement Policy.

7. This reform supports the Government’s strategic objectives to drive economic growth, reduce costs for business and consumers and to fulfil the UK’s net zero commitments by increasing access to Consumer-Led Flexibility energy supply services and improving stability of the national grid. The Government will continue to apply an enforcement approach that supports delivery of these wider policy objectives.

8. The territorial scope for the proposed legislation is Great Britain (GB). Whilst MIR is reserved, electricity supply, transmission and distribution are devolved to the NI Executive (NIE). NI also operates a separate electricity grid from that of GB, therefore, the NIE could make changes regarding its energy policy independently from the rest of GB. Any revision to MIR in NI, by the UK Government, would need to be consistent with obligations under the Windsor Framework. Given that the Government’s proposed changes to MIR align with the EU’s intended updates to MID, this will help support and preserve the functioning of the UK Internal Market (UKIM).

9. The Government is keen to reduce regulatory and administrative burdens for businesses trading UK-EU. DBT and DESNZ will continue to monitor international developments in this space, including the EU’s TTA and wider revisions to the EU’s Measuring Instruments Directive (MID), and will consult with industry and stakeholders on whether to make further changes to UK legislation on measuring instruments in due course, particularly where they support UK economic growth and promote regulatory simplicity.

Footnotes

1. Paragraph 10.5 of Schedule 1A. ↩

2. As defined by section 7 of the Weights and Measures Act 1985. ↩

3. This includes EVSCP, ESA and heat pump manufacturers, flexibility service providers and electricity suppliers. ↩

4. Clean Flexibility Roadmap, July 2025 Mapping the path to a clean, flexible, consumer-focused electricity system ↩

5. UK Mobile Phone Statistics 2025 – Uswitch website ↩

6. In-Service Testing (IST) is a program testing the accuracy of meters currently in use. ↩

7. ESA Regulation 14 will apply MIR regulations 46 to 52B and Schedules 1A, 1B, 1E and 1K to all ESAs in scope. ↩