Consumer Scotland published its response to the Ofgem Smart Meter Guaranteed Standards: Supplier Guaranteed Standards of Performance consultation on 12 May 20251. The statutory body for consumers in Scotland said it broadly welcomes the proposals to introduce new guaranteed standards of performance for specific elements of the smart meter consumer experience2.
"We broadly welcome the Ofgem's proposals to introduce new Guaranteed Standards of Performance for specific elements of the smart meter consumer experience."
The response sets out where Consumer Scotland wants the proposed standards tightened. It says 90 days is disproportionately long for a smart meter not to be communicating with the supplier and undermines consumer protections, and suggests a shorter defined period, for example 30 or 45 days, paired with escalating compensation for delays2. It also asks whether the consumer should receive another compensation payment if the meter remains not operating for 365 days, and for every other 365-day period thereafter2. On installation appointments, it supports consumers receiving compensation every six weeks should a supplier not be able to offer an appointment in that timeframe, and supports Ofgem setting an ambitious timeframe to drive timely installations2. It proposes a standard requiring suppliers to investigate operational smart meter issues and provide a resolution plan within five working days of being notified2.
The response cites Department for Energy Security and Net Zero geographic analysis showing the proportion of installed domestic electricity smart meters in Scotland at 51 per cent, against a UK average of 63 per cent, with the lowest rates concentrated in rural and remote island areas2. It also cites analysis indicating around 10 per cent of installed smart meters are operating in traditional mode2. Second generation smart meters (SMETS2) now rely on long-range radio communications, providing coverage for over 99.5 per cent of Scotland, the response states2.
Consumer Scotland raises what it calls an accountability gap: there is currently no existing or proposed compensation scheme for consumers whose smart meter's fault is under the responsibility of the Data Communications Company (DCC), the body responsible for the telecommunications network that connects smart meters to suppliers, and the DCC has no consumer facing operation and is not subject to guaranteed standards of performance2. It draws a comparison with broadband, where the broadband supplier compensates the consumer, often automatically, and then seeks redress from Openreach via service level agreements or credits2. It also notes the current legal obligation on suppliers to offer all consumers a smart meter is due to expire at the end of 2025, and supports guaranteed standards being extended to smart meter installations for non-domestic consumers2.
Why it matters for households
Guaranteed standards of performance set the time limits a supplier must meet and the compensation a household can claim when it does not. The consultation concerns how those rules, currently written around traditional meters, would apply to smart meters and to the faults that are specific to them, such as a meter that stops communicating with the supplier. For a household, the practical question is how long a faulty meter can go unfixed before money is owed, and Consumer Scotland's position is that the proposed 90-day period is too long2. The response also points to a gap where the fault sits with the DCC rather than the supplier, leaving no route to compensation in that case2.
The rollout figures matter for energy independence in a direct sense. A working smart meter is what allows a household to see its own usage, to avoid estimated billing, and to use time-of-use tariffs and, in many cases, to add low-carbon technology such as solar panels, batteries and heat pumps2. Where installation rates are lowest, in rural and remote parts of Scotland, households have less access to those options2. Consumer Scotland's evidence on smart meters in Scotland is that the gap is not explained by supplier performance alone2.
What happens next
The response was published on 12 May 20251. Ofgem's decisions following the consultation have not been reported. The current legal obligation on suppliers to offer all consumers a smart meter is due to expire at the end of 2025, according to the response2.