Consumer Scotland published its response to Ofgem's Consumer Standards: Supplier 24-7 Metering Support statutory consultation on 16 December 2024, in HTML and PDF formats1. The consultation concerns the activation of a supplier licence condition requiring support for consumers who lose supply because of a meter fault outside normal contact hours2.
Consumer Scotland said it welcomed the opportunity to respond, and agreed with the proposal to activate supplier SLC 31G.3A(c)2. It cited Ofgem's estimate that around 83,000 consumers each year need support during out of contact hours, and noted that the period when suppliers are not contactable, between 20:00 and 8:00, is also when temperatures can be at their coldest2.
"We welcome the opportunity to respond to Ofgem's statutory consultation on Supplier 24-7 Metering Support."
The body identified access, safety, redress and information as the consumer principles most relevant to the proposal2. It said it saw value in ensuring consumers have access to information when they need it, and argued that requiring meter fault fixes to be carried out of working hours for consumers in vulnerable circumstances should form part of the regulatory framework for suppliers, adding that it will raise this in the future review of the Guaranteed Standards of Performance framework2.
On implementation, Consumer Scotland raised concerns about the clarity of changes to the Contact Ease Licence Conditions and about online-only routes. It said online-only 24/7 support should not be the sole route for consumers to raise a fault, citing households with no broadband, those in rural and remote areas with poor connectivity, and a small number of households without access to at least one mobile network operator2. It also pointed to the migration from the Public Switched Telephone Network to Voice over Internet Protocol, noting its own report finding that consumers in remote and rural areas of Scotland had greater than average reliance on landlines, poorer than average mobile signal and more frequent and longer lasting power cuts2. It cited current Ofcom guidance for providers to ensure a minimum of one hour of continuous call time in the event of a power outage2.
Consumer Scotland answered "No" to the consultation question on further implementation issues it had not considered, and agreed that the non-monetised benefits to consumers would be considerable, particularly for those in vulnerable circumstances2. It also said it would welcome Ofgem insight into whether any harm or detriment was experienced during the period the condition was dormant2.
Why it matters for households
A meter fault that cuts supply leaves a home without electricity for heating, lighting, cooking and, for some, life-sustaining medical equipment. The consultation concerns what happens when that fault occurs at night or at a weekend, when suppliers have not historically been contactable. For a household, the practical question is whether a fault can be reported and acted on at the time it happens, rather than the next working day.
Consumer Scotland's response highlights that the route used to report a fault matters as much as the hours covered. A home whose broadband runs through the electricity supply may lose internet access at the same moment it loses power, and rural and remote households may have weaker mobile coverage. That shapes how independently a household can act during an outage, and how quickly a fault can be resolved.
What happens next
Consumer Scotland said it will engage with the future review of the Guaranteed Standards of Performance framework to reiterate its position on out-of-hours fixes for consumers in vulnerable circumstances2. It also called for Ofgem to engage with Ofcom on electricity failures and to set out how such issues could be addressed, both for out-of-contact-hours meter faults and in cases of network failure2. No date for Ofgem's decision on the consultation has been reported.