Open consultation

National Underground Asset Register tranche 1: regulations

Published 6 August 2025

Applies to England, Northern Ireland and Wales

About this consultation

Why we are consulting 

The Data (Use and Access) Act 2025 (“the 2025 Act”) which received Royal Assent on 19 June 2025 introduces measures to allow the National Underground Asset Register (NUAR) to operate as a statutory register. It does this by updating the New Roads and Street Works Act 1991 (“the 1991 Act”) and the Street Works (Northern Ireland) Order 1995 (“the 1995 Order”).   

The NUAR measures contained in the 2025 Act will be implemented by regulations introduced in at least 2 tranches. The initial tranche of NUAR regulations, which parts 1-3 of this consultation will inform the development of, is intended to cover: 

• The requirement for undertakers who own apparatus in the street to take a snapshot of information they hold on their apparatus as of a specified date, and upload this to NUAR within a specified period ^{[footnote 1]}

• The requirement for undertakers to record additional information about in-street apparatus when installing, maintaining, repairing or otherwise interacting with it  ^{[footnote 2]}

• The requirement for undertakers to ensure the information held in NUAR about their in-street apparatus remains up to date, by uploading to NUAR any new or amended information about their apparatus within a specified period of it changing e.g., after installing, maintaining, repairing or otherwise interacting with it ^{[footnote 3]}

• How access to information held in NUAR will be provided to undertakers and authorised contractors working on behalf of these undertakers for the purposes of carrying out street works in England, Wales and Northern Ireland^{[footnote 4]}

Stakeholders, particularly undertakers required to upload information to NUAR and those accessing information through the service are therefore encouraged to share their views on these topics via parts 1-3 of this consultation.  

The initial tranche will be followed by a second tranche of regulations which will include provisions under section 106E(1) of the 1991 Act and article 45E(1) of the 1995 Order as amended by the 2025 Act, to establish a fee structure to recover the operating costs of NUAR from undertakers.  

Part 4 of this consultation introduces an overview of proposals for this fee structure. A subsequent consultation to seek detailed views in relation to the second tranche of regulations will be launched when appropriate (currently this is expected to take place during 2027).  

In addition to the regulations specified above, there may be further regulations which: 

a. Implement the findings of ongoing discovery work into providing access to information held in NUAR (under section 106C and article 45C) for additional use cases, to other user groups, or through channels other than the existing NUAR user interface. More information about this work can be found in our recent blog, and 

b. Establish requirements for those carrying out works in the street to report missing or incorrect information to the undertaker regarding their apparatus under the amended section 80 of the 1991 Act and article 40 of the 1995 Order. Regulations made regarding section 80 or article 40, if any, will be subject to a subsequent consultation. 

Issued:  Wednesday 6 August 2025

Respond by: Wednesday 15 October 2025

Enquiries (including requests for the paper in an alternative format) to: 

Email: nuarpolicy@dsit.gov.uk 

NUAR Policy
Geospatial - Government Digital Service
Department for Science, Innovation and Technology
100 Parliament Street
London
SW1A 2BQ
United Kingdom
 

Consultation reference: NUAR Regulations: Information recording, upload, and access  

Audiences: This consultation primarily serves to understand the nature and potential impact of the proposed NUAR regulations on undertakers. As such, we encourage undertakers who own apparatus in the street (“undertakers”) to respond to this consultation, including: 

• Undertakers – Including those across the utilities sector currently supplying asset information to enable street works under section 79 of the 1991 Act.  

• Highway authorities 

• Local authorities  

• Devolved government and authorities 

We are also keen to understand the potential impact of these on the wider street works sector. As such representatives from the following stakeholder groups are encouraged to respond to Questions 1, 2, 5, 6, 7, 8, 9, and 10 of this consultation, as well as any other questions that may be of interest: 

• Trade associations 

• Professional bodies

• Other organisations operating in any of the following sub-sectors: 
  • Construction
  • Environmental Agencies
  • Health and Safety
  • Asset Management

• National resilience planners  

• Regulators 

• Other interested organisations, academics or members of the public – including any other current users of the NUAR platform not covered by the above. 

Territorial extent: 

The geographical scope of this consultation is England, Wales, and Northern Ireland.  

The relevant legislation for England and Wales is the New Roads and Street Works Act 1991, as amended by the Data (Use and Access) Act 2025. 

The relevant legislation for Northern Ireland is the Street Works (Northern Ireland) Order 1995, as amended by the Data (Use and Access) Act 2025. 

How to respond: submit your online responses through the form.

Or if you are unable to reply online responses and any additional material you wish to be considered should be submitted via email or post to the relevant address below. Responses or material sent to any other email or postal addresses will not be included in our consideration of consultation responses. We would encourage submissions of over 6 pages to be accompanied by an executive summary. 

Email to: nuarpolicy@dsit.gov.uk 

Write to: 

NUAR Policy
Geospatial - Government Digital Service
Department for Science, Innovation and Technology
100 Parliament Street
London
SW1A 2BQ
United Kingdom
 

Considerations for responses: 

This consultation is intended to be an entirely written exercise. Please contact the enquiries mailbox if you require any other format, e.g. braille or large font. 

When responding, please state whether you are responding as an individual or representing the views of an organisation. 

