Ofgem Licence Cyber Baseline Evidence & Assurance Orchestrator
DESNZ and Ofgem have decided to develop baseline cyber-resilience requirements for all Ofgem licensees while separately reviewing which downstream gas and electricity organisations should fall within the NIS regime. That creates a layered compliance problem: organisations need to understand which cyber framework applies to which licensed entity or activity, avoid duplicating controls already evidenced elsewhere and be able to show a consistent baseline across businesses with very different risk profiles and regulatory histories. Operational consequences: Without a common evidence model, licensees can maintain separate NIS assessments, Cyber Assessment Framework mappings, corporate security controls, licence evidence, audits and consultancy outputs. The same control may be assessed repeatedly under different labels, while gaps or stale evidence are hard to see across entities. Smaller or newly regulated licensees face the additional challenge of creating an auditable baseline without the governance teams found in critical-infrastructure incumbents.