Consumer Scotland published its response to Ofgem's statutory consultation on involuntary prepayment meters (PPMs) on 2 August 2023. The statutory body for consumers in Scotland, established by the Consumer Scotland Act 2020 and accountable to the Scottish Parliament, said it broadly agrees with integrating the code of practice into the supply licence, and strongly supports retaining over 85s in the "do not install" (DNI) category1.
The response states that the current system has failed to protect households facing involuntary PPM installation, and that the risk of disconnection still exists for the 421,000 consumers in Scotland using prepayment meters and 4.1 million across Great Britain1. Consumer Scotland said it supports Ofgem's more prescriptive process for suppliers, and that the revised standard licence condition 28 should incorporate the seven points set out in the consultation, with the aim of having the rules ready for winter 2023-241.
"Consumer Scotland is concerned about the inclusion of under 5s within the FAN category rather than the DNI"
The body said it questions why clinical evidence from NHS professionals for under 5s to be in the DNI category has not been upheld, and that the primary rationale for the categories should be clinical risk rather than practicality or cost1. It cited Mohan (2021), which it says showed household energy poverty was associated with 1.41 times higher odds of child respiratory illness and 1.47 times higher odds of a child wheezing1. Its Energy Affordability Tracker found that 37% of households with a child under 5 reported difficulty keeping up with energy bills, 39% reported cutting back on food to afford energy bills, and 25.8% reported rationing energy use, with 12.9% saying they could not heat their home due to financial concerns1.
On over 85s, Consumer Scotland said there are significant health risks from living in cold and damp homes or avoiding power use for cooking, and that it strongly supports retaining this group in the DNI category1. It also raised concerns about "cliff edges" for vulnerable consumers falling just outside the risk categories, called for clarity on what constitutes frequent self-disconnection, and said alternative debt recovery routes are needed where a PPM is not safe or reasonable1.
| Group | Ofgem proposal | Consumer Scotland position |
|---|---|---|
| Over 85s | DNI | Supports retaining in DNI |
| Under 5s | FAN | Wants moved to DNI |
Why it matters for households
The prepayment meter rules for vulnerable customers determine when a supplier can install a meter without a household's consent. The DNI category removes any circumstance in which a supplier may proceed with an involuntary installation, while the "further assessment needed" (FAN) category leaves more discretion with the supplier1. For a household with a young child, that difference decides whether a prepayment meter can be forced on the home at all, and with it the risk of self-disconnection where credit runs out. For a household with someone over 85, the same question applies to the risk of a cold home. Consumer Scotland's evidence points to the practical effects already reported by families with children under 5, including rationing energy and cutting back on food1. The moratorium on involuntary prepayment meter installations and the wider Ofgem regulatory framework set the context in which these categories operate.
What happens next
Consumer Scotland said the code should be integrated into the supply licence in good time to be ready for winter 2023-24, with ongoing monitoring, evaluation and review of its effectiveness1. It also called for clear definitions of terms and expectations so that suppliers apply the rules consistently1. Ofgem's decisions on the final categories, and on the treatment of under 5s, have not been reported in the response.