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Regulatory Sandboxing Project

  • Date released: 7 July 2026
  • Request number: FOI202605009
  • Release of information under: FOIA

Information requested

I am making this request under the FOI Act. This is based on this ONR article from 1 May: ONR publishes findings of regulatory sandboxing to develop AI capability

The article is about a report, and the report said:

“Whilst the core of this project was the regulatory sandboxing activities, there was a set of other enabling activities essential for success, including:

  • Consultation and expression of interest. Consultation activities with various external stakeholders identified key industrial partners and regulators who could contribute to the project in the given timescales. This phase stretched over three weeks before the launch event.”

Please will send me any documents which show who those stakeholders were, and what they discussed with the ONR and relevant partners involved in the ONR’s regulatory sandboxing for AI project.

Our response

We confirm that under s.1 of the FOIA we hold the information you have requested. Please find attached the following three documents:

It is important to note that some information within these documents has been withheld. In our initial response to you on 9 June 2026, we confirmed that we needed additional time to consider the public interest test for the qualified exemption s.43 of the FOIA - commercial Interests, which is set out below.

S.40 FOIA – Personal information

In addition, personal data has been withheld under the s.40 of the FOIA – Personal information. As this is an absolute exemption, it does not require a public interest test. The personal data includes names, job titles and contact details. Release of this type of information could identify an individual directly.

Release of the information would breach principle (a) of GDPR (lawfulness, fairness and transparency) on the grounds that there is no lawful basis to process this data. In addition, releasing this personal data would also breach principle (b) of GDPR (purpose limitation) as the data was provided as part of their work.

Further information

As context for our approach, we established open and transparent stakeholder communications across three distinct channels:

  • Open Invitation: At the project’s launch, we published an open invitation on our LinkedIn page https://uk.linkedin.com/company/office-for-nuclear-regulation welcoming Expression of Interest (EoI) submissions from interested parties. All stakeholders who provided an EoI were invited to the official launch meeting on 7 October 2025.
  • Engagement at Industry Forums: We actively presented this opportunity at the Head of Innovation forum held at Redgrave Court on 27 September 2025. UK dutyholders at this forum were invited to join the launch meeting discussions and present use cases relevant to their commercial interests. The final list of project partners was consolidated transparently based on their response.
  • Technical Services Framework (TSF): Our project contractor was formally identified and appointed using our fair and competitive TSF process.

Exemptions applied

S.40 and S.43

Public Interest Test (PIT)

S.43 – Commercial interests

S.43(2) exempts information whose disclosure would, or would be likely to, prejudice the commercial interests of any legal person (an individual, a company, the public authority itself or any other legal entity).

Factors for disclosure

  • ONR is committed to being an open and transparent regulator;
  • As set out in our policy for openness and transparency, we aim to be an exemplar of transparency and openness to retain, and enhance, the trust and confidence of the workers and public we serve;
  • We will use openness and transparency to achieve our objective of developing and maintaining stakeholder trust in ONR as an effective independent regulator; and,
  • Issues related to the nuclear industry are subject to close scrutiny and debate, there is a public interest in the release of such information.

Factors against disclosure

  • Information regarding the internal effort cost breakdowns, specific funding proposals, and strategic partner arrangements should not be released. Disclosing these specific commercial pricing models and resource structures would give market competitors unfair insight into the commercial terms, financial bidding strategies, and operational AI capabilities being developed by our partners.

Conclusion

ONR operates with a presumption of disclosure and is committed to being an open and transparent regulator. However, this openness must be balanced against the significant public interest in protecting commercial confidentiality and ensuring fair market competition. In this case, the public interest in withholding a portion of the requested information outweighs the public interest in disclosing. Releasing detailed financial effort breakdowns and strategic partner arrangements would give market competitors unfair insight into the commercial terms and operational AI models being developed, undermining the integrity of future competitive tenders.

Therefore, we have determined that while some information can be shared, specific technical, financial costings, and commercial partner details must be withheld under s43(2) of the FOIA.

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