The questions in this consultation have been targeted to gather the key information to inform the implementation of these regulations. As such, your response will be most useful if it is framed in direct response to the questions posed. For questions which encourage more general feedback, views which relate to the following areas will be particularly helpful in shaping our policy, though further comments and evidence are also welcome: 

•  The potential impact of these regulations on those carrying out street works – in considering this please give thought to the impact of safety as well as operational efficiency. 

• The potential impact of these regulations on your organisation - in considering this please give thought to both negative and positive impacts. 

• The ability of organisations to comply with the requirements set out in these regulations. 

Confidentiality and data protection: 

Copies of the responses not designated as confidential may be published after the closing date on the DSIT website.

Further, information provided in response to this consultation, including personal data, may be published or disclosed in accordance with the access to information regimes (these are primarily the Freedom of Information Act 2000 (FOIA), the Data Protection Act 2018 and the UK General Data Protection Regulation, and the Environmental Information Regulations 2004).  

If you want the information that you provide to be treated as confidential, please be aware that, as a public authority, the Department for Science, Innovation and Technology is bound by various statutory obligations, including under the FOIA, and may therefore be obliged to disclose all or some of the information you provide. In view of this it would be helpful if you could explain to us why you regard the information you have provided as confidential. If we receive a request for disclosure of the information, we will take full account of your explanation, but we cannot give an assurance that confidentiality can be maintained in all circumstances. An automatic confidentiality disclaimer generated by your IT system will not, of itself, be regarded as binding on the Department.  

The Department for Science, Innovation and Technology will process your personal data in accordance with the law and in the majority of circumstances this will mean that your personal data will not be disclosed to third parties. Read the full National Underground Asset Register tranche 1 regulations: privacy notice to find out how it stores, processes and shares your personal information.

Quality assurance:  

The regulations set out in this document have the opportunity to transform how the street works sector accesses the information needed to carry out their works. As such we remain committed to ensuring the sector has the opportunity to provide views on their implementation. A Ministerial commitment to consult with industry in the development of these regulations was made during the passage of the Data (Use and Access) Act 2025. This consultation fulfils that commitment and has been carried out in accordance with the government’s consultation principles.  

If you have any complaints about the way this consultation has been conducted, please email: betterregulation@dsit.gov.uk 

Response: The government’s response to this consultation will be published on GOV.UK.

Definitions 

Below we have defined a number of terms used frequently in this document and in the 2025 Act. 

1991 Act: Refers to the New Roads and Street Works Act 1991 which is amended by the Data (Use and Access) Act 2025. This Act establishes the legal framework for street works in England and Wales. 

Provisions within an Act are referred to as “sections” 

1995 Order: Refers to the Street Works (Northern Ireland) order which is amended by the Data (Use and Access Act 2025. This Order establishes the legal framework for street works in Northern Ireland and contains equivalent provision for Northern Ireland. 

Provisions within an Order are referred to as “articles” 

Apparatus: Defined in the 1991 Act and 1995 Order as - A sewer, drain or tunnel or any structure for the lodging therein of apparatus or for gaining access to apparatus.  

In practice this include physical infrastructure that conveys commodities and provides services, this includes any structure for lodging therein of apparatus or for gaining access to apparatus or accessories for providing protection, support and monitoring.  

Data (Use and Access) Act 2025: Legislation which, among other things, amends the 1991 Act and 1995 Order.   

Raster data: A geospatial format represented as a grid of pixels, with each pixel denoting a geographic attribute like elevation or the presence/absence of an asset. Each pixel is georeferenced to a specific location.  

Safe dig: A practice and approach aligned with Health and Safety Guidance 47 (HSG47)6, aimed at reducing accidental strikes on underground assets to ensure the safety of workers and minimise operational disruptions while working in the vicinity of buried apparatus.  

Undertakers: Defined in the 1991 Act and 1995 Order as – A person by whom relevant statutory right is exercisable or the licensee under the relevant street works licence  

In practice this includes organisations or entities responsible for maintaining and operating infrastructure, particularly in relation to street works and utility services.  

Vector data: A geospatial data type which comprises of points, lines, and polygons recorded against a specified coordinate reference system

Executive Summary

This consultation aims to gather views on an initial tranche of regulations to implement some of the measures established in the Data (Use and Access) Act 2025, which relate to the National Underground Asset Register (NUAR). NUAR is a government digital service designed to provide instant, secure access to information about apparatus in the street (for example, pipes and cables), to improve the safety of operatives working in the vicinity of these apparatus and to improve the efficiency of street works across England, Wales, and Northern Ireland. 

NUAR is being delivered by the Government Digital Service (GDS) in collaboration with the Ordnance Survey (OS), building on OS’ role as the UK’s national mapping agency. The service enables authorised users to access a comprehensive map of in-street pipes and cables, and will ultimately integrate data from over 600 gas, water, electric, telecommunications companies, and local authorities. This innovative approach addresses critical challenges, including the reduction of accidental strikes on apparatus in the street –estimated to number 60,000 per year, at an economic cost of £2.4 billion annually. 

