Consumer Scotland published its response to Ofgem's consultation on Resetting the Energy Debt Landscape: The Case for a Debt Relief Scheme on 6 February 20251. The statutory body for consumers in Scotland, established by the Consumer Scotland Act 2020 and accountable to the Scottish Parliament, set out its position on the regulator's proposals for energy debt and repayment plans2.
The response welcomes the proposed consumer debt outcome and supports a Debt Guarantee as its consumer-facing element, arguing that a single outcome drawing together existing licence protections and Standards of Conduct should set clear expectations of what a good debt journey looks like2. On Ofgem's list of options, Consumer Scotland said: "Yes, we consider that the right options are being prioritised"2.
"Consumer Scotland welcomes the proposed consumer debt outcome"
On back-billing, the response describes the introduction of SLC 21BA as a landmark development in limiting back-billing to 12 months, except where the customer's behaviour had been obstructive or manifestly unreasonable2. It supports Citizens Advice's call, made in response to the January 2025 price cap increase, for back-billing to be limited to six months for households with a smart meter, and says reducing the limit for all billpayers should remain an ambition2. The body also supports making monthly billing the default, while saying consumers should be able to stay on quarterly billing if that is their preference2.
Other positions in the response include support for third party authorisation, agreement that suppliers should accept relevant information from a consumer's choice of third party representative, and support for consideration of the Standard Financial Statement, or the Common Financial Tool in Scotland, in ability to pay assessments2. Consumer Scotland notes that HM Revenue and Customs estimates around 8.8 per cent of the UK adult population participate in the grey economy, and that most of the data sources suppliers use are not available for those consumers2. It sees potential value in Fuel Direct and welcomes a proposal for Ofgem to work with government, suppliers and consumer groups on its administration and take-up, noting past compatibility issues with Universal Credit deductions and that consumers could not remain on Fuel Direct for ongoing usage after the debt was repaid2. It gave no comment on costs and benefits, vulnerability identification, changes of tenancy, the Debt Assignment Protocol, moving consumers in debt onto the cheapest tariff, debt collection agencies, court enforcement action, or which issues should be prioritised2.
Why it matters for households
Energy debt is the point at which a household's energy bills and energy independence meet the credit terms its supplier sets. The consultation covers the rules that decide how repayment is agreed, how far back a supplier can bill for past consumption, and who can speak for a customer in difficulty. A shorter back-billing limit would cap how far a catch-up bill can reach; monthly billing as the default would surface payment problems earlier. Consumer Scotland's support for a Debt Guarantee points to a stated minimum of care rather than guidance alone. The response does not set out figures for what any of this would save a household, and no costs or benefits were quantified in it2.
What happens next
The response was published on 6 February 20251. Ofgem's decisions on the proposals, and any timetable for them, have not been reported in these documents. Households in Scotland seeking help with energy bills and debt in Scotland can approach the energy consumer bodies named in the response, including Citizens Advice, and grant support exists through bodies such as the British Gas Energy Trust.