Consumer Scotland published its response to an Ofgem consultation on electricity metering obligations on 11 March 2025, backing the regulator's policy intention while calling for tighter conditions on how suppliers may be excused from replacing Radio Teleswitch Service (RTS) meters1.
The statutory consumer body for Scotland said the industry has known about the RTS switch-off for well over a decade, and that several extensions have already been granted1. It said consumers of different suppliers are experiencing different levels of care and support with the switchover, and that these concerns have previously been shared with Ofgem through the Energy Consumers Network that Consumer Scotland convenes1.
"We welcome the proposed policy intention set out in Ofgem's Open Letter."
On the proposed "All Reasonable Steps" exception, Consumer Scotland said it accepts the need for one but that it should be construed narrowly and apply only where two conditions are both met: that a supplier has demonstrably taken all reasonable steps to replace the RTS meter, and that any alternative action would result in the consumer being off supply1. It also recommended explicit protections and compensation mechanisms for affected consumers, pointing to Regulation 5 of the Electricity and Gas (Standards of Performance) (Suppliers) Regulations 2015, which addresses faulty prepayment meters, as precedent1.
The response sets out risks it says RTS consumers face after the service ceases in June 2025, quoting Ofgem's own consultation that such consumers "may also be at risk of higher bills or going off supply" and may see disruption to heating or hot water or higher tariff rates when meters fail to switch between rates1. It notes a significant proportion of Scotland's RTS meters are in rural areas such as the Highlands and Islands, where power cuts are already more likely and longer lasting1.
On tariffs, Consumer Scotland said recent price cap changes set out a third successive increase and a 4.5% rise for Economy 7 consumers, and that not all suppliers offer Economy 10 tariffs, risking reduced choice and higher costs for some1. It also said constraints under the Distribution Connection and Use of System Agreement, specifically for Load Managed Areas in the north of Scotland, may be contributing to low replacement rates in the Scottish Hydro Electric Power Distribution licence area, and repeated its call for a coordinated, area-based approach across suppliers1.
| Consumer Scotland position | Detail |
|---|---|
| Exception to replacement | Should apply only where all reasonable steps taken and alternative would leave consumer off supply1 |
| Redress | Explicit protections and compensation mechanisms recommended1 |
| Tariff protection | Consumers should be no worse off after meter replacement1 |
| Replacement approach | Coordinated, area-based approach across suppliers advocated1 |
Why it matters for households
RTS meters rely on a radio signal to switch between peak and off-peak rates, commonly used with Economy 7 and other restricted meters. If the signal ends before a meter is replaced, a household can be billed at a single, usually higher, rate, or lose the timed switching that heats water or storage heaters. Consumer Scotland's response describes both outcomes as live risks for households in Scotland, particularly in rural and vulnerable circumstances1.
The consultation concerns smart meter rules and supplier obligations and sits within Ofgem's remit as energy regulator. For a household, the practical question is whether its supplier replaces the meter in time and on terms that leave bills no higher. Consumer Scotland's call for a compensation route mirrors the existing complaints and redress system for other metering failures, though no such scheme for RTS consumers has been confirmed.
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. Ofgem's decisions on the licence modifications and on any redress mechanism have not been reported.