The Energy Saving Trust published its response to Ofgem's consultation on changes to prepayment meter standing charges and other debt costs on 30 September 2025. The charity said its submission covers questions 4, 5, 11, 12 and 13 of the consultation run by the energy regulator for Great Britain1.
On the fairness of fixed network costs falling on households with very low consumption, the Trust said these costs form a disproportionate part of the overall energy bill for such customers, many of whom are likely to be in vulnerable circumstances or facing affordability challenges. It proposed allocating costs through a targeted social tariff, for example via a flat rate addition to the unit cost for energy, and said such a tariff could be supported by mechanisms such as "energy prescriptions" for vulnerable customers, or an initial free allocation of energy. It added that any social discount could be applied to the standing charge or on a percentage basis to electricity consumed during off-peak hours, which it said would avoid distorting signals to the electricity grid about supply and demand.
"We believe a social tariff should be introduced to reduce the cost of energy bills for a subset of vulnerable consumers."
On regional variation, the Trust said the current differences in electricity standing charges were designed for the system of the 1990s, with a few centralised power stations distributing power across the UK. It said this is no longer the case, with more renewable energy generated regionally and locally, removing the argument that standing charges need to be higher in regions such as Scotland to accommodate higher distribution costs. It noted that the North of Scotland has historically paid higher standing charges and unit costs on the basis that transmission and distribution costs there are higher, and that the area is now a significant net contributor to renewable generation. Areas that are net generators of renewable energy should, as a matter of fairness and as part of a just transition to net zero, see a benefit through reduced costs, it said.
The Trust said standing charges in themselves have no impact on customers' incentives to use energy efficiently, based on its experience running Home Energy Scotland. It said many customers do not understand the difference between volumetric charges and fixed charges, simply looking at the total amount of the bill. It also said Ofgem could encourage suppliers to provide a comparison between tariffs with a higher standing charge and tariffs with a higher volumetric rate, and to make no-standing-charge tariffs available again, which it said were particularly valuable to vulnerable consumers with low usage.
On identifying vulnerable customers, the Trust said simply being able to identify that a customer is vulnerable should be sufficient to trigger tailored advice and support. It suggested linking proactive advice to social security benefits and to the Priority Services Register, which identifies people likely to be disproportionately affected in a power outage, for example due to age or medical needs. It said the biggest gap in advice provision in Great Britain is in England, and that existing provision there is patchy and variable.
Why it matters for households
Standing charges are the fixed daily amounts paid whatever energy is used, so they fall hardest on homes with the lowest consumption, including many older and vulnerable households. The Trust's argument is that the current split between fixed and unit charges, and the regional differences within it, no longer match how electricity is generated and moved around Great Britain. For a household, the practical questions raised are how much of a bill is fixed before any energy is used, whether a no-standing-charge or low-standing-charge tariff would suit a low-usage home, and whether a social tariff would reach those who need it. The Trust's position is that energy efficiency measures offer a long-term route to permanently lower bills, and that advice on them should reach fuel poor and vulnerable homes.
What happens next
The response is dated 30 September 2025 and addresses Ofgem's consultation. No decision or timetable from Ofgem following the consultation has been reported.
Sources1 cited
- Ofgem standing charges response - Energy Saving Trust, energysavingtrust.org.uk