BioChain Limited has submitted its response to the UK Government’s Smart Data multi-sector call for evidence, calling for provenance to become a core component of trusted data sharing across agrifood and other sectors. The response rests on a single principle: consent makes data shareable, but provenance is what makes shared data usable as evidence.
Smart Data has the potential to make it significantly easier for organisations and customers to access and reuse information held across different systems, but moving data is only part of the problem. When an important fact moves from one organisation to another, the recipient also needs to understand where it came from, who asserted it, under what authority, which method or standard was used, which version is current, and whether the information has since been corrected. Our response argues that this provenance should travel with the data, as data.
The submission concentrates particularly on agrifood, where evidence is already distributed across many independent organisations and systems. A single animal, food product or environmental claim may involve information held by farms, veterinary practices, diagnostic laboratories, livestock traceability systems, processors, assurance schemes and government bodies. Each of those systems performs its own function well; the difficulty appears when information needs to be relied upon across the boundaries between them.
We therefore argue against creating another large central platform. Smart Data should instead connect existing systems while allowing those systems to remain the authoritative source of their own records. The response considers several applications of that approach, including livestock health, disease surveillance and biosecurity; veterinary and laboratory evidence; farm-level environmental and carbon data; food provenance and processing; assurance and certification; cross-border sanitary and phytosanitary evidence; and reducing repetitive regulatory and supply-chain reporting. Two of those are worked through in detail in our sector briefs, on cattle traceability and evidence and on agri-food carbon data.
A central theme of the submission is the need to distinguish between authentication, authority, provenance, integrity and accuracy. A digitally signed laboratory result can demonstrate that a particular laboratory issued a record and that the record has not subsequently been altered, but it does not by itself demonstrate that the test was performed correctly, that the correct sample was tested, or that the scientific conclusion is accurate.
Smart Data services should therefore be explicit about what has actually been verified, rather than allowing the word “verified” to create a confidence that the underlying checks do not support. As automated systems consume shared data faster than anyone can audit it by hand, that false confidence becomes a risk in its own right.
The BioChain architecture separates the problem into five stages, set out in full on our technology page.
The five steps are the same everywhere. Here is what each one connects in this context.
The separation matters because different failures require different controls. A record can be genuine but linked to the wrong animal; a person can be correctly identified but lack the authority to make a particular assertion; and an authentic, unchanged record can still contain an inaccurate result. Treating these as one problem called “trust” makes all three harder to diagnose.
The response does more than propose principles: it offers a route for testing them. We are already applying this provenance architecture to UK livestock and veterinary data, including through PigWare, a 12-month trial launched in September 2026 on two commercial pig farms under ADOPT, part of Defra’s Farming Innovation Programme delivered in partnership with Innovate UK.
The submission proposes building on that environment with a small, bounded feasibility pilot connecting an animal-health evidence chain across several existing systems. It would run for nine months and connect between three and five systems without replacing any of them or creating a new central database, producing a working evidence chain, a data-access map for every element and a proposed minimum provenance profile for agrifood. The aim is deliberately measurable: to establish whether preserving provenance across organisational boundaries reduces the time and effort needed to reconstruct evidence, while making its source, version and authority easier to establish.
The response also argues that Smart Data should complement existing UK programmes rather than duplicate them, among them livestock traceability infrastructure, the Food Data Transparency Partnership, the Food Data Infrastructure and Governance project, AHDB’s Farm Data Exchange, and the farm, laboratory, processor and assurance systems already in daily use. The role of a provenance layer is not to become the new system of record, but to make it possible for evidence from those systems to be connected and relied upon while retaining its history.
The development of Smart Data infrastructure creates an opportunity to establish common rules for provenance alongside identity, authentication, accreditation and consent. That becomes more important as shared data is consumed not only by people but by automated systems and AI, because the question will increasingly be not simply whether data can be accessed, but where it came from, who asserted it, what it relates to, which version it is, and whether it can be relied upon for the decision at hand.
Our response is intended to help make those questions part of Smart Data architecture from the outset, rather than something retrofitted once the first dispute arrives.
A consultation run by the Department for Business and Trade (CP 1608) on how Smart Data schemes should work across agrifood, trade, retail, property, transport and other sectors, and on the governance those schemes would need. It closed on 1 October 2026.
To define a minimum provenance record once, centrally, alongside accreditation and authentication, so that every sector scheme adopts the same expectation rather than inventing its own. And to keep the words “verified” and “true” separate in whatever trust framework emerges.
Because the decisions are high-consequence and the evidence is already distributed. Disease control, certification, lending and market access all depend on combining records held by organisations that do not share a system, and today that chain is usually reconstructed by hand once something has gone wrong.
Yes. It is published in full on this site and can be read online or downloaded as a PDF; nothing in it is confidential. It is a public submission to a government department.
BioChain Limited’s full response to the UK Government Smart Data multi-sector call for evidence is available to read online, and the PDF can be downloaded from our resources page.
For discussions relating to Smart Data, agrifood provenance, animal-health evidence chains or potential feasibility work, contact Ashley Morgan, Chief Executive, BioChain Limited — ashley.morgan@thebiochain.com.
Key takeaways
If your organisation generates, manages, analyses or governs biological evidence and would be interested in participating in a UK or European provenance demonstrator, The BioChain would welcome the conversation.
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