Citizens Advice published its response to Ofgem's consultation on the energy price cap benchmark consumption review on 30 September 20251. The charity said it agrees with the regulator's minded-to proposal, subject to caveats1.
The response concerns the benchmark consumption values that sit behind the price cap, the figures used to illustrate what a typical household pays. Citizens Advice said Ofgem should set out how it assesses the impact on headroom allowances when it makes methodological changes to the price cap, and that this should be done consistently1.
"We agree with Ofgem's minded-to proposal with some caveats."
"Ofgem should make clear how it assesses impact on headroom allowances when making methodological changes to the price cap and ensure this is done in a consistent fashion."
The response document runs to 80.8 KB and was published alongside the charity's consultation submission1. The specific benchmark figures Ofgem proposed, and the size of any change to them, have not been reported in the published response summary1.
Why it matters for households
The benchmark consumption values are the assumed usage levels behind headline price cap figures. They determine what the quoted annual bill actually represents, so a change to them changes the number a household sees when the cap is announced, even where the underlying unit rates are unchanged. For a home trying to judge its own energy independence, whether through usage reduction, typical domestic consumption values or a different tariff structure, the benchmark is the yardstick against which its own consumption is compared.
Headroom is the allowance within the cap that lets suppliers absorb cost changes without immediately passing them through. How Ofgem assesses the effect of methodological changes on that allowance therefore bears on how much of a cost swing reaches bills and how quickly. Citizens Advice's caveat is about the transparency and consistency of that assessment rather than opposition to the proposal itself1.
Citizens Advice is one of the statutory energy consumer bodies in the UK, alongside Consumer Scotland and the Consumer Council for Northern Ireland. Its consultation responses form part of the process by which energy rules are proposed, decided and changed, overseen by Ofgem.
What happens next
No next steps, timetable or decision date for the benchmark consumption review are given in the published response1. Ofgem's final decision on the review has not been reported1.