Creation of a Mechanism to Allow Third Parties to Report Objection Activity

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    Issue Rejected
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Issue Rejected
Summary
Presently only industry parties can raise the matter of non-compliant or unwarranted objections activity that a supplier may be participating in. This Issues has been raised to request RECCo to consider accepting notice and evidence (that can be acted upon) from qualifying 'non industry' parties, from third party consultants and brokers.

Latest update and next planned activity

Date of latest update
Latest Update
15/07/2025 - The Code Manager has rejected Issue I0213. This Issue has been deemed out of scope of the REC and has been rejected following a legal review. This decision was ratified by the REC Change Panel at their meeting on 15 July 2025.

Impacts Overview

Impacted Consumers
Electricity Gas Domestic Non-Domestic
Impacted REC Parties and Market Participants
Energy Supplier Shipper Other
Impacted REC Documents
Schedule 30 - Resolution of Consumer Facing Switching and Billing Issues
Priority and rationale
Standard

Priority last updated on 29 May 2026

Solution development

Problem Statement
There is currently not a method for Third Parties, who may be involved in the Switching process, to report non-compliant Objection activity. Non-Compliant Objection activity can result in time consuming procedures for Consumers, creating unnecessary engagement with Energy Suppliers, and may result in a financial burden.
Proposed solution summary
  1. I0213 has been raised with a suggestion that the Code Manager should consider accepting notice and evidence from qualifying non-industry Parties, including Third Party consultants and brokers (Third Party Intermediaries (TPIs)). A possible solution for this may include a new submission page, or form, on the REC Portal, that would allow Third Parties to submit evidence of non-compliant Objection activity.

No documents available.

Change Plan

Proposal Plan Approved at REC Change Panel

Completed

Start:

Due:

Completion:

06 May 2025

Original submission

Change details

Simon Askew - Energy Consultants Association
16 Sep 2024

Change details

Creation of a mechanism to allow third parties to report objection activity that is not compliant with code or licence conditions for energy supply.
Presently only industry parties can raise the matter of non-compliant or unwarranted objections activity that a supplier may be participating in. We believe that RECCo needs to consider accepting notice and evidence (that can be acted upon) from qualifying 'non industry' parties, from third party consultants and brokers.
Objections activity that is not allowed by licence or code damages our industry in so many ways. Without a central place to raise these with RECCo, there's no way for RECCo to know if the objections RECCo has visibility of, are legitimate or not. This objection activity has been, in our view, the single biggest problem for customers that attempt to change suppliers, for the past two decades. It results in hundreds of thousands of wasted hours each year, creating unnecessary engagement with suppliers, along with a financial burden on customers that have no desire to pay higher out of contract or deemed prices. The unintended consequence of this objection activity results in many industry complaints and a 'debt' burden to the industry as the supplier often struggle to recover what can be considered overcharges imposed on the customers.
RECCo could create a page on the portal that captures the necessary information to enable RECCo to automatically request evidence to support the reason for objecting, from the objecting supplier. This could be automated or partly automated at least. We believe that once suppliers start seeing the frequent requests to justify objections from RECCo, that their behaviour will change, they will prefer not to have the spotlight shining on them. We are certain that a a trial prior to adopting this as a RECCo process would evidence a shift in behaviour after a short period.
We have provided a spreadsheet to the Code Manager, of evidence of objections activity from an anonymous Supplier that objected to 76 supplies, a total of 242 times. We have further supporting information that evidences Suppliers acceptance that they objected unlawfully, should RECCo request it.

Impacts

Electricity, Gas, Domestic Prepayment, Domestic Credit, Microbusiness, Small and Medium Enterprise (SME), Industrial and Commercial (I&C), Other (please specify in the Additional information box below)
Switching experience, Billing accuracy, Trust and confidence, Ability to pay
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Schedule 30 - Resolution of Consumer Facing Switching and Billing Issues
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No details provided
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No details provided
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No details provided
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No details provided
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No details provided
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Energy Suppliers, Shippers
Third-party intermediary
No details provided
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No
No details provided

Priority & timing

No
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Yes, we believe that the evidence we have provided, and the historical data and evidence of objections behaviour that RECCo has access to, is sufficient justification. We would like to see the reporting facility be made available to coincide with the new industry approved COT process (date TBC).
Dependent on R0155
No details provided
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Activity

Status has been changed to Issue Rejected.
james.hardy has been allocated as Lead Analyst.