The NUAR measures under the Data (Use and Access) Act 2025 amend the New Roads and Street Works Act 1991 and the Street Works (Northern Ireland) Order 1995. These measures introduce provision for NUAR to operate as a statutory register across England, Wales and Northern Ireland. The implementation of these measures will occur through secondary legislation in, at least, 2 tranches. 

The initial tranche of NUAR regulations, as covered in Parts 1-3 of this consultation, will update existing duties and introduce new requirements on undertakers who own and maintain apparatus in the street to keep records of specified information about their apparatus. 

The regulations will implement a new minimum information specification to ensure that a comprehensive baseline of the necessary information to inform street works is collected moving forwards. The regulations will establish requirements for undertakers to upload information about their apparatus to NUAR and ensure that this remains up to date whenever changes occur, for example during installation or maintenance. To ensure this information is made available for the purposes of street works excavation, the regulations would grant access to information held in NUAR for undertakers and authorised contractors working on their behalf in England, Wales, and Northern Ireland. These regulations are necessary to ensure NUAR has comprehensive and up to date information to support those undertaking street works to carry out their work safely and efficiently. 

The closing date for responses is Wednesday 15 October 2025.

Background

The National Underground Asset Register (NUAR) was established in 2018 by the Geospatial Commission, moving from pilot phase in 2019 to ‘minimum viable product’ in 2023 and ‘public beta’ in 2025.  

In January 2025, the Geospatial Commission, alongside the Central Digital and Data Office (CDDO), the Government Digital Service (GDS) and the Incubator for Artificial Intelligence (i.AI), merged to create the new Government Digital Service - the digital centre of government – bolstering Government’s capacity to drive forward the use of geospatial data to address significant national challenges.  

As part of this function GDS has taken on responsibility for NUAR. GDS is responsible for policy and performance oversight of the service while operational aspects of NUAR are being delivered by partners in the Ordnance Survey as part of their function as the UK’s national mapping agency.  

The problem 

There are around 4 million kilometres of underground pipes and cables in the UK, and an estimated 60,000 accidental strikes on these apparatus every year – costing the UK economy £2.4 billion per annum and putting workers’ safety and lives at risk.  

As part of existing safe dig working practice as established in HSG47 (Health and Safety Guide 47) workers must currently request and collate information about apparatus in the street from multiple organisations, a process which takes over 6 days on average. 

About NUAR 

The National Underground Asset Register (NUAR) is a new government digital service providing secure access to a map of the apparatus (e.g., pipes and cables) in the street for authorised users in England, Wales and Northern Ireland.  

With NUAR, undertakers and authorised contractors working on their behalf can get that information instantly, any time of the day, any day of the year. This means planners and excavators get access to the information they need, when they need it, to carry out their work effectively and safely. 

NUAR provides secure access to information from undertakers across the public and private sectors. These will include over 600 gas, water, electric and telecommunications companies and local authorities. 

Industry has been pivotal in the delivery of NUAR to date and this collaboration with the sector is reflected in the large number of undertakers voluntarily sharing information about their in-street apparatus through the service so far. Because of this success NUAR has recently moved to public beta which means that NUAR can be used as part of safe digging by eligible users as per HSG47, with responsibility for deciding on how, when and if NUAR is used for these purposes remaining with those carrying out excavations.

However, legislation is required to allow NUAR to become a comprehensive and sustainable service. As such, implementation of the regulatory framework established by the Data (Use and Access) Act is required. 

Legislative context 

The recording and sharing of information on apparatus in the street is currently legislated for in England and Wales by the New Roads and Street Works Act 1991 (“the 1991 Act”) and for Northern Ireland by equivalent provisions in the Street Works (Northern Ireland) Order 1995 (“the 1995 Order”). This legislation requires, amongst other things, undertakers to record and share information about their apparatus in the street to support safe excavations free of charge.  

However, the above legislation does not specify how or when information should be shared, meaning it is shared and received in different formats, levels of quality and timescales. The result is that currently excavators must collect information from 6 to 10 organisations, which takes on average 6.1 days to collect the information required to inform an excavation.   

The 1991 Act and the 1995 Order have been updated by the Data (Use and Access) Act 2025 (“the 2025 Act”). The contents of the 2025 Act are available to view on the UK Parliament website. Further context of the measures included can be found in the explanatory notes  which accompany the 2025 Act. To summarise, the NUAR measures under the 2025 Act seek to achieve 5 key aims, they:  

• Require undertakers to upload information about their apparatus in the street into NUAR in a specified form and manner,  necessary to ensure NUAR delivers comprehensive data to enhance worker safety and improve efficiencies  

• Set out a scheme under which the undertakers will be required to pay fees to fund the running cost of NUAR  

• Establish enforcement mechanisms to apply to undertakers who do not comply with the above requirements  

• Allow the Secretary of State to make provisions for, or in connection with, granting licenses in relation to any copyright, database right or other intellectual property right which is not owned by the Crown  

• Allow the Secretary of State to enter into arrangements with one or more persons to exercise certain functions of the Secretary of State, with such persons prescribed in the regulation, to enable NUAR to be operated efficiently as an enduring service

The consultation covers the following aspects on the NUAR measures contained in the 2025 Act:

