Consumer Scotland has published its response to an Ofgem consultation on tackling energy debt that arises when consumers move house, setting out tentative support for reform alongside a series of risks and recommendations. The response was first published on 21 January 20261. Consumer Scotland describes itself as the statutory body for consumers in Scotland, established by the Consumer Scotland Act 2020 and accountable to the Scottish Parliament1.
The consultation it answers is Ofgem's debt strategy update of November 2025, which covers debt arising at change of tenancy1. Consumer Scotland says it is worth exploring reforms to the change of tenancy process "given the proportion of overall debt that arises where there has been a change in housing occupant", and that it therefore tentatively supports Ofgem's early thinking1. It adds that the changes in question are substantial and will fundamentally alter the home move process for consumers1.
The response raises specific concerns about rented homes. It says the call for input largely discusses circumstances where there is no gap between two occupants, as in a house sale, but that in rented accommodation there will commonly be a gap between one resident moving out and the next moving in, during which the landlord or letting agent is responsible for supply1. That interim period "could in some cases be days, but in others could be weeks or months"1. Without two separate notifications to the supplier, Consumer Scotland warns, tenants could become liable for energy bills incurred before their tenancy began, or nominal credit on the account could be used by the landlord before the new tenant moves in1.
On prepayment, Consumer Scotland says it understands Ofgem intends to allow a meter to be switched to prepay only where it is known there is no occupant, and would welcome confirmation of this in future consultations1. It also states it is unclear of the rationale for Ofgem's suggestion to apply a zero standing charge tariff by default where there has been a change of tenancy1. On payment method more broadly, it notes that Ofgem reports smart prepay customers tend on average to be the most satisfied cohort of consumers1.
The response cites research from health charities that a terminally ill person's energy bills can rise by 75% after diagnosis, and a case study putting additional average estimated monthly costs, before heating and typical electricity costs are accounted for, at more than £2701. On how quickly a household can act, it says: "we cannot assume that every household will be capable of contacting an energy supplier as soon as they move in, a week or two of credit should be the minimum expectation"1.
Where suppliers fail to deliver, Consumer Scotland says there should be harsh and immediate penalties, which "could be in the form of a Guaranteed Standard of Performance payment, as well as Ofgem enforcement action"1. It also recommends a broad consumer awareness campaign and individual communications waiting for a new occupant on arrival1. Asked for evidence on levels of debt or arrears relating to change of tenancy, the response answers "No answer."1
Why it matters for households
Energy debt tied to a change of tenancy is a household-level problem before it is a supplier-level one. A new occupant who cannot reach a supplier quickly, or whose account is set up slowly, can face a gap in supply or an unexpected prepayment meter, and Consumer Scotland identifies self-disconnection as the main risk, particularly for people with health conditions or at-home medical equipment1. The interim period between tenancies matters for energy bills and energy independence, because responsibility for supply sits with the landlord or letting agent in that window, and unclear boundaries can leave a tenant paying for energy used before they moved in1. For households in Scotland, the process runs through distinct housing and tenancy law, which Consumer Scotland says will affect how any change of tenancy rules work in practice1. Existing routes for help with energy bills and debt in Scotland and for grants for energy debt operate alongside whatever Ofgem decides.
What happens next
The response is Consumer Scotland's contribution to an Ofgem consultation, and no decision or implementation date is set out in it1. Consumer Scotland asks Ofgem to test proposals against a range of consumer archetypes and change of tenancy scenarios rather than only straightforward cases, and to confirm its intention on prepayment switching in future consultations1. It also offers to contribute further to the design of the process1. Ofgem's next steps on the consultation have not been reported in the material published by Consumer Scotland1.