Consumer Scotland published its response to the UK Government consultation "Fairer, Faster Redress in the Energy Retail Market" on 9 December 2025, setting out its position on the role and powers of the Energy Ombudsman. The statutory body for consumers in Scotland said the current eight-week waiting period before a complaint can be referred is too long, and that it agrees with shortening it to four weeks with exceptions1.
The Energy Ombudsman acts as an independent dispute resolution service for consumers and energy suppliers, but consumers can only use it if they are made aware of it and choose to access it1. Consumer Scotland recommended that the Department for Energy Security and Net Zero adopt two of its three proposals for tackling low awareness: advanced signposting by suppliers, and auto-onboarding of consumer details where the consumer has consented. It said the third proposal, pro-active outreach, should be further tested with consumers first, and supported the voluntary "Access for All" trial run by the ombudsman and suppliers as a place to test automatic referral1.
"Consumer Scotland agrees with shortening the waiting time before a consumer can refer their complaint to the EO to 4 weeks with exceptions"
On exceptions, Consumer Scotland said extending the waiting period may be appropriate in narrow instances where the supplier lacks the powers to resolve the issue itself, such as smart meter problems caused by faults in the Data Communications Company network, but that any extension should not be unlimited1. It pointed to Ofgem's recent decision to close the accountability gap in reforms of the Guaranteed Standards of Performance, so that consumers receive compensation for smart meter issues caused by the DCC1.
On enforcement, Consumer Scotland recommended that suppliers who fail to engage with ombudsman processes or implement decisions within 30 days should face a financial penalty. Of the proposals presented, it preferred flat rate or GSOP-style payments, noting the GSOP framework is currently under review by Ofgem1. It cited Ofgem research showing that only 41% of consumers trust energy suppliers to be fair in how they deal with consumers, against 60% for financial services and 45% for broadband suppliers1.
Consumer Scotland also questioned whether the ombudsman should be placed on a statutory footing, saying the drawbacks and potential benefits should be carefully assessed before any change, and that other ways to improve its effectiveness should be explored first1. It suggested DESNZ consider whether the deadlock letter remains a useful feature of the complaints escalation process, and explore proportionate data-sharing agreements between suppliers, advice bodies and the ombudsman, with caution around privacy and consent1.
Why it matters for households
The waiting period before a householder can escalate a complaint is the practical gate on the Energy Ombudsman route. A shorter wait of four weeks would mean billing disputes and service failures reach independent arbitration sooner, which matters where money is already in dispute. The exceptions Consumer Scotland accepts mean some cases, notably those tied to the DCC network behind smart meters, could still take longer, though it argues suppliers must keep consumers updated and that separate compensation exists for those faults1.
The enforcement proposal addresses a different problem: a decision in a householder's favour that a supplier does not act on. A 30-day deadline backed by a financial penalty is intended to make outcomes real rather than nominal1. Low awareness remains a barrier, since the service depends on consumers knowing it exists and choosing to use it1. Consumer Scotland's caution on automatic referral reflects a risk that vulnerable consumers, including those already working with advice services, could be pushed into a formal process without support1.
What happens next
The consultation response is Consumer Scotland's contribution to a UK Government consultation; no implementation dates are set out in the response. Consumer Scotland said the ombudsman's statutory status should be assessed by DESNZ before any change, and that the GSOP framework is under review by Ofgem, with any ombudsman enforcement recommendations to be joined up with that work1. The "Access for All" trial is described as currently being conducted by the ombudsman and energy suppliers1.