Consultation Part	Questions included	1991 Act Section	1995 Order Article	Description
1	Yes	106B(1)	45B(1)	Initial upload of information into NUAR
2	Yes	79(1B)	39(1B)	What information must undertakers record about their in-street apparatus
2	Yes	79(3B)	39(3B)	Duties in relation to uploading information into NUAR on an as it changes
3	Yes	106C	45C	Access to information kept in NUAR
4	No	106E	45E	Fees payable by undertakes in relation to NUAR

Respondent Profile and Background

Q1. What type of organisation are you?

a.Utilities Company,

b.Highways authority,

c.Local authority,

d.Devolved Government,

e.Contractor organisation carrying out street works,

f.Professional body,

g.Trade association,

h.Regulator,

i.None of the above

Q2.Is your organisation:

a. Already onboarded to the NUAR service

b. Not currently using the NUAR service

c. None of the above

Q3. Complete this question if you answered ‘none of the above’ to the previous 2 questions. Describe your organisation type and current level of involvement with the programme. (optional)

Q4. Provide your organisation’s name if you are responding on behalf of an organisation:

Q5. Are you responding on behalf of a small or micro business?

a. Yes

b. No

Part 1 - The initial upload of information to NUAR

Relevant section(s) of the 1991 Act and the 1995 Order – Section 106B and article 45B

1.1 Legislative context 

Currently, information about apparatus in the street is recorded and shared under sections 79(1) and 79(3) respectively of the 1991 Act (for England and Wales) and articles 39(1) and 39(3) respectively of the 1995 Order (for Northern Ireland).  

Section 79(1) and article 39(3) require undertakers to collect information about the location, nature, and (if known) whether the apparatus is in use. 

Section 79(3) and article 39(3) require undertakers to make the information recorded under s.79(1) and a.39(3) available for inspection at all reasonable hours, free of charge by any person having authority to execute works in the street or other persons appearing to the undertaker to have sufficient interest. Together, these requirements ensure that those carrying out street works have access to information about apparatus in the street as part of their safe working practices under Health and Safety Guidance 47 (HSG47).  

NUAR is already streamlining this process: it provides instant access to a map of the apparatus in the streets across England, Wales and Northern Ireland for authorised users, with over 300 undertakers already sharing their information on a voluntary basis. To allow NUAR to operate as a comprehensive standardised register of this information, it is necessary to implement a legal requirement for undertakers to share information with NUAR.

The first step in this process is for undertakers to upload the information they currently hold about their apparatus under their section 79(1) and article 39(1) requirements into NUAR. Part 1 of this consultation will focus on this initial upload, as set out under section 106B(1) and article 45B(1). (Following this there will be a requirement to “refresh” this information as and when it changes – covered in more detail in part 2 of this consultation).  

Section 106B(1) and article 45B(1) introduce requirements for undertakers to take a snapshot of information they hold about their in-street apparatus on a specified “archive upload date”. After the archive upload date the undertaker will have a specified initial upload period within which they must upload the information held at that date. Regulations under this provision will ensure that the information held in NUAR is reflective of the records they hold in relation to their apparatus ^{[footnote 5]}. The intention of this approach is to ensure that by a set date the information held in NUAR about an undertakers in-street apparatus accurately reflects the undertakers’ own records on that date, while allowing sufficient time for them to achieve this.

1.2 Regulation making powers 

Regulations under section/article 106B/45B, which provides for the initial upload of information to NUAR, may include provision for: 

106B/45B (1)(b) – Any additional information that is to be uploaded, in addition to that held under section 79(1) and article 39(1)

106B/45B (2) – Any cases where the requirement to upload information under 106B/45B do not apply. 

106B/45B (3) – How this information should be uploaded (including the form and manner) 

106B/45B (8)(a) – The date of the archive upload data 

106B/45B (8)(b) – The duration of the initial upload period 

It is anticipated that any additional information requirements established under 106B(1)(b) will be limited to administrative information that is necessary to onboard the undertaker to NUAR (for example this may include the contact details for a responsible party within the organisation). Since this information will be limited in scope and only collected where necessary to operate the NUAR service effectively it will not be covered in this consultation. 

Regulations regarding how information should be uploaded to NUAR, and any exemptions to this requirement should align as closely as practical with the requirements set out in Part 2 of this consultation. Questions relating to these 2 topics are considered in Part 2.  

This section seeks feedback in relation to the timings for the initial upload of information to NUAR.

1.3 Timings for the initial upload of information into NUAR 

For the requirement to complete an initial upload of information to NUAR ^{[footnote 6]} a period of 12 months is proposed. This is to allow sufficient time for undertakers to work with the NUAR onboarding team: support@nuar.uk to ensure that their information is transformed and ingested into the NUAR platform, and that any challenges experienced can be worked through in good time.  

To allow time for parliamentary passage of proposed secondary legislation the archive upload date which starts this upload period is unlikely to begin before spring 2026 at the earliest. As such the requirements set out in this part are unlikely to be enforced before spring 2027 at the earliest.

