Ofgem has published an open letter consulting on modifications to the electricity supply licence that would amend current electricity metering obligations, with the stated aim of further protecting consumers1. The consultation concerns the wind-down of the Radio Teleswitch Service (RTS), which is due to cease in June 20251.
Consumer Scotland, the statutory body for consumers in Scotland established by the Consumer Scotland Act 2020 and accountable to the Scottish Parliament, published its response to the consultation on 11 March 20251. It said it welcomed the proposed policy intention and identified access, safety and redress as particularly relevant to the proposal1.
"We welcome the proposed policy intention set out in Ofgem’s Open Letter."
Consumer Scotland said the industry has been aware of the need to switch off the RTS signal for well over a decade, and that several extensions have already been granted, reflecting concerns about industry readiness and the need for continuity in access to affordable and fair tariffs1. It said consumers of different suppliers are experiencing different levels of care and support with the RTS switchover, and that these concerns have previously been shared with Ofgem through forums such as the Energy Consumers Network, which Consumer Scotland convenes1.
The response sets out risks it says RTS consumers face after the service ends. It cites Ofgem’s acknowledgement in the consultation that RTS consumers "may also be at risk of higher bills or going off supply" and "may experience disruption to their heating or hot water provision within their home or business, or potentially will experience higher rates of tariffs when their RTS meters fail to switch between the different rates"1. Consumer Scotland said this risk is compounded in rural areas such as the Highlands and Islands, where a significant proportion of RTS meters in Scotland are located, and that it remains unclear whether consumers with RTS meters will be able to be restored to supply effectively following a power cut once the service is discontinued1.
On barriers to replacement, Consumer Scotland pointed to constraints under the Distribution Connection and Use of System Agreement, specifically in relation to Load Managed Areas in the north of Scotland, which it said may be contributing to the low rate of RTS meter replacements in the Scottish Hydro Electric Power Distribution licence area1. It said rural consumers experience significant difficulties securing supplier engineer appointments, and that it has previously advocated for a coordinated, area-based approach to RTS meter replacements across suppliers1.
On tariffs, Consumer Scotland said concerns about affordability after meter replacement have been heightened by the recent price cap announcement, which it described as setting out a third successive price increase and a 4.5% increase for Economy 7 consumers1. It said that as not all suppliers offer Economy 10 tariffs, there is a real risk of reduced consumer choice, which could leave affected consumers with fewer competitive options and in some cases higher costs1.
Consumer Scotland said it accepts the need for an "All Reasonable Steps" exception for suppliers, but that it should be construed narrowly and apply only where a supplier has demonstrably taken all reasonable steps to replace the RTS meter, and where any alternative action would result in the consumer being off supply1. It recommended that explicit protections and compensation mechanisms are established for affected consumers, drawing a parallel with Regulation 5 of the Electricity and Gas (Standards of Performance) (Suppliers) Regulations 2015, which addresses faulty prepayment meters1.
Why it matters for households
RTS meters switch between different rates using a broadcast signal, and some also control heating and hot water. If the signal stops before a meter is replaced, the response states that households may face incorrect or unpredictable bills, loss of supply, or disruption to heating and hot water1. For a home, that affects both the reliability of supply and the ability to know what a unit of electricity costs, which is central to any household trying to manage its own energy use and cost.
The consultation sits within the smart meter rules and supplier obligations that govern how and when meters are exchanged, and within Ofgem’s role as energy regulator. Where a replacement meter changes the tariff structure available, the choice of tariff and the ability to compare it against alternatives bears directly on a household’s running costs. Consumer Scotland’s points on Economy 7 and Economy 10 relate to time-of-use tariffs, which reward shifting demand to cheaper periods; the current transformers and sensors used in home monitoring are a separate matter from the meter itself. Households in the north of Scotland face additional constraints through Load Managed Areas, which the response links to slower replacement rates1.
What happens next
The RTS service is due to cease in June 20251. Consumer Scotland said it looks forward to Ofgem publishing a summary of supplier responses on measures to mitigate consumer detriment1. No date for that publication is given in the response.