National Energy Action (NEA) published its response to Ofgem's call for evidence on prepayment rules and protections on 14 March 20231. The charity said the regulator is consulting on enhancing protections for customers regarding the forced installation of prepayment meters1.
NEA set out four areas it believes need significant consideration1. The first is the level of prescription in the licence, particularly in relation to ensuring installations are "safe and reasonably practicable", which NEA says currently leads to divergent outcomes depending on each supplier's interpretation of the principle1. The second concerns the types of households that should never have a prepayment meter installed under warrant, beyond those with mental health issues, who NEA notes are already protected explicitly in the licence1.
The third area is clarity over the equivalence of remote switching of smart meters to prepay mode and the installation of legacy prepayment meters, both with and without a warrant1. The fourth is the timing of the current ban on prepayment meter installations1.
"There is a need to ensure that the current ban on prepayment meter installations does not end before there is confidence that the rules have been sufficiently tightened and clarified, and that suppliers are adhering by the rules that they have set."
The four areas NEA identifies are:
| Area | NEA's position |
|---|---|
| Licence prescription | The "safe and reasonably practicable" test produces divergent outcomes depending on supplier interpretation1 |
| Protected household types | Consideration needed beyond households with mental health issues, already protected explicitly in the licence1 |
| Remote switching equivalence | Clarity needed on whether remote switching of smart meters to prepay mode is equivalent to installing legacy prepayment meters, with or without a warrant1 |
| Installation ban | The ban should not end before rules are tightened, clarified and shown to be followed1 |
Ofgem has not published a response to the call for evidence, and no date for the end of the installation ban has been reported1.
Why it matters for households
A prepayment meter changes how a household pays for energy: credit is bought in advance, and supply can stop when the credit runs out. The rules that govern when a supplier can install one without the household's agreement, and under what safeguards, therefore bear directly on a home's energy independence, because they determine how much control a household keeps over its own supply.
NEA's response points to a gap between a principle written into the licence and what happens in practice. If "safe and reasonably practicable" is interpreted differently by different suppliers, two households in similar circumstances could see different outcomes1. The question of which households should never have a meter installed under warrant is also unresolved beyond the mental health group already named in the licence1.
The remote switching point matters because a smart meter can be moved to prepay mode without anyone visiting the property. NEA asks for clarity on whether that is equivalent to fitting a legacy prepayment meter, with or without a warrant1. If the two are not treated as equivalent, the practical protections attached to a home visit may not apply to a switch made remotely.
The installation ban is the backstop. NEA's position is that it should remain until the rules are tightened, clarified and demonstrably followed1. For households, the ban is the difference between the current pause and a return to installations under the rules as they stand.
What happens next
No next steps have been reported. Ofgem's call for evidence is the process NEA has responded to, and the timing of any decision on the rules, or on the end of the installation ban, has not been published1. Households wanting the background on how prepayment rules and protections work can read the site's guide to prepayment meters and vulnerable customer protections, and on the regulator's role in Ofgem: what the energy regulator does and what it covers. The mechanics of forced installation are covered in disconnection, warrants and forced prepayment installation, and how these tariffs work in prepayment and pay as you go energy tariffs.