Q6.Please indicate your view regarding the following statement: The proposed initial upload period of 12 months provides sufficient time for my organisation to upload the specified information to NUAR.

a. Strongly agree

b. Agree

c. Neither agree nor disagree

d. Disagree

e. Strongly disagree

f. NA

Q7.If you don’t agree that 12 months is sufficient time for your organisation to upload the information to NUAR, why is this and what do you think can be done to address these factors? (optional)

Part 2 - Keeping information in NUAR up to date

Relevant section(s) of the 1991 Act and the 1995 Order – Sections 79(1B) and (3B) and articles 39(1B) and 39(3B)

2.1 Legislative context 

After NUAR has been populated with information under the requirements set out in part 1 of this consultation, the information must be kept up to date as and when it changes, for example, through the installation of new apparatus or the maintenance of existing apparatus.  

There are 2 key aspects to this requirement, as set out under new sections 79(1B) and (3B) of the 1991 Act and article 39(1B) and (3B) of the 1995 Order, as amended by the 2025 Act. This part sets out the government’s proposal for the regulations to implement these new requirements. 

Section 79(1B) and article 39(1B) relate to the recording of information about in-street apparatus. Current information recorded about in-street apparatus is of varying quality and completeness. Prior to the introduction of these new sections by the 2025 Act, the 1991 Act and the 1995 Order contained requirements under section 79(1) and article 39(1) respectively which require undertakers to record information about their apparatus’ location, nature, and (if known) if the apparatus is in operation.  

For NUAR to operate effectively and enable those carrying out street works to operate safely, it is necessary to ensure that a minimum baseline standard of information is recorded which is sufficient to inform their operations in line with the existing industry guidance (HSG47). To enable this, new section 79(1B) and article 39(1B) have been inserted into the 1991 Act by the 2025 Act to allow for additional information beyond that are already required to be recorded under section 79(1) of the 1991 and Article 39(1) of 1995 to be specified in regulations. 

To clarify, the requirement to upload this additional specified information with NUAR will not apply to the duties set out in part 1 of this consultation. As such undertakers would not be penalised for not having recorded this information historically.

The second requirement is introduced under section 79(3B) of the 1991 Act and article 39(3B) of the 1995 Order. This establishes that undertakers must refresh the information held in NUAR about their apparatus within a specified period of it changing after their own records become updated by the requirements established by sections 79(1) and (1B), and articles 39(1) and (1B).^{[footnote 7]}

2.2 Regulation making powers 

Part 2 of this consultation sets out the government’s proposal for the regulations to implement section 79(1B) and article 39(1B), as well as section 79(3B) and article 39(3B) of the 2025 Act and includes questions for consultees to answer.

Regulations under section/article 79/39 may include provision for: 

79/39 (1B) – What information must be recorded about apparatus. 

79/39 (1B) – Exemptions to the requirement to record information.  

79/39 (3B) – Exemptions to the requirement to upload information to NUAR. 

79/39 (3B) – Length of the period, within which, the undertaker must upload updated information to NUAR. 

79/39 (3C) – How the information should be uploaded to NUAR, including form and manner.

This part of the consultation is broken down into 4 sections  

1. The first section considers what information should be recorded about apparatus under the s.79(1B) and a.39(1B) requirements. 

2. The second section considers the time frames within which apparatus information is to be uploaded.  

3. The third section considers the form and manner in which this information is required to be uploaded.  

4. The fourth section considers the exemptions to the duty to upload information under sections 79(1B) and 79(3B) respectively.

2.3. What information must be recorded 

It is acknowledged that for different sectors the relevant information to record with regard to apparatus may vary. As such it is proposed that the following information must be recorded as a minimum standard by all undertakers. 

NUAR Minimum Information Specification

• Asset ID - This an identifier assigned uniquely to an item of apparatus by an undertaker. It should be as stable and persistent as possible relative to that particular physical apparatus or defined region.  

• Asset owner - Name / identity of the undertaker responsible for the apparatus. 

• Business contact - Contact information (telephone number or email address) for the apparatus’ responsible party. 

• Emergency contact (if applicable) - Contact information (telephone number or email address) to reach the responsible party in the event of an emergency involving this apparatus.  

• Horizontal Coordinate Reference System - Coordinate system, datum, and epoch date (if applicable) associated with the X and Y coordinates.  

• Asset type/subtype - An indication of the type or subtype of apparatus. A list of acceptable values will be provided to improve consistency.

In addition to this minimum standard, it may be appropriate for undertakers to record additional information (as set out below) to ensure both the apparatus and those operating in its vicinity are protected. There will not be a legal requirement to upload this information to NUAR, as we consider that this requirement may be too onerous for some sectors. However, its inclusion is strongly encouraged for undertakers operating apparatus which pose a significant risk injury or loss of life through strikes.

NUAR Desirable Information Specification

• Commodity type - An indication of the commodity being conveyed by the apparatus. 

• Category Tier - An indication of the “Tier” to which an apparatus belongs. This will vary by sector and apparatus type (e.g. Voltage Level, Pressure Tier etc)  

• Material - May include the material of carrier or protective features as well as “core” apparatus. This attribute may only be appropriate for certain apparatus, and where the inclusion of this information poses a risk to the security of the apparatus it should not be included. 

• Size - This may be as simple as a single internal diameter value for a pipe, or each dimension (width, length, height) may be required for non-circular apparatus. Unit of measurement should always be recorded, and the dimension being measured should be specified if appropriate, even if as a convention for all apparatus (e.g. internal diameter, external diameter etc).  

