Ofgem published the Involuntary Prepayment Meter Code of Practice in April 2023, setting out the standards suppliers have agreed to follow when moving a customer onto a prepayment meter (PPM) without their consent. The document states that it "sets clear expectations on suppliers on when it is acceptable to move a customer involuntarily to a prepayment meter (PPM) and sets out high standards for how such customers are to be treated"1.
The Code covers both installation under warrant and the remote switching of smart meters to PPM for debt without consent, including cases where a supplier installs a smart meter in credit mode and later switches it to prepayment1. It states that involuntary PPM, like disconnection, "should be a last resort for customers in payment difficulty"1. Suppliers must not execute an involuntary PPM where the debt is less than three months old after the bill was issued, or less than £200 per fuel, or where the customer is on or moving to a repayment plan1. At least 10 attempts to engage the customer across multiple channels are expected in the three months before any involuntary PPM, and a site welfare visit is required in all instances before progression1.
The Code sets out two risk categories. Where a household falls into the high risk group, suppliers "should not install a PPM"1. The medium risk group requires further assessment case by case1.
| Risk level | Examples given in the Code | Expected supplier action |
|---|---|---|
| High risk | Households needing continuous supply for health reasons, including dependency on powered medical equipment, refrigerated medication, carelines or health alarms, or a medical dependency on a warm home; households with a very elderly occupant (85+) without support in the house; chronic, severe or terminal health conditions | Do not install1 |
| Medium risk | Children under 5 or elderly 75+; other serious medical conditions; serious mental or developmental health conditions; temporary situations such as pregnancy or bereavement | Further assessment required on a case-by-case basis1 |
The Code also states that suppliers must assume any customer facing involuntary PPM for debt "is likely to be in a financially vulnerable situation and therefore more likely to self-disconnect", and must assess ability to pay where a medium risk characteristic is present1. Where a supplier concludes a household would frequently or for prolonged periods self-disconnect and risk significant harm, it "must consider PPM to be not safe and reasonably practicable"1. Each case must be assessed by a team independent of debt recovery and PPM installation1.
Energy UK, the industry body, states that "Since April 2023, energy suppliers have followed a mandatory Code of Practice for the involuntary instalation of prepayment meters offering stronger protections for customers", and that Ofgem monitors suppliers to ensure these protections are met2. Energy UK also points to the Winter 2023 Voluntary Debt Commitment, introduced with its membership and Citizens Advice, which includes further credit for prepayment customers at risk of coming off supply and extra steps to assess customers in financial difficulty2.
Why it matters for households
For a household, the Code draws a line around when a supplier can move a home onto prepayment without agreement, and what has to happen first. The debt thresholds and the 10-attempt requirement mean a recent or small debt should not, on the Code's terms, trigger an involuntary move. The high risk list is the clearest protection: where someone in the home depends on powered medical equipment, refrigerated medication or a warm home for medical reasons, the Code says a PPM should not be installed1.
The practical effect on a home's energy independence turns on self-disconnection. A prepayment meter requires topping up to keep supply running, and the Code itself treats customers moved onto one for debt as more likely to self-disconnect1. That is why the ability-to-pay assessment and the medium risk checks matter: they are the point at which a supplier is expected to judge whether a household could keep the meter fed. Where a PPM is not suitable, the Code says alternative debt recovery actions must be "fair, reasonable and appropriate" for the customer's circumstances and level of debt1.
What happens next
The Code states it "will be subject to monitoring and review in relation to its compliance by suppliers, consumer outcomes and in relation to consumer behaviour, should this lead to significantly higher levels of bad debt"1. No further dated steps are set out in the document. Energy UK's guidance, last updated in November 2025, states that Ofgem monitors suppliers against these protections and directs customers who believe their protections are not being met to the Citizens Advice Consumer Service2.
Sources2 cited
- Involuntary PPM Code of Practice, ofgem.gov.uk
- Support for energy bills - Energy UK, energy-uk.org.uk