Proposed changes to UK energy market pricing structures: EIR release

Information requested

Discussions with the UK Government

Between 1 January 2025 and 31 August 2025, please provide details of any discussions the Scottish Government had (a) at official level and (b) at ministerial level with the UK Government concerning the potential introduction of a zonal pricing model in the UK energy market. Please include, where available:

- Dates of meetings or correspondence
- Participants and departments involved
- Any briefings, minutes, or notes summarising the Scottish Government’s position or concerns

Scottish Government position on zonal pricing

Between 1 January 2025 and 31 August 2025, did the Scottish Government express, either explicitly or implicitly, to the UK Government whether it supports or opposes the introduction of zonal pricing in the UK energy market?

If so, please provide copies of any correspondence, briefing notes, or records evidencing that position. 

Engagement with external organisations

Please provide a list of all external organisations, stakeholders, or industry representatives the Scottish Government met with between 1 January 2025 and 31 August 2025 where zonal pricing was a substantive item of discussion (for example, appearing on the agenda or forming the purpose of the meeting).

For each meeting, please include:
- The date
- The organisation(s) or individuals present
- The Scottish Government attendees
- Any available record of discussion or outcome

Internal discussions related to SNP policy

Please provide details of any internal discussions, correspondence, or briefing material prepared by Scottish Government officials regarding the Scottish National Party National Council’s 2025 decision to adopt zonal pricing as party policy.

Please specify the dates of these discussions, which directorates or officials were involved, and whether any assessment was made of the policy’s implications for Scottish Government positions or communications with the UK Government.

Response

As the information you have requested is ‘environmental information’ for the purposes of the Environmental Information (Scotland) Regulations 2004 (EIRs), we are required to deal with your request under those Regulations. We are applying the exemption at section 39(2) of the Freedom of Information (Scotland) Act 2002 (FOISA), so that we do not also have to deal with your request under FOISA.

This exemption is subject to the ‘public interest test’. Therefore, taking account of all the circumstances of this case, we have considered if the public interest in disclosing the information outweighs the public interest in applying the exemption. We have found that, on balance, the public interest lies in favour of upholding the exemption, because there is no public interest in dealing with the same request under two different regimes. This is essentially a technical point and has no material effect on the outcome of your request.

On reviewing materials within scope of your request, some exceptions have been applied in line with the EIRs. You can find information on the exceptions that have been applied to information in Annex A.

I have included copies of some of the information you requested in Annex B. This relates to your request for information on discussions with the UK Government, the Scottish Government position on zonal pricing and engagement with external organisations. As detailed below, we do not hold information on internal discussions related to SNP policy. Other information has already been released in response to previous requests as listed below. Under regulation 6(1)(b) of the EIRs, we do not have to give you information which is already publicly available and easily accessible to you in another form or format. If, however, you do not have internet access to obtain this information from the website(s) listed, then please contact me again and I will send you a paper copy.

You may wish to review the publications section of the Scottish Government website for further information.

Discussions with the UK Government

I have provided links below to previous EIR publications that contain information relating to your request that you may find helpful:

FOI response 202500459761: Briefing materials and minutes between Scottish Government Ministers and Officials regarding zonal pricing meeting
FOI response 202500463818: Meeting with Parliamentary Under-Secretary of State on the Review of Electricity Market Arrangements (REMA)
EIR response 202500475435: Zonal pricing for electricity representations
EIR response 202500474141: Secretary of State for Energy Security and Net Zero materials

Scottish Government position on zonal pricing

I have provided links below to previous EIR publications that contain information relating to your request that you may find helpful:

FOI response 202500457230: Deputy First Minister and Cabinet Secretary for Economy and Gaelic correspondence regarding zonal pricing
FOI response 202500459477: Correspondence from Senior Special Adviser which includes the phrase “zonal pricing”
FOI response 202500463818: Meeting with Parliamentary Under-Secretary of State on the Review of Electricity Market Arrangements (REMA)
EIR response 202500464189: Briefing materials and minutes for the zonal pricing meeting
EIR response 202500465527: Electricity market deep dive session information
EIR response 202500464077 & 202500470332: Meeting notes regarding Discussion on Zonal Pricing and Reformed National Market

Engagement with external organisations

I have provided links below to previous EIR publications that contain information relating to your request that you may find helpful:

