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Citizens Advice published its response to Ofgem's second Energy code reform implementation consultation

Citizens Advice has welcomed most of Ofgem's second energy code reform implementation consultation, while calling for open governance duties across new code bodies and adequate resourcing for the regulator.

A newspaper on a kitchen table beside a model of rules and regulation

Citizens Advice published its response to Ofgem's second Energy code reform implementation consultation on 2 June 20251. The consumer body said it welcomes the majority of the proposals in the consultation, and set out two recommendations covering governance transparency and the resources available to the regulator1.

The first concerns the new code management arrangements. Citizens Advice noted that a currently open joint Department for Energy Security and Net Zero and Ofgem consultation on code manager licence conditions and code modification appeals to the Competition and Markets Authority refers to an objective for openness and transparency for the Code Manager within the licence regime1. It argued that the same principle should extend to all operations of the Code Manager, the Stakeholder Advisory Forum, and any subcommittees or Performance Assurance Boards1.

The response adds that these bodies should publish their decisions with explanations, and publish the details of other governance activities, for example through minutes of meetings1.

The second recommendation concerns Ofgem itself. Citizens Advice described the changes to codes and code manager governance as substantial, and said the role and expected activities of Ofgem are likely to be equally substantial in facilitating and driving those changes1. It called for sufficient resources to be provided to Ofgem to enable an efficient and effective transition to new code management bodies1. The response does not set out a figure for the resources it considers sufficient, and no cost estimate for the transition has been reported1.

Why it matters for households

Energy codes are the detailed rulebooks that govern how suppliers, network operators and other parties operate the market, including the charges and processes that ultimately feed into household bills. Who manages those codes, and how openly they decide changes, shapes how far consumer interests are represented when the rules are rewritten. The energy consultations process is where those rules are proposed and settled, and Ofgem is the body that approves and enforces them.

Citizens Advice is one of the statutory consumer bodies in this area, alongside Consumer Scotland and the Consumer Council, as set out in the guide to energy consumer bodies. Its argument here is procedural rather than about prices: that the new code bodies should be required to explain their decisions and publish how they reached them, so that households and the organisations representing them can see the reasoning. Where governance is opaque, the practical effect for a home is that changes affecting tariffs, connections or service standards can arrive without a visible account of why. The call for Ofgem to be properly resourced points to a different risk, that a slow or underpowered transition leaves the old arrangements in place longer than planned.

The wider framework of UK home energy regulation and policy determines how much of this detail reaches households directly, and how far energy suppliers pass through the costs of code administration.

What happens next

The joint Department for Energy Security and Net Zero and Ofgem consultation on code manager licence conditions and code modification appeals to the Competition and Markets Authority was open at the time of the response1. Ofgem has not published its decisions on the second implementation consultation, and no timetable for the transition to new code management bodies has been reported1.

Sources1 cited
  1. Citizens Advice response to Ofgem’s Energy code reform: second implementation consultation - Citizens Advice, citizensadvice.org.uk