Citizens Advice published its response to the Department for Energy Security and Net Zero (DESNZ) consultation on the first phase of the Energy Smart Appliances (ESA) regulations under the Smart Secure Electricity Systems (SSES) Programme on 5 February 20261. The charity, which is one of the statutory energy consumer bodies in the UK, said it is broadly supportive of the direction of travel while setting out conditions it says the framework must meet1.
The response states that minimum smart functionality standards across appliances in scope will be important for consumer confidence, interoperability and usability1. Citizens Advice said smart and flexible technologies have the potential to reduce bills and support system decarbonisation, but that these benefits depend on appliances working in ways that are predictable, transparent and controllable in practice1.
"Essential services such as heating must not become difficult to manage or understand as a result of smart or automated operation."
The charity said consumers need to know when and why their appliances behave differently, and to retain meaningful control, including the ability to override automated functions1. It welcomed proposals on digital interfaces, metering, cybersecurity, assurance and flexibility guidance packs, but said these will only deliver real benefits if products are accessible and usable for a wide range of households1. Information must be clear and available in accessible formats, and accountability across manufacturers and importers must translate into clear routes to redress when things go wrong1. The framework should also support interoperability and avoid locking consumers into a single provider or restricting repair1.
Citizens Advice highlighted the importance of applying lessons from the electric vehicle smart charge point market to other appliances, particularly around load control, randomised delay and consumer expectations, and said transparency about how delay, override and flexible operation work in practice will be critical to maintaining trust1. It also noted that the Initial Impact Assessment relies on optimistic assumptions about consumer engagement, and said distributional impacts and Equality Act considerations should be kept under review, particularly for people who need predictable warmth, who may struggle with complex digital interfaces, or whose routines cannot easily shift in response to system signals1.
Why it matters for households
The ESA regulations sit within the wider Energy Smart Appliances and Automated Load Control framework, which covers appliances able to shift or delay their operation in response to signals from the grid. For a household, the practical questions are whether a heat pump, battery or smart appliance can still be run on the occupant's own terms, and whether an automated delay can be understood and overridden. Citizens Advice's response focuses on those points rather than on the technical standards themselves1.
The response also raises redress. If a smart appliance behaves unexpectedly, the household needs a clear route to a remedy, and the charity says accountability across manufacturers and importers must translate into clear routes to redress1. Existing routes for energy complaints and redress are separate from this framework, and the response does not set out how the two would connect.
On cost, the response says smart and flexible technologies have the potential to reduce bills, but does not put a figure on any saving1. No estimate of bill impacts for households appears in the response.
What happens next
The response is a consultation reply, not a decision. DESNZ has not published a response to the consultation or a timetable for the first phase of ESA regulations in the material available1. The next formal step in the energy consultations process would be the government's own summary of responses and its decision on the final rules, but no date for that has been reported1.