• Depth/elevation - Where possible, the depth relative to the surface (alongside unit of measure) as well as elevation relative to datum if possible (may be a “Z” value of the geometry).  

• Currency - The date of installation of the apparatus, plus information about when the apparatus was last surveyed/measured/captured/updated.  

• Protection method - Any protection deployed for the apparatus (e.g. slabbing, tape etc)  

• Quality/accuracy - If possible, it is useful to record information related to the quality and accuracy of data

Q8. ‘The ‘minimum information specification’, set out in the consultation document, offers enough detail to cover street works excavation.

a. Strongly agree

b. Agree

c. Neither agree nor disagree

d. Disagree

e. Strongly disagree  

f. NA

Q9. Select any additional fields or types of information you would want to include in the minimum standard for apparatus data collection.

a. Category Tier

b. Material

c. Size

d. Depth/elevation

e. Currency

f. Protection method

g. Quality/accuracy

h.Other

i. No additional fields

Q10. If ‘Other’, provide details of the fields or types of information you would want to include in the minimum standard for apparatus data collection (optional) 

Q11. If you agree that the ‘minimum information specification’ should either remain as proposed or expand to include additional fields, explain why. (optional) 

This question relates to the proposals set out in Part 2 of the NUAR Tranche 1 consultation document. If, in the previous questions, you selected to include additional fields, please explain the benefits to including this information in the minimum specification. If you did not select to include additional fields please explain, why and any challenges around implementation.

Q12. Select potential challenges for you or your organisation when meeting the minimum information specification: 

a. Technical challenges of implementing new data collection process in the field

b. Resource demands of implementing new data collection processes in the field

c. Updating existing data systems

d. Ensuring the protection and security of sensitive information during the upload process

e. Compliance within the proposed timelines

f. Other

g. No challenges anticipated

Q13. If “Other”, describe the potential challenges you and your organisation anticipate when meeting the minimum information specification (optional).

Q14.In your opinion, are there any apparatus types that might be particularly affected by the proposed information specifications set out in this part?. How will they be affected and what considerations should be made?

2.4 Timing for uploading information to NUAR 

The length of time between an undertaker’s records being updated with new or amended information, and the information in NUAR being updated, is important since it will drive the currency of information in NUAR – critical for informing the safety of street works. Regulations made under section 79(3B) and article 39(3B) may establish the length of this “refresh” period.

The following refresh periods are under consideration: 

• A minimum refresh frequency of 28 days is proposed for apparatus that risk injury or loss of life through strikes. For apparatus which if struck would have the highest impact, a more frequent refresh may be appropriate although this would remain at the discretion of the undertaker to ensure their apparatus, and those working in their vicinity, receive the maximum level of protection.  

• For apparatus which do not risk injury or loss of life through strikes a quarterly refresh is proposed as a minimum.

The sector will be engaged in due course to establish what constitutes higher impact apparatus information.

Q15. When updating higher impact information in NUAR, the regulations propose a minimum refresh frequency of 28 days. Does this timeframe create any challenges for your organisation? (optional)

Q16. Do you have any other comments on the proposed refresh periods? (optional)

2.5 Mechanism for uploading information to NUAR 

For information to be presented in the NUAR user interface, it needs to be ingested into the NUAR data model (for more information about this please see our blog post). Before the information can be ingested it needs to be transformed into a compatible format. Regulations under sections 106B(1) and 79(3B) of the 1991 Act, and articles 45B(1) and 39(3B) under the 1995 Order may specify the form and manner in which information is to be uploaded to NUAR. 

To allow this upload to happen efficiently and minimise the impact of these regulations on those required to upload information to NUAR, the intention is to continue to provide a free at the point of use data transformation service for the duration of the initial upload period^{[footnote 8]} . The NUAR data transformation and ingestion service will accept information uploaded in a vectorised spatial format ^{[footnote 9]} and transform this into a format which complies with the NUAR data model.

Q17. In what data format(s) is your in-street apparatus data currently stored?  

a. Vectorised data in a standard geospatial format (e.g.,GeoPackage) 

b. Raster data in a standard geospatial format (e.g., GeoTIFF) 

c. PDF files 

d. Non-digitised format (e.g., paper records) 

e. Other

Q18. If ‘Other’, specify the data format(s) your in-street apparatus data is currently stored in (optional).

Q19. What activities would your organisation need to undertake or procure in order to  vectorise the information you hold in relation to your in-street apparatus, including legacy information? 

a. No action needed 

b. Increasing capability - Including technical assistance with vectorising data

c. Increasing capacity – Including access to necessary compute resources 

d. Procurement of data transformation 

e. Training for staff

f. Other

Q20. If you selected “Other” in the previous question specify what activities would your organisation need to take or procure?

Q21. Do you have any further comments about the proposal to use vectorised information or to continue the period of free data transformation for the initial upload period? (optional)

The NUAR data transformation and ingestion service accepts information uploaded in any vectorised spatial format. This service is currently free of charge.

2.6 Exemptions to uploading information to NUAR 

The NUAR provisions provide the scope for some exemptions to the requirement to share apparatus information with NUAR, both during the initial upload period and during the regular refresh. Even a single pipe or cable can cause serious injury or death if hit by mistake, including apparatus designated as sensitive in nature. Accidental strikes also disrupt services to businesses and residents. As such, it is important that NUAR holds comprehensive information to ensure that street works undertakers can carry out their works safely.  

