Citizens Advice response to consultations on code reform implementation and code manager licencing
As the statutory consumer advocate for energy consumers Citizens Advice has engaged in the detailed work of industry codes for many years and we have a unique perspective of their operation.
They represent a fundamental part of the whole energy system and they govern and facilitate significant changes which affect all end consumers of energy.
Across both consultations from Government and Ofgem we welcome much of the direction of code reform including:
which codes will be consolidated
the intention to revise code objectives and improve code modification processes
the constitution of the Stakeholder Advisory Forum (SAF)
the requirement for code managers to be not for profit bodies
the levels of prescription in the code manager licence
the consideration of the role of statutory consumer advocates in future processes
In the two responses we set out areas for clarification and a number of recommendations including:
Identifying areas of codes for part consolidation early on
Introducing a consumer benefit code objective to align with Ofgem’s statutory duties and a consumer interest licence condition
Providing a formal appeals route for code manager budgets
Providing additional checks and balances to the performance regimes of code managers where there are not licenced or codified financial incentives
Requiring a consumer champion to code manager boards in line with the FCAs Consumer Duty
Citizens Advice response - Energy code reform: implementation consultation 168 KB