British Industrial Competitiveness Scheme (BICS): changes to the Renewables Obligation (Scotland) Order 2009

6. Publication of the obligation level

The Renewables Obligation (Scotland) Order 2009 (ROSO 2009) requires Scottish Ministers to publish the obligation level (in SROCs per megawatt hour of electricity supplied) 6 months before the start of each obligation period, that is, by 1 October. The obligation levels for 2026 to 2027 were published on 29 September 2025.^[2]

The obligation level for Scotland, England and Wales for 2027 to 2028 will be calculated using the current RO rules and published by 1 October 2026. It is unlikely that the legislative changes, which give effect to BICS, will be in place in time to be taken into account for the 2027 to 2028 obligation level at this point.

We recognise that the ROS can represent a significant cost for electricity suppliers and early notification of the obligation level is important to enable them to price the cost into domestic and non-domestic retail tariffs.

To minimise the impact that this uncertainty will have on electricity suppliers’ ability to forecast costs, it is expected that DESNZ, with the agreement of Scottish Ministers, will calculate an estimate of how the obligation level for Scotland would be adjusted to account for the BICS exemption alongside, or shortly after, the obligation level for 2027 to 2028 is published. This estimate will provide an indication of what the obligation level is likely to be, once the BICS exemption is implemented.

The level of the obligation for Scotland (and England and Wales) for 2027 to 2028 will then be adjusted to account for the BICS exemption before 1 April 2027, through changes to the ROS Order 2009 and the RO Order 2015. This will allow the Obligation level for 2027 to 2028 to be revised after the current 1 October deadline. If the necessary parliamentary clearances have not been granted or are delayed beyond 31 March 2027 it will not be possible to implement the ROS exemption for the 2027 to 2028 obligation year. In this case the obligation level based on the current methodology would remain the obligation level for 2027 to 2028.

It is expected that the following obligation level for 2028 to 2029 will revert to publication by 1 October 2027 and continue to follow this timetable going forward.

The Department of Business and Trade recognise the importance of issuing BICS eligibility confirmation promptly to avoid knock on impacts to the effective functioning of the ROS. Timely issuance will ensure exempt supplies are accurately reflected in supplier obligations, meaning electricity suppliers will be able to fully pass on the intended savings to consumers.