REC Changes to tie in with DCP451 - Suspending Registrations
Summary
A DCUSA Change Proposal - DCP 451 ‘Suspending Registrations’ - has been raised to look into this issue. The solution must consider a cross-code solution, which does not put consumer outcomes at risk.
Latest update and next planned activity
Date of latest update
Latest Update
This Change Proposal was implemented as part of the 7 November 2025 REC Release.
Impacts Overview
Impacted REC Parties and Market Participants
Distribution Network Operator
Energy Supplier
Impacted REC Documents
Schedule 24 - Switching Data Management
Other Industry Codes impacted
Distribution Connection and Use of System Agreement (DCUSA)
Priority and rationale
Standard
Priority last updated on 29 May 2026
Solution development
Problem Statement
A lack of clarity on the process for when a DNO ends a Regulatory Alliance with an Energy Supplier can cause confusion with the Energy industry, and lead to poor Consumer outcomes if the correct process is not followed.
No documents available.
Change Plan
Change Report (Proposal Plan) approved by Change Panel
Completed
Start:
Due:
Completion:
17 Jun 2025Change approved
Completed
Start:
Due:
Completion:
05 Aug 2025Original submission
Change details
- - -
6 Mar 2025
Change details
REC Changes to tie in with DCP451 - Suspending Registrations
Under the DCUSA, there are provisions allowing a DNO to suspend a Supplier from registering meter points within their network by terminating their Regulatory Alliance. These are listed within DCUSA clauses 54.2 and other clauses referenced within those paragraphs. The process for terminating these Regulatory Alliances is documented within REC Schedule 24 where the DNO can update the Regulatory Alliance Data Items within CSS via the CSS API.
Recent enquiries from DNOs have highlighted the following:
1. There is a need to clarify the link back to the DCUSA clauses to ensure it is clear that the use of the CSS functionality listed in REC Schedule 24 clauses 4.10.7 and 4.10.8 is only permitted in accordance with DCUSA and any such action would be governed under that Code and not under the REC.
2. There is a need to ensure this action is only taken when authorised and clarify where the responsibility lies to review and/or approve such actions.
3. There is a need to set out what controls prevent DNOs from terminating a Regulatory Alliance incorrectly to prevent delays to switching and any subsequent consumer and market participant detriment.
4. There is a need to clarify how interested parties e.g. the impacted Supplier, other Code Bodies, etc. are notified to allow them to manage potential downstream impacts of such action.
5. There is a need to clarify the operational processes used by the DNO and CSS to enable the updates to the Regulatory Alliance Data Items - this should include timescales for action as well as pathways for escalation and resolution as required.
Recent enquiries from DNOs have highlighted the following:
1. There is a need to clarify the link back to the DCUSA clauses to ensure it is clear that the use of the CSS functionality listed in REC Schedule 24 clauses 4.10.7 and 4.10.8 is only permitted in accordance with DCUSA and any such action would be governed under that Code and not under the REC.
2. There is a need to ensure this action is only taken when authorised and clarify where the responsibility lies to review and/or approve such actions.
3. There is a need to set out what controls prevent DNOs from terminating a Regulatory Alliance incorrectly to prevent delays to switching and any subsequent consumer and market participant detriment.
4. There is a need to clarify how interested parties e.g. the impacted Supplier, other Code Bodies, etc. are notified to allow them to manage potential downstream impacts of such action.
5. There is a need to clarify the operational processes used by the DNO and CSS to enable the updates to the Regulatory Alliance Data Items - this should include timescales for action as well as pathways for escalation and resolution as required.
Due to lack of clarity, DNOs are unsure if they have taken all appropriate steps to terminate a Regulatory Alliance. Additionally, the following risks may manifest if the Code requirements and hand-offs are not clarified:
1. There is a risk that a DNO terminates the Regulatory Alliance within CSS without following the due process as required under the DCUSA.
2. There is a risk that the impacted Supplier is unaware of this suspension and continues to acquire and attempt to register customers.
3. There is a risk that the suspension prevents the impacted Supplier from meeting its wider Code and/or Licence obligations and in turn, causing consumer detriment. (e.g. delays in re-registering customers where an erroneous switch resolution is agreed.)
1. There is a risk that a DNO terminates the Regulatory Alliance within CSS without following the due process as required under the DCUSA.
2. There is a risk that the impacted Supplier is unaware of this suspension and continues to acquire and attempt to register customers.
3. There is a risk that the suspension prevents the impacted Supplier from meeting its wider Code and/or Licence obligations and in turn, causing consumer detriment. (e.g. delays in re-registering customers where an erroneous switch resolution is agreed.)
A DCUSA Change Proposal - DCP 451 ‘Suspending Registrations’ - has been raised to look into this issue. The solution must consider a cross-code solution, which does not put consumer outcomes at risk.
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Impacts
No details provided
Switching experience, Trust and confidence
Potential misuse or premature use of processes listed in Schedule 24 for the prevention of Registration can prevent consumers from registering with a Supplier of choice and lead to unnecessary delays in switching.
Schedule 24 - Switching Data Management
Specifically, clauses 4.5 (k), 4.10.7, 4.10.8, 4.11.5 to 4.11.9. Other similar provisions worth reviewing are clauses 4.5 (h), 4.5 (j), 4.9.3, 4.9.4, 4.10.3, 4.10.4.
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Distribution Network Operators, Energy Suppliers
Whilst this issue has been identified based on queries from DNOs attempting to suspend an Electricity Supplier from registering customers due to the breach of obligations under DCUSA, other similar provisions for Party-to-Party as well as market sanctions listed in Schedule 24 should be reviewed to ensure they are sufficiently clear. These may also impact Gas Transporter, Shipper, Supplier and CDSP, as well as other Codes such as BSC and UNC.
Distribution Connection and Use of System Agreement (DCUSA)
As above, other related provisions may impact BSC and UNC.
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Priority & timing
No
This Change should move at pace with DCP-451.
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Switching experience, Trust and confidence
Activity
Status has been changed to Implemented.
Implementation Date has been updated to 07 Nov 2025.
vaishnsharma has been allocated as SME.