Citizens Advice published its response to Ofgem's statutory consultation on involuntary prepayment meters (PPMs) on 26 July 2023. The charity said it supports Ofgem's proposal to move the Prepayment Meter Code into supplier licence conditions, and set out four amendments it wants made to the code as part of that process1.
The proposed changes are: include children under the age of 5 in the Do Not Install category; include the treatment of certain serious mental and developmental health conditions in the Do Not Install category; clarify the treatment of chronic obstructive pulmonary disease (COPD) and its constitutive conditions by moving it into the high risk category; and clarify the timetable for the 10 contact attempts to engage with the consumer1.
"Citizens Advice welcome this consultation, which has the potential to improve the regulatory landscape for people affected by prepayment meters."
The charity said the risks of force-fitting a prepayment meter are now greater than when the rules on involuntary PPMs were first introduced, pointing to high energy prices and the wider cost of living crisis. It said Ofgem is "taking the correct steps to supplement principles-based regulation with more detailed guidance in this area" and that it supports formalising the changes by integrating them into the supply licences1.
Citizens Advice also raised enforcement. It said it has been encouraged by Ofgem's recent approach to monitoring and enforcement through tools such as Market Compliance Reviews, and by the monitoring arrangements proposed in the consultation, adding that together these "provide a more secure basis to safeguard vulnerable consumers in the future"1.
| Proposed amendment to the PPM Code | Change sought |
|---|---|
| Children under 5 | Add to the Do Not Install category |
| Certain serious mental and developmental health conditions | Add treatment of these to the Do Not Install category |
| COPD and its constitutive conditions | Move into the high risk category |
| The 10 contact attempts | Clarify the timetable for engaging the consumer |
Why it matters for households
Involuntary prepayment installation is the process by which a supplier moves a household onto a prepayment meter without the occupier's consent, usually to recover debt. The rules governing who can and cannot be moved onto one, and what a supplier must do first, sit in the Prepayment Meter Code and, under Ofgem's proposals, would sit in supplier licence conditions instead1. Licence conditions are enforceable obligations, which is the basis for Citizens Advice's support for the move1.
The Do Not Install category is the group of households where installation is not permitted at all. Widening it to include under-fives and certain serious mental and developmental health conditions would extend the protection to more homes, if Ofgem adopts the amendments. Moving COPD into the high risk category would not bar installation outright but would place it in a group subject to stricter handling under the code1.
For a household, the practical effect of a prepayment meter is that energy is paid for in advance and supply can stop when the credit runs out. That makes the accuracy of the vulnerability categories, and the number and timing of attempts a supplier must make to contact the occupier before installing, directly relevant to whether a home keeps its supply. The prepayment meter moratorium and the wider rules on prepayment and vulnerable customers set out how these protections operate, and the forced prepayment meter rules cover what a supplier must do before switching a meter.
What happens next
Citizens Advice said the success of the changes will depend on prioritising monitoring and enforcement, "especially over the course of the first winter that they apply (2023/24)", to ensure suppliers implement them and that they lead to better outcomes for consumers1. Ofgem's decisions on the consultation, and whether it adopts the four amendments, have not been reported in the response.
Sources1 cited
- Statutory Consultation - Involuntary PPM - Citizens Advice, citizensadvice.org.uk