Consumer Scotland published its response to Ofgem's statutory consultation on smart meter guaranteed standards of performance (GSOPs) on 10 October 2025. The body, which describes itself as the statutory body for consumers in Scotland, said it broadly supports the proposed framework and welcomed measures intended to close what it called the "accountability gap" on smart meter network issues1.
The response covers three areas: equal access to consumer protections across Great Britain, clarity and consistency with other regulatory frameworks such as the Retail Energy Code, and timeframes that are realistic but ambitious1. On installation, Consumer Scotland welcomed a six-week installation standard and the extension of the installation Guaranteed Standard equally across Great Britain, noting lower smart meter installation rates in rural, remote and island areas of Scotland1.
"We broadly support Ofgem's proposed statutory framework for improved Guaranteed Standards of Performance (GSOPs) for smart meters"
On operational issues, the body welcomed the maintenance of a five-day requirement to communicate the core issue with a smart meter to a consumer, and supported a definition covering the in-home display and a customer's bill as well as the meter itself1. It questioned whether the onus should fall wholly on the consumer to notify a supplier, suggesting a trigger to investigate should begin after a period of non-operation where readings are not reaching a supplier1.
On meters not operating in smart mode, Consumer Scotland said the proposed 90-day threshold is a long period for a meter to be without smart functionality, and recommended Ofgem keep the threshold under review and consider reducing it to 45 or 60 days1. It also said 120 days is a long period for a consumer to be without smart functionality, and that a proposed new timeframe of six months provides a sufficient incentive to suppliers1. It cited government statistics indicating around 10 per cent of smart meters installed were not operating in smart mode1.
| Item | Consumer Scotland position |
|---|---|
| Installation standard | Welcomes a 6-week standard, applied equally across Great Britain1 |
| Communicating the fault | Welcomes the maintained 5-day requirement1 |
| Not operating in smart mode | Concerned the 90-day threshold is long; suggests 45 or 60 days1 |
| Repeat compensation | Says 6 months provides a sufficient incentive to suppliers1 |
On appointments, Consumer Scotland said proposed regulation 3(1A)(b) creates risks where suppliers offer only one or two inconvenient slots, and recommended wording requiring a range of first-time appointments, or a prescribed number such as three appointments over four weeks1. It also said regulation 9A should make clear it covers both first-time and replacement installations, which it said will matter as early generation meters are replaced ahead of the 2033 switch off of 2G and 3G signals1.
Why it matters for households
Guaranteed Standards of Performance set the compensation a household can claim when a supplier misses a defined service level, so the thresholds and definitions in this consultation decide when a home's redress is triggered. Consumer Scotland's concerns centre on time: a meter sitting outside smart mode for 90 days, or 120 days without smart functionality, is a period in which a household cannot receive automatic readings, real-time usage information or tariffs that depend on them1. Its point on appointments bears on whether a household in an area with few engineers can obtain a slot at all, and its point on replacement installations bears on homes whose early meters will need changing before the 2G and 3G switch off1. The response also notes that as of December 2024 small businesses gained access to the Energy Ombudsman's dispute resolution services, and that VWAN connections from 2026 onwards could improve connectivity for rural consumers in Scotland1.
What happens next
Consumer Scotland said the proposed implementation date, starting April 2026, has the potential to impact the RTS phase out, and noted that the RTS phase out programme will pause its group code switch-off in Scotland from September 2025 until spring 20261. It recommended Ofgem keep under review its position on VWAN not being a qualifying technically eligible solution for the time being1. Ofgem's decisions on the consultation have not been reported.