Regulatory Assurance

Context

This involves the assurance of Scottish Water's medium-term (SR27) business plan, covering the period from 2027 to 2033. The business plan will set out Scottish Waters investment plans together with the outcomes that we propose to deliver for our customers, communities and the environment, as well as the underlying evidence that we have prepared to support those plans. The information in Scottish Water's business plan submission will be used by the Water Industry Commission Scotland (WICS), Scottish Water's independent economic regulator, in the preparation of its Final Determination. While the business plan is Scottish Water's plan, WICS need to have confidence in the integrity of the data and commentary within it. If WICS have concerns over the impartiality or quality of the assurance report, this would undermine / reduce the value of the assurance to Scottish Water. Therefore, it is essential that the third-party assurance undertaken on the plan is completely impartial.

The timelines for when the assurance work is required is between March and May 2025 for the draft business plan and between October and February 2026 for the final business plan. These dates are fixed due to the submission dates set out by WICS for both plans.

Areas which require assurance are

• Draft and Final Business Plan Data tables, in particular examining whether Scottish Water has prepared these in line both the business plan guidance and definitions set out by WICS and that they are fully consistent with the accompanying commentary prepared by Scottish Water;
• Review of the robustness of the systems and processes used to produce the information;
• Identification of the key assumptions made by Scottish Water in preparing its data tables and review of the reasonableness and materiality of those assumptions; and
• Assurance of the accuracy, completeness and comprehensiveness of the data.

In addition, Scottish Water requires that its independent assurer

• Is able to demonstrate that it is free from any conflicts of interest and/or that where any actual or perceived conflicts of interest may arise as a result of its appointment, that the assurer can put in place measures/arrangements to manage those conflicts of interest for the duration of the appointment;
• Is able to demonstrate the impartiality of its approach to the assurance of the business plan;
• Provides timely efficient feedback on the Draft Business plan to allow Scottish Water to make improvements in its data, evidence and/or processes ahead of the Final Business plan submission;
• Provide draft and final assurance reports to both Scottish Water and Water Industry Commission Scotland (WICS), setting out both the work that has been undertaken, any factors which prevented and/or impeded the assurer from undertaking its role as it might reasonably have expected, and the assurer's findings.

In addition to the above matters, there will be a requirement to engage directly with external stakeholders, including the WICS, to respond to questions on the draft and final assurance reports, including providing further explanation of the assurer's work, findings and/or other matters arising within the terms of reference of their appointment, as is reasonably required.

In order to facilitate the assurer in its role, Scottish Water shall grant the assurors any necessary and timely access to premises, assets, systems, data, working papers, other records and relevant personnel associated with the carrying out of Scottish Water's regulated activities. Scottish Water shall supply the assurors with any information relevant to the assurance process including all material assumptions underpinning the data submission as well as access between the assurors and the financial auditors.

Scottish Water shall not be required to do anything which is outside their control, or to do, or allow the assurors to do, anything which would materially disrupt Scottish Water's business.

Our requirements

The independent assurers should be able to demonstrate a track record in the following areas:

• Independent Third-Party Assurance provision for regulated businesses;
• Assurance for Business Plan submissions for regulated businesses;
• Experience of working with regulated water companies;
• Relevant knowledge of technical, commercial and regulatory aspects of the water sector.