The Energy Saving Trust published its response on 9 April 2025 to the UK Government's call for evidence on the future regulation of default tariffs1. The charity said it agreed with the principles set out in the consultation and that no other key decisions fell outside them1.
On the type of tariffs suppliers use, the Trust backed new protections. It said an obligation should sit on suppliers to ensure customers default onto tariffs that suit their circumstances, giving the example that a tariff suited to a home heated by storage heaters is very unlikely to suit a home heated by a heat pump1. It also said suppliers should be able to offer both single-rate and time of use default tariffs, and that single default tariffs will remain important for customers who struggle to avoid high electricity use at peak times1.
"Specifically, we think that an obligation should be put on suppliers to ensure that customers default on to tariffs that suit their circumstances"
On vulnerability, the Trust said default arrangements should consider a person's vulnerability, but warned that defining a specific group as vulnerable might overlook other households that struggle with price fluctuations. It suggested consideration of an assumption of "universal vulnerability", meaning everyone is treated as vulnerable to volatile energy prices1.
For households with low carbon technologies, the Trust said default tariffs for electric vehicle owners should be smart time of use tariffs, and that protections should cover the type of tariff they default onto1. Where an EV owner has no smart meter or smart charge point, it said the default should as far as possible have a clear off-peak period for charging, such as overnight, and that a significant number of customers are likely to be in that position until the smart meter roll out is complete and SMETS1 meters have been upgraded1. It listed heat pumps, smart high retention storage heaters, electric storage heaters, electric battery storage, heat battery storage and solar PV as technologies that could influence default arrangements, and noted that a household without a smart meter cannot take advantage of smart time of use tariffs1.
| Question area | Energy Saving Trust position |
|---|---|
| Supplier obligation | Default tariffs should suit the household's circumstances1 |
| Vulnerability | Consider an assumption of universal vulnerability1 |
| Electric vehicles | Smart time of use defaults, with protections1 |
| Price cap | Reform or replace with more flexible regulation during the MHHS transition1 |
| Gas | Default gas tariff regulation should be updated if electricity protections are reformed1 |
On price regulation, the Trust said the current default price cap should be reformed or replaced with more flexible price regulations as the market transitions to MHHS, with targeted price protection kept in place for consumers who are inactive in the market. It said it has no firm view on when in that transition the change should take place, and no existing position on how to secure a greater diversity of tariff types1. It added that default gas tariffs should also be updated if electricity price protections are reformed1.
Why it matters for households
Default tariffs are what a household ends up on when a fixed deal ends and no new one is chosen, so the rules around them decide what an inactive household pays. The Trust's argument is that the tariff a home lands on should reflect how that home uses energy, which links directly to tariffs and household energy independence and to the workings of the energy price cap. Its position that a household without a smart meter cannot access smart time of use tariffs points to a gap that persists until the roll out finishes, and its call for an off-peak period for EV owners without smart equipment is aimed at that group. The proposal to reform the cap during the MHHS transition would change how energy bills are regulated for households that never switch.
What happens next
The response is the Trust's input to a government call for evidence, and no decision or timetable has been reported. The Trust said it does not have a firm view on when in the MHHS transition the price cap should change, and it called for further research on universal vulnerability1. The wider process by which such responses feed into rules is set out in energy consultations and how policy is made.
Sources1 cited
- Future default tariffs response - Energy Saving Trust, energysavingtrust.org.uk