Switch Request Objections (Change of Occupier)
Summary
This Change Proposal looks to clarity obligations regarding the losing suppliers' rights to object and the circumstances surrounding registrations by gaining suppliers, following the migration from the MRA to the REC.
Latest update and next planned activity
Date of latest update
Latest Update
26/01/2024 - Withdrawn following adoption window closure.
Impacts Overview
Impacted Consumers
Electricity
Gas
Domestic
Non-Domestic
Impacted REC Parties and Market Participants
Energy Supplier
DCC
Shipper
Data Collector
Data Aggregator
Meter Asset Provider
AMR Service Provider
Impacted REC Documents
Schedule 1 - Interpretations and Definitions
Schedule 25 - Central Switching Service
Schedule 23 - Registration Services
Schedule 26 - Switching Service Management
Impacted REC Services
Central Switching Service (CSS)
Priority and rationale
Standard
Priority last updated on 29 May 2026
Solution development
No documents available.
There is currently no Change Plan.
Original submission
Change details
Simon Askew - Business Energy Direct
12 Jun 2022
Change details
Switch Request Objections - Additional
The lack of clarity regarding the losing suppliers rights to object and the circumstances surrounding registrations by gaining suppliers , following the migration from the MRA to the REC
An increase in the number of objections by suppliers that no longer find it necessary to follow the previous requirements under the MRA, with all previous guidance and definitions no longer being applicable.
The adoption of previous requirements under version 12.9 of the MRA, in particular 16.2 of the MRA.
The REC doesn't provide the correct definitions for what a 'Change of Occupier' is, the present definition being 'means that the Consumer at a premises has changed (or is due to change)'. Firstly a 'Consumer' is defined in the REC as 'means any person supplied (or seeking a supply) of Energy at an RMP (whether or not that person also exports or is seeking to export electricity at an RMP).
Consumers are typically referred to and considered as domestic customers, across the industry. This is covered in the Standard Licence Conditions and the 1989 Electricity Act. By not creating an appropriate definition for, or including the wording 'non domestic consumer' in the relevant sections where such needs to be clear, suppliers can choose to behave differently to how they would under the MRA.
Secondly, the MRA document 'Guideline for use of the Change of Tenancy Indicator' (GD28), detailed instances that would constitute a Change of Tenancy or as is described in the REC 'Change of Occupier. Unfortunately the REC only details the narrow view of 'Consumer at a premises has changed'. There are instances where the Consumer (sic) Non Domestic Consumer, hasn't changed literally, however a different legal entity is responsible for energy consumed, due to a 'Change of Legal Status'. In addition GD28 goes a step further and reminds suppliers to consider that an entity named on a lease or rental agreement, isn't necessarily the entity legally responsible for energy charges.
Consumers are typically referred to and considered as domestic customers, across the industry. This is covered in the Standard Licence Conditions and the 1989 Electricity Act. By not creating an appropriate definition for, or including the wording 'non domestic consumer' in the relevant sections where such needs to be clear, suppliers can choose to behave differently to how they would under the MRA.
Secondly, the MRA document 'Guideline for use of the Change of Tenancy Indicator' (GD28), detailed instances that would constitute a Change of Tenancy or as is described in the REC 'Change of Occupier. Unfortunately the REC only details the narrow view of 'Consumer at a premises has changed'. There are instances where the Consumer (sic) Non Domestic Consumer, hasn't changed literally, however a different legal entity is responsible for energy consumed, due to a 'Change of Legal Status'. In addition GD28 goes a step further and reminds suppliers to consider that an entity named on a lease or rental agreement, isn't necessarily the entity legally responsible for energy charges.
Impacts
Electricity, Gas, Domestic Prepayment, Domestic Credit, Microbusiness, Small and Medium Enterprise (SME), Industrial and Commercial (I&C)
Switching experience, Billing accuracy, Trust and confidence, Security of supply, Ability to pay
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Schedule 1 - Interpretations and Definitions, Schedule 25 - Central Switching Service, Schedule 23 - Registration Services, Schedule 26 - Switching Service Management
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No details provided
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No details provided
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Standards Definition
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No details provided
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Central Switching Service (CSS), Switching Operator
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Energy Suppliers, DCC, Shippers, Data Collectors, Data Aggregators, Meter Asset Providers, AMR Service Providers
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No details provided
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No
No details provided
Priority & timing
No
One example is quickly identified by us. A micro-business customer's transfer of supply was prevented at two premises, on more than 30 separate occasions. Following investigation by Ombudsman Services Energy it was found that the supplier had repeatedly objected without having grounds to do so. This also led to an unlawful remote disconnection, resulting in loss of produce (spoiled) and revenue due to not being able to operate. The micro-business customer suffered significant financial detriment, which the supplier was obliged to cover. The total loss to the supplier exceeded more than £35,000.
Around 3 months maximum.
No
No details provided
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