FOI response 202500463438: Materials pertaining to zonal pricing
FOI response 202500457230: Deputy First Minister and Cabinet Secretary for Economy and Gaelic correspondence regarding zonal pricing
FOI response 202500459477: Correspondence from Senior Special Adviser which includes the phrase “zonal pricing”
EIR response 202500462432: Correspondence including the phrase “zonal pricing” with SSE
EIR response 202500462435: Correspondence including the phrase “zonal pricing” between Scottish Government and employees of Scottish Renewables
EIR response 202500462437: Correspondence including the phrase “zonal pricing” between Scottish Government Officials and employees of Octopus Energy
EIR response 202500462991: Correspondence and documentation related to follow-up discussion between the First Minister and selected SEAB members
FOI response 202500463409: Briefing materials regarding Zonal Pricing of Electricity
EIR response 202500465527: Electricity market deep dive session information
EIR response 202500466595: Scottish Government and True North meeting regarding Zonal Pricing
EIR response 202500470399: Zonal pricing impact on wind farm building in Scotland
EIR response 202500474141: Secretary of State for Energy Security and Net Zero materials

Internal discussions related to SNP policy

While our aim is to provide information whenever possible, in this instance the Scottish Government does not hold some of the information you are seeking in relation to Internal discussions related to the Scottish National Party policy. It may help if I explain that Scottish Government officials provide advice to Scottish Ministers in their capacities as said ministers and would not provide advice within a partypolitical context.

Therefore, with respect to your request this is a formal notice under the exception at regulation 10(4)(a) of the EIRs confirming that the Scottish Government does not hold this information. However, you may wish to contact the Scottish National Party who may be able to help you.

ANNEX A

The following exceptions have been applied, not subject to the public interest test:

Regulation 11(2) – Personal Data

While our aim is to provide information whenever possible, in this instance an exception under Regulation 11, personal data, has been applied to some of the information requested. Information has been redacted under Regulation 11 (Personal Data), as it contains personal information and disclosing it would contravene the data protection principles in Article 5(1) of the General Data Protection Regulations (GDPR) and in Section 34(1) of the Data Protection Act 2018. This exception is not subject to the ‘public interest test’.

Regulation 6(1)(b) – Information publicly available

While our aim is to provide information whenever possible, in this instance an exception under Regulation 6(1)(b), information already available, has been applied to some of the information requested. For information that is already publicly available, we do not have to give you information which is already publicly available and easily accessible to you in another form or format. In the attached documents we have provided you with the relevant links to access this information.

10(4)(a) of the EIRs (information not held)

An exception under regulation 10(4)(a) of the EIRs applies to some the information you have requested. This regulation relates to information which the Scottish Government does not hold. This regulation is subject to the public interest test. This exception applies to your request for the project scope or description.

This exception is subject to the ‘public interest test’. Despite not holding this information, we have a statutory obligation to apply this test. Therefore, taking account of all the circumstances of this case, we have considered if the public interest in disclosing the information outweighs the public interest in applying the exception. We have found that, on balance, the public interest lies in favour of upholding the exception. While we recognise that there may be some public interest in information about the project’s in the 2024/25 in year hydrogen fund, clearly we cannot provide information that we do not hold.

The following exceptions have been applied, subject to the public interest test:

Regulation 10(4)(e) – Internal communication

While our aim is to provide information whenever possible, in this instance an exception under Regulation 10(4)(e), internal communication, has been applied to some of the information requested. This exception is subject to the ‘public interest test’. Therefore, taking account of all the circumstances of this case, we have considered if the public interest in disclosing the information outweighs the public interest in applying the exception. We have found that, on balance, the public interest lies in favour of upholding the exception. We recognise that there is some public interest in releasing the information as part of an open, transparent and accountable government. However, this is outweighed by the greater public interest in allowing Scottish Government officials and ministers a private space to share free and frank views for the purpose of deliberation of any given policy.

Regulation 10(5)(f) – Third party interests

A small amount of information has been withheld under Regulation 10(5)(f) (third party interests). This exception is subject to the ‘public interest test’. Therefore, taking account of all the circumstances of this case, we have considered if the public interest in disclosing the information outweighs the public interest in applying the exception. We have found that, on balance, the public interest lies in favour of upholding the exception. We recognise that there is some public interest in releasing the information as part of an open, transparent and accountable government. However, disclosure of this particular information would, or would be likely to, prejudice substantially the confidentiality of said information and the interests of those providing information to the Scottish Government in confidence.

About FOI

The Scottish Government is committed to publishing all information released in response to Freedom of Information requests. View all FOI responses at https://www.gov.scot/foi-responses.

EIR 202500491475 - Information released - Annex B

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