VTPs get their cake and eat it too under P415

The UK’s P415 reform is reshaping who can play in wholesale electricity markets. This interesting paradigm allows splitting the energy supply contract from an optimization service, an important step towards an energy system where the center of gravity shifts from the energy supplier to the end-consumer and the OEM.

If you are an OEM and you’re planning to invest in being ready for P415, there’s a subtlety that you might want to take into account. Call it a bug if you’re a supplier, a feature if you’re a Virtual Trading Party (VTP): There’s currently no compelling incentive for the VTP to buy back deviation volumes.

In fact, the delayed load lands on the supplier’s (BRPs) imbalance position, not the VTP’s. It’s a design quirk with possibly major consequences: suppliers carry the rebound risk, while VTPs get to cherry-pick high-margin trading opportunities. This means that the VTP can extract more value at the expense of BRPs until this bug gets resolved. If and how does this happen? Only time will tell. But first, let’s take a step back…how does P415 work?

‍

P415: an abbreviated primer

Under P415, energy users can turn their assets into tradable flexibility by allowing a third party to control their usage, though always remaining within comfort boundaries (e.g. temperature, charging constraints). The recent approval of P483 significantly increases its scope of application, enhancing the scalability of P415, which had previously been limited to owners of half-hourly settled meters.

The VTP temporarily takes on the role of a Balance Responsible Party (BRP) for the specific moments when flexibility is traded. The traded volume, or Deviation Volume, is calculated against a P376 baseline - the average consumption over recent non-activation periods. Any deviation is added to the VTP’s position, and the supplier is compensated via a Transfer of Energy correction model. This allows the VTP to optimise consumption in high-price periods, sell the resulting deviation into the wholesale market, and pass the value back to the consumer, all without disrupting their comfort boundaries or operational needs if done in a smart way.

‍

Why the zero-sum bug matters

P415 allows both demand turn-down and demand turn-up deviations. If load is shifted away from a high-price period (e.g., pausing EV charging), there’s no requirement nor incentive to “buy back” that energy later to even things out (initial compensation designs did provide those incentives).

The result is a market “bug/feature“ with one big implication: Suppliers carry the rebound risk. Any delayed consumption shows up in the supplier’s imbalance position, not the VTP’s. The supplier absorbs that imbalance cost which explains why some suppliers are vocally resisting P415.

The bottom line is that VTPs get to have their cake and eat it too. It is Beebop’s view that if P415 is successful this will be remedied.

‍

Example: EV charging shift

Take Neil, for example. Every evening he plugs his EV into his home charger between 7 pm and 8 am. His daily charging need is 10 kWh, and with a 5 kW charger that usually means the car tops up from about 7 to 9 pm - right in the middle of a pricey peak.

But Neil’s no fool. He’s using the services of a VTP. The VTP spots an opportunity: sell a 1h block (5 kWh) into the market while wholesale prices are flying at £150/MWh. That single move generates £0.75 of value (5 kWh × £0.15/kWh).

Later that night, when prices have cooled off, Neil’s EV quietly recharges the remaining 2.5 kWh. Crucially, the VTP doesn’t need to buy back that “rebound” energy - it simply rolls into the supplier’s imbalance position.

‍

Where Beebop and OEMs fit in

Beebop has built best-in-class aggregation and disaggregation algorithms and the deepest trading integration stack in the market. By partnering with leading VTPs, Beebop will be combining optimisation excellence with top-notch market execution, ensuring every stage of the flexibility value chain is optimised.

For OEMs to participate successfully in P415 markets, they must:

• Obtain COP 11 metering certification for compliance
• Deliver high-quality telemetry for real-time control and monitoring
• Ensure API integration so assets can integrate with aggregators and market platforms

Beebop’s platform is the keystone linking OEM assets to VTPs, enabling end users to monetise their flexibility potential at scale.

‍

Key takeaways

P415 opens the UK wholesale electricity market to specialist Virtual Trading Parties (VTPs), allowing OEMs to monetise asset flexibility independently of supply contracts. With compliant metering and half-hourly settlement (soon to be opened up to more participants thanks to the recently approved P483), OEM-connected assets can participate in lucrative wholesale electricity markets.

Unlike other frameworks, P415 doesn’t require zero-sum energy balancing, letting VTPs capture high-margin opportunities without buying back rebounds - a bug/feature some players already use. Beebop’s tech stack bridges OEM assets to top traders, ensuring compliance, telemetry, and seamless market integration to maximise flexibility value.

‍

References

Elexon. (n.d.). P415: Facilitating access to wholesale markets for flexibility dispatched by Virtual Lead Parties. Retrieved August 14, 2025, from https://www.elexon.co.uk/bsc/mod-proposal/p415/

Elexon. (n.d.). Becoming a Virtual Trading Party. Retrieved August 14, 2025, from Becoming a Virtual Trading Party

‍