MOSL

Business Plan

IMPROVEMENT PROGRAMMES

Market Code Simplification

Improvement programme summary

Our Market Code Simplification programme is focused on ensuring the codes are suitably adaptive to enable efficient change, facilitate innovation and lower barriers for entry to the market. Through this programme, we aim to make codes clearer, more transparent, and more accessible by removing complexity and by providing guidance in plain English.

This work will build on the findings of our 2020/21 review of market codes, which is due to conclude prior to the start of 2021/22.

Its delivery is phased across all three years of our business plan and includes:

Application of clear architectural principles - to guide future code development
Simplifying points of complexity - where there is a case for change identified through the findings of the 2020/21 review
Providing plain English guidance on key areas of the market codes
Redesign (re-architecture) of the market codes - in 2023/24 (should a case for such major change be identified through the review)
How trading parties and customers will benefit

The programme is a key component in delivering our Market Improvement strategic priority.

Code complexity contributes to market frictions through indirect costs experienced by trading parties relating to training their teams in complex code rules, resolution of disagreements regarding complex or ambiguous rules and slow pace of change. The simplification of obligations and processes captured in the current market document set would support a maturing market that is better set up to respond to change and, in turn, deliver benefits to customers more quickly.

These improvements will be created by a programme that:

Makes the market codes easier to navigate and more accessible for trading parties
Better supports efficient market entry and competition by reducing the potential for error and disagreement and making the market codes easier to understand for new market entrants
Facilitates flexibility and innovation in governance, with the market codes being quicker and easier to change.

Customers will ultimately benefit from faster development of the market codes which may lead to new innovations and business models entering the market, offering greater choice and value.

How the workstream builds on our current 2020/21 Business Plan 

In 2020/21, under the market code review, we have consulted trading parties on the matter of code complexity and this feedback is being considered by the Panel’s Code Advisory Group to inform the way forward.

By the beginning of 2021/22, the code review will have identified architectural principles to guide the design of simple and clear documents going forward. It may also identify areas of complexity in the current market document set that constitute points of friction or opportunities for improvement. These will determine the extent of work through 2021/22 to resolve these points of friction through a blend of simplified code drafting and plain English guidance.

Delivery for 2021/22 – milestones and outcomes
Area
Milestone
Benefit
Simplification of identified points of complexity in existing codes
Code changes to be progressed under 'business as usual' provisions for any ‘high-priority areas’. Milestones to be determined based on priortisation within the findings of the 2020/21 review
Resolves those points of complexity which are leading to indirect costs as identified in the 2020/21 review
Production of plain English guidance on key areas of the market arrangements
Milestones to be determined based on priortisation within the findings of the 2020/21 review
Supports transparency and consistent understanding in relation to areas of complexity which are leading to indirect costs as identified in the 2020/21 review
Three-year delivery plan

Based on findings from the market code review taking place this year the code simplification programme will focus on high priority areas in year one.

Future code changes will follow code architectural principles to ensure changes are implemented consistently, with simplicity and transparency in mind.

We recognise that any major re-architecting of the market codes that may arise from the review will not be a ‘business as usual’ activity. Such major work will need appropriate focus and resources. We have planned to progress this re-architecture work in 2023/24, subject to a clear business case being identified and approved.

2020/21
Current year
2021/22
Year one
2022/23
Year two
2023/24
Year three
Complete code review

Identify architectural principles

Prioritise areas for simplification
Small scale change implemented that can be delivered without major review as ‘business as usual’

Plain English guidance
Small scale change implemented that can be delivered without major review as ‘business as usual’

Plain English guidance
Substantial change recommendations delivered – requiring additional Panel committees and resource time

Substantial legal review (subject to case for change)
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