Citizens Advice published its response to an Ofgem consultation on the energy price cap's technical approach to market wide half hourly settlement (MHHS) on 6 May 20261. The consumer body said it broadly supports incremental reform of the cap rather than fundamental change, and set out its opposition to placing all default consumers on a default time-of-use (ToU) tariff1.
The consultation concerns how the energy price cap should be adapted for MHHS, the settlement reform that requires half hourly metering and settlement across the market. Citizens Advice said the introduction of MHHS will require targeted changes to keep the cap compatible with market offerings, but that on current evidence there is no case for more fundamental reform at this stage1. It called for any future plans to be grounded in evidence and supported by robust modelling of distributional impacts across consumer groups1.
On tariff structure, the response supports maintaining a single-rate cap and introducing a ToU cap variant, and opposes a default ToU tariff for all default consumers1. Citizens Advice said this approach fails to recognise that many consumers cannot use energy flexibly, and that where consumers face additional barriers to switching, for example because of debt, they may be effectively locked into tariff structures incompatible with their consumption patterns, which could cause their costs to rise1. It said targeting should focus on consumer groups where flexibility is more established, such as users of low carbon technologies, particularly when rolling off existing tariffs1. It also warned that multiple default variants or overly granular segmentation risk increasing complexity for consumers and suppliers and could undermine the protective functions of the cap1.
The response restates support for cost-reflectivity within the cap while calling on Ofgem to conduct distributional analysis of that principle's impact on consumers, with further intervention where negative outcomes are identified1. Citizens Advice also reiterated support for Ofgem's Cost Allocation and Recovery Review (CARR) and encouraged Ofgem to set out clearly how interactions between this work and the CARR will be managed1.
"We broadly support incremental reform to the price cap, which we believe should involve maintaining a single-rate cap and introducing a ToU cap variant."
"We do not support proposals to move all default consumers onto a default ToU tariff."
Why it matters for households
The price cap sets the default rates most households pay when they do not choose a fixed or other tariff, so how it treats time-of-use pricing determines whether a household that cannot shift its usage is exposed to higher costs. Citizens Advice's position is that a single-rate cap should remain available, with a ToU variant added rather than imposed1. For a home weighing a tracker or time-of-use tariff against the cap, the practical question is whether flexible pricing suits the household's actual pattern of use. The response notes that some consumers, including those in debt, may be unable to respond to price signals and could see costs rise under a structure mismatched to their consumption1. It also flags that reverting to current default arrangements for users of low carbon technologies may reduce incentives to use them flexibly and may not fully reflect system costs1.
What happens next
The response was published on 6 May 20261. No decision date or timetable for Ofgem's next steps on the consultation has been reported. Citizens Advice has asked Ofgem to clarify how this work interacts with the Cost Allocation and Recovery Review1. How the consultation process concludes, and whether the cap gains a ToU variant, has not been reported.