Addressing consumer harms in the non-domestic market

In recent months, Ofgem has shone a light on areas across both the domestic and non-domestic market where suppliers could improve their practices for customers and go beyond what they are obligated to do in the licence conditions. In a time of significant and extended volatility, the regulator has brought attention to several issues that non-domestic consumers in particular are facing in the market; for example, excessive security deposits and risk premia, difficulties with contacting suppliers, and increased charges under deemed rates and in standing charges. Ofgem has called on suppliers to take action to address these problems, and in December 2022, published a letter setting out a range of good practices regarding the handling of debt and disconnection. It advised that suppliers should look to incorporate these recommendations into their day-to-day operations.

Ofgem has made it clear that transparency with customers is key for engagement, with a focus on supplier collection processes occurring when a customer falls into debt. It noted that many suppliers include a copy of their collections process on their website to allow customers to understand what stages occur and when. It also recommended suppliers should review their debt and disconnection pathways, and that where these are short, they ensure that proactive communication is made with customers. Examples given include sending letters at key stages of the pathway and following this up with phone calls, or through the customers preferred method of communication.

Where charges are concerned, Ofgem highlights that suppliers should ensure the security deposits their customers pay are set appropriately and should not exceed a “reasonable amount”. To refund a customer, Ofgem also recommends that, where it is fair and reasonable, it should be returned within 10 working days to the customer. During the disconnection process, charges should be “reasonable and proportionate” in the way they are applied – suppliers have been encouraged to empower employees to be flexible, and where appropriate, to waive certain charges.

Another key point made by the regulator is the ability to check for vulnerable customers. While there has been a keen focus on this in the domestic market with a market compliance review, those domestic customers who are in a shared occupancy with non-domestic premises are not to be forgotten. Suppliers should use site visits as an opportunity to identify any domestic residents and assess whether they fall into the vulnerable category. Where they do, non-domestic suppliers should take all reasonable steps to avoid disconnection and ensure that they sign up to the Priority Services Register if possible.

Further to this point, the regulator highlights the importance signposting to third parties and the provision of key information. Given the current energy market volatility and exposure to high prices, it is imperative that where consumers find themselves struggling, suppliers can point them towards help, for example through organisations such as Business Debtline, and Citizens Advice.

In a more recent letter on 3 February, Ofgem reiterated the above points directed that non-domestic suppliers should conduct a board-level review of their procedures regarding debt and disconnection, in relation to the key points it outlined in its December letter, by 14 February. The aim of this is to ultimately improve the customer experience and outcomes, and that by implementing more of these good practice recommendations, suppliers can help to provide some reassurance to customers in a market that continues to fluctuate.

We keep track of all updates and developments to the supplier compliance landscape, similar to that included in today’s blog, for both domestic and non-domestic suppliers through our Energy Supplier Compliance Portal. If you are interested in attending our compliance update webinar for suppliers on 9 February at 10am, click here to sign up.

If you have any questions about our services or would like to sign up for a free two-week trial to see our new Compliance Portal, please get in touch through email with

This advert shows our Energy supplier compliance portal, which is a one-stop-shop for suppliers. Find out more by contacting

Related thinking

Low carbon generation

Latest developments in the TPI space

We recently published our 2023 Annual TPI report which provides an independent review and analysis of the market for TPIs, and the services provided by them. The report also looks at the current challenges and opportunities for TPIs, such as regulatory changes, competition with suppliers, and diversification of services. 2023...

Regulation and policy

What’s going on with REGOs?

Renewable Energy Guarantees of Origin, more commonly referred to as REGOs, are certificates issued to accredited renewable generators for every MWh of electricity they produce over a year period. The initial intentions of these certificates were to provide suppliers a means to prove the level of renewable generation they received...

Home supply and services

Ofgem strives to improve consumer experiences across both the domestic and non-domestic sectors

Over the last week, a number of anticipated publications were issued by Ofgem that hold the potential to make a significant change to the requirements on both domestic and non-domestic suppliers. The findings of Ofgem’s non-domestic market review were revealed, alongside a policy consultation on the options available to address...

Energy storage and flexibility

Waiting to connect: the problems and solutions for network connection queues (Part 2)

Network connection queues continue to be a notable topic of interest as many generators face significant delays to project development – an issue that is directly conflicting with net zero ambitions and recent focuses on strengthening domestic energy supplies. In Part 1 of our two-part series on connection queues we...

Energy storage and flexibility

Waiting to connect: the problems and solutions for network connection queues

The number of grid applications has risen significantly in recent years, resulting in increased pressure on the electricity networks to facilitate new connections. In its Energy Security Strategy, the UK government set out ambitions for 95% of electricity to be sourced from low carbon generation by 2030, and for the...

Energy Market Design

Are prices going to rise in Contracts for Difference Allocation Round 5?

A number of factors may be about to put an end to the trend for falling energy prices in the Contracts For Difference (CfD) scheme. The CfD scheme has provided strong subsidy support whilst also providing consumers robust levels of protection. High investor confidence and steady reductions in capital costs...

Business supply and services

What happened in 2022 in the energy market?

The GB energy market never stands still and 2022 was no different. In this infographic, we look back at some key happenings from the past year in different segments of the GB energy market.  Click the image below to see our snapshot.

Business supply and services

Terms and conditions apply: Ofgem looking further into business market

As turbulence has continued in the wholesale energy markets throughout 2022, including through the crucial October contracting round for the business supply market, non-domestic energy suppliers have come under considerable pressure. Firstly, they have had to attempt to pass through extraordinary price increases to customers in recent months, particularly if...