However, we acknowledge in some cases it is not appropriate or necessary to collect and share information about apparatus. As such, we intend to consider exemptions on national security grounds for apparatus located within: 

a. Prohibited places – as defined under the National Security Act 2023

b. Designated sites – as defined under s.128 of the Serious Organised Crime and Police Act 2005 (SOCPA) 

And also, in circumstances where: 

c. The Secretary of State reasonably considers it necessary to do so in order to protect the safety and interests of the United Kingdom. 

With the exception of prohibited places, there are currently no proposed exemptions to the requirement to record information under section 79(1B) or article 39(1B), or the requirement to upload information with NUAR under section 79(3B)  or Article 39(3B), or to the initial upload of information under s.106B (as set out in part 1 of this consultation).  

Our approach to ensuring NUAR only holds the necessary information is as follows: 

1. The minimum information specification limits the need to share some fields which may be considered sensitive ^{[footnote 10]} e.g., Category tier, diameter or material. 

2. If, based on this consultation the minimum information specification is expanded to include information which could be considered sensitive we will engage with relevant stakeholders to consider how this information could be collected in an appropriate way e.g., diameter of pipe might be recorded in bands as opposed to precise values. 

3. Undertakers will be able to control what is seen about their apparatus data through the user interface. This means that information about a sensitive apparatus could be obscured from view, instead a sensitive zone would be illustrated with instructions to contact the relevant undertaker for further information.

Q22. Exemptions to the requirement to share apparatus information with NUAR should be considered. 

a. Strongly agree

b. Agree

c. Neither agree nor disagree

d. Disagree

e. Strongly disagree

f. NA

Q23. Specify the exemptions you think should be permitted and why? (optional)

Part 3 - Access to information held in NUAR: DUA section 106C(1)/45C(1)

Access to information held in NUAR will be enabled under section 106C of the 1991 Act and article 45C of the 1995 Order as amended by the 2025 Act.

3.1 Legislative context 

Currently under section 79(3) of the 1991 Act and article 39(3) of the 1995 Order undertakers must make information about their in-street apparatus “available for inspection at all reasonable hours, free of charge by any person having authority to execute works in the street or other persons appearing to the undertaker to have sufficient interest”.  

To ensure the information held in NUAR can be made available to the appropriate user groups for legitimate purposes, and in the right way, regulation making powers have been established under section 106C of the 1991 Act and article 39(3) of the 1995 Order. Such regulations will establish the protocols regarding the access to information held in NUAR. It is important that any such regulations effectively balance the user need for this information with necessary security considerations. 

NUAR is currently operating as a voluntary system and has recently moved into an operational phase known as ‘public beta’. The proposed regulations are based on the existing usage model, which has been developed in collaboration with current users of the service as well as security stakeholders (including the National Cyber Security Centre, the National Protective Security Authority, and the security teams of undertakers).  

Regulation making powers 

Part 3 of this consultation sets out the principles of the NUAR access model and seeks views regarding the potential risks and benefits of the implementation of this more widely across the street works sector. The provisions under section 106/45C allow for a nuanced approach to access to ensure NUAR can operate effectively as a digital service. Regulations made under section 106/45C may, among other things, make provision for:

106/45C(2) - What information is made available; 

To whom the information is made available; 

Any exceptions to the availability of information, including adapting, modifying or obscuring information before making it available;  

The purposes for which information held in NUAR is to be made available; 

How information is to be made available; 

Any fees charged for the access to information held in NUAR; 

Any licences including terms and conditions in regard to non-crown IP rights.^{[footnote 11]}

3.2 Access to information: Safe Dig

Under the proposed regulations, NUAR will be accessible to undertakers and authorised contractors working on behalf of these undertakers in England, Wales and Northern Ireland. Information will be free at the point of use, however a fee structure will be implemented to recover operating costs from undertakers, this is expanded on in Part 4 of this consultation.  

Information about the spatial location will be provided via the NUAR user interface as well as via PDF work packs for the purpose of safe dig. The nature of both the user interface, and the information available through it, may change from time to time in line with user needs. However, this video provides an overview of what information is currently available through the service and the user experience it provides.  

Access to NUAR will be granted in accordance with an end user licence which will clearly establish agreed usage criteria as well as appropriate security measures that should be applied in the access of information held in or accessed from the NUAR platform. Guidance will be issued for users accessing information held in NUAR, this will be developed in conjunction with the security services and relevant stakeholders. Robust security measures have been integrated into the platform. These include:

• UK-only data centres 

• Cyber-security good practice including data encryption and network segmentation 

• Multi-factor authentication and periodic reaffirmation of account validity 

• Role-based access controls to ensure NUAR is only accessed by authorised users with the principle of “least privilege”. 

• Geographical constraints which control where users are allowed to query data based on their legitimate area of operations, and the size of the area that they can query based on their role. 

• Logging of all user activity to enable monitoring and reporting on suspicious usage patterns. 

• Asset filtering/obfuscation to all asset owner to decide the level of information that should be visible about their assets and restrict the available information that can be seen regarding sensitive assets.  

