Demand as an Active Agent: Regulatory and Operational Comparison Between Colombia and the United Kingdom's Electricity Market

The global energy transition and the high penetration of variable renewables are increasing the need for system flexibility. In this context, active demand (demand response, DR) enables consumers and aggregators to adjust consumption in response to economic and operational signals. This article compares Colombia and the United Kingdom as two contrasting cases: one representing an emerging framework and the other a mature market with recent operational evidence. To move beyond a purely descriptive comparison, we propose a replicable ‘readiness’ assessment framework that evaluates six enabling dimensions: market access, measurement/verification and settlement, aggregator schemes, digital enablement, and incentive design. Drawing on the literature, the analysis identifies that Colombia’s…