These measures are demonstrated in our NUAR demo which is available on YouTube.

The NUAR Administration Portal will allow designated administrators within organisations which act as undertakers to invite and manage their direct users (constrained by email domain) and to manage the supply chain organisations who work on their behalf.  The information that users can access will depend on what role they are assigned. This follows the principle of least privilege.   

Level 1 – These users would be able to request and view NUAR information to varying geographic extents specified by their user role (for example access may be limited to a 100x100m or 500mx500m area). They would be able to see detailed attribute data that had been provided and uploaded to NUAR, excluding data that data owners have marked as sensitive or redacted. All data requests will be logged by the NUAR operator.  

Level 2 – These users would be able to view NUAR information that an authorised level 1 user had requested. They would not be able to request information themselves via the platform (this would be enforced via the platform itself as they would not have the functionality available to them).  

Level 3 – It may be appropriate for a subset of users to have access to the NUAR platform but not to any of the asset information (for example administrators who are solely responsible for assigning access to others).    

Work is being undertaken to consider the potential for NUAR information to be provided to other groups, for other purposes, and through other channels. This is subject to further consideration and approvals. For more information on this please see our recent blog on the subject.

As set out in the blog, work is underway to test the technical feasibility of a number of potential options. Central to this work is ensuring that this information can be made available securely. Although the data stored in NUAR is potentially valuable, it could present a substantial security risk if released without proper control. The evidence collected through this work will inform a decision by the end of 2025 on which, if any, of these proposed enhancements should be taken forward.

Q24. What are the risks to implementing these new regulations? (optional) 

Q25. Do you have any further comments about the above risks?

Q26. What are the benefits to implement these new regulations? (optional) 

Q27. Do you have any further comments about the above benefits? 

Q28. Enter your email address if you would like to hear from us about your feedback. (optional)

Part 4 - Funding of the NUAR service

Undertakers are already legally required to make certain data available to street works undertakers free of charge to enable them to plan and carry out their works safely. NUAR will make it more efficient for them to fulfil this obligation.  The data that undertakers will be legally required to share is referred to for the purposes of this part as “statutory apparatus data”.  

Once NUAR is fully operational, undertakers will be able to share their data for the purposes of safe digging through the NUAR service, rather than having to respond to each data request individually.  As this will lead to efficiency benefits for undertakers and will maintain longstanding industry practice of data being free at the point of use, the running costs of NUAR will be shared across the undertakers.  

As set out in the 2025 Act, any fees charged for the operation of NUAR will be limited to covering the costs of running the service. The collection of these fees will not generate a profit for government. It is envisaged that undertakers will not be charged before there is comprehensive information in the platform. Further engagement will be undertaken before any charges are introduced. Current timelines anticipate that fees are unlikely to be introduced before 2028.  

NUAR supports organisations of various sizes, from small and micro businesses to large entities. Different organisations may derive varying levels of benefit from the NUAR service. To address this in the fee structure, it is proposed to use the length of network to allocate benefits. Organisations with larger apparatus networks are expected to receive more requests for information and thus benefit more than those with shorter networks therefore, the more likely they are to be saving time and administration costs by sharing their data through the NUAR platform than responding to individual requests. 

It is acknowledged that undertakers may share information beyond the statutory apparatus data legally required. Therefore, to ensure that the fee structure continues to encourage the provision of high-quality information to facilitate safe street works excavation, the intention is to exclude non-statutory apparatus from the fee structure. This will mean those sharing data beyond legal requirements will not incur additional costs for providing high-quality, additional information. 

Both public and private sector organisations are expected to benefit from the efficiencies of sharing information through NUAR. Therefore, we are considering a fee structure that would collect charges from all organisations involved in NUAR. 

We are not seeking views on the policy set out in this part at this time. A subsequent consultation will be carried to seek detailed views in relation to the proposals set out in this part – currently this is expected to take place during 2027.

1. Under section 106B(1) of the 1991 Act and article 45B(1) of the 1995 Order as amended by the 2025 Act. ↩

2. Under section 79(1B) of the 1991 Act and article 39(1B) of the 1995 Order, as amended by the 2025 Act. ↩

3. Under section 79(3B) of the 1991 Act and article 39(3B) of the 1995 Order as amended by the 2025 Act. ↩

4. Under section 106C(1) of the 1991 Act and article 45C(1) of the 1995 Order as amended by the 2025  Act. ↩

5. If you have already onboarded to NUAR it is anticipated that the form and manner of this upload will be similar to existing processes and attempts will be made to ensure that information already submitted to NUAR could be used to fulfil this requirement. ↩

6. Under section 106B(1) and article 45B(1) as detailed in part 1.1 of this consultation document ↩

7. These include – placing the item in the street or altering its position, inspecting, maintaining, adjusting, repairing, altering or renewing the item, locating the item in the street in the course of executing any other works, or receiving any such information in relation to the item under section 80(2)(a). ↩

8. Based on current timelines this would extend until at least spring 2027. ↩

9. A geospatial data type which comprises of points, lines, and polygons recorded against a specified coordinate reference system ↩

10. Although this information could serve to protect those carrying out street works so should be recorded and uploaded where possible ↩

11. Crown IP is licensed by the Keeper of the National Archives ↩