Introducing Third Party Intermediary (energy broker) assurance and accreditation
Summary
This change seeks to expand the obligation for Energy Suppliers to only work with TPIs who are adhering to principles as set out in the REC TPI Code of Practice to all Non-Domestic Consumers. It also looks to reduce the burden on Energy Suppliers having to perform their own audits by introducing a REC Services Accreditation Scheme and allowing companies to qualify as an Industry-Recognised Accreditation Body.
Latest update and next planned activity
Date of latest update
Latest Update
16/05/2025 - The Authority has published their decision to reject R0137 and R0137A.
Impacts Overview
Impacted Consumers
Electricity
Gas
Non-Domestic
Impacted REC Documents
Schedule 1 - Interpretations and Definitions
Schedule 24 - Switching Data Management
Schedule 26 - Switching Service Management
Priority and rationale
Priority last updated on 29 May 2026
Solution development
Problem Statement
Non-Domestic Consumers have more limited protections than Domestic and Microbusiness Consumers in the energy market, and so may not always experience best practice from all parties they interact with. The aim is to expand these protections while limiting the audit burdens on Suppliers and TPIs.
Proposed solution summary
- As a Non-Domestic Consumer, I want to work with TPIs who are demonstrating best practice standards within the market.
- As a Non-Domestic Energy Supplier, I want clear obligations around my use of TPIs so I can demonstrate best practice standards within the market and ensure my audit obligations are met.
- As RECCo, I want to provide an assurance and accreditation scheme to register TPIs to remove the burden of Suppliers having to individually audit TPIs.
- As a Third Party Intermediary, I want clear obligations so I can become accredited and assure that Suppliers and Non-Domestic Consumers are receiving best practice standards within the market.
No documents available.
Change Plan
Service Provider Impact Assessment opens
Completed
Start:
20 Jul 2023Due:
05 Jul 2024Completion:
05 Jul 2024Service Provider Impact Assessment closes
Completed
Start:
05 Jul 2024Due:
09 Aug 2024Completion:
06 Aug 2024Party Impact Assessment opens
Completed
Start:
09 Aug 2024Due:
16 Aug 2024Completion:
15 Aug 2024Party Impact Assessment closes
Completed
Start:
16 Aug 2024Due:
09 Sep 2024Completion:
09 Sep 2024Preliminary Change Report Issued
Completed
Start:
09 Sep 2024Due:
08 Oct 2024Completion:
08 Oct 2024Responsible Committee Review
Completed
Start:
08 Oct 2024Due:
15 Oct 2024Completion:
15 Oct 2024Consultation opens
Completed
Start:
15 Oct 2024Due:
18 Oct 2024Completion:
17 Oct 2024Consultation closes
Not Started
Start:
18 Oct 2024Due:
08 Nov 2024Completion:
Responsible Committee Decision
Not Started
Start:
10 Dec 2024Due:
17 Dec 2024Completion:
Final Change Report issued
Not Started
Start:
08 Nov 2024Due:
10 Dec 2024Completion:
Sent to Authority for Determination
Not Started
Start:
17 Dec 2024Due:
18 Dec 2024Completion:
Original submission
Change details
Jon Dixon - RECCo
20 Jul 2023
Change details
Introducing Third Party Intermediary (energy broker) assurance and accreditation
An energy broker is a ‘Third Party Intermediary’ or TPI that sits between a non-domestic energy consumer and the energy supply market. In a legal sense the broker is an ‘agent’ that is authorised to act on behalf of a ‘principal’ (the consumer) to create legal relations with a third party (the Supplier). These TPIs undertakes an important role in streamlining the pricing and contracting element for businesses who may not otherwise have the resource or knowledge to find an offering that appropriately meets their needs. The TPI also acts as an importance sales channel for suppliers who may not otherwise have been able to establish contact with those potential customers. However, the TPI sector is facing growing criticism for not being fair or transparent in its dealings, often stemming from the inappropriate behaviours of a few bad actors.
Although TPIs are currently not regulated (and there has not as yet been any follow up to the government's 2021 proposals to introduce TPI Regulation) Ofgem has instead introduced licence conditions upon non-domestic suppliers which requiring them to ensure that any TPI brokers they contract with are adhering to certain principles. They are also required to be registered to an Alternative Dispute Resolution (ADR) scheme. This licence oligation effectively requires each supplier to undertake their own audits of TPIs in order to ensure that their licence obligations are being discharged. This places a large burden upon both suppliers and TPIs, who must each undertake any audit activities many times, effectively having to repeat the process for each bilateral arrangement they enter into. This additional burden has resulted in a contraction of the number of relationships that suppliers and TPIs maintain, which may diminish competition and choice to the consumer. This also risks an asymmetric playing field, with those parties who are ‘doing the right thing’ bearing a high compliance cost, whilst their competitors may follow a path of least resistance; this could lead to a ‘race to the bottom’ and further detriment to consumer outcomes.
We seek to ensure that Suppliers only use TPIs who adhere to the principles set out in the TPI CoP. RECCo will develop an assurance and accreditation regime, maintaining a register of TPIs that it has determined fulfil those CoP requirements and therefore do not need to be individually audited by each Supplier. However, should a Supplier wish to contract with a TPI that has not been accredited under the REC accreditation scheme, it will be free to do so if it can demonstrate that it has otherwise satisfied itself that the TPI nonetheless adhere to the CoP principles.
Yes, please see supporting background paper, and link to the TPI Code of Practice
Impacts
Electricity, Gas, Microbusiness, Small and Medium Enterprise (SME), Industrial and Commercial (I&C)
Switching experience, Trust and confidence
While the new licence obligations placed upon non-domestic suppliers by Ofgem in Autumn were focused on microbusiness consumers and followed on directly from its microbusiness strategy review, the concerns raised apply to the non-domestic sector as a whole. While some larger consumers may be sophisticated and well informed consumers, perhaps assisted by specialist energy procurement managers and therefore not in need of the same sort of protections as introduced by Ofgem for smaller business consumers, the issues may apply to the higher consuming sector of the market. At thsi stage we see no reason why the principles of the CoP and assurance that may be provided by any supporting accreditation scheme should not be extended to the market as a whole.
Schedule 1 - Interpretations and Definitions, Schedule 24 - Switching Data Management, Schedule 26 - Switching Service Management
This Change Proposal will be accompanied by the introcution of a new REC service, providing accreditation of TPIs, and of a new document - the TPI Code of Practice
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No systems impacts expected as a result of this particular change
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Priority & timing
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Activity
Proposed solution summary changed to As a Non-Domestic Consumer, I want to work with TPIs who are demonstrating best practice standards within the market.As a Non-Domestic Energy Supplier, I want clear obligations around my use of TPIs so I can demo…
Proposed solution summary changed to As a Non-Domestic Consumer, I want to work with TPIs who are demonstrating best practice standards within the market.As a Non-Domestic Energy Supplier, I want clear obligations around my use of TPIs so I can demonstrate best practice standards within the market and ensure my audit obligations are met.As RECCo, I want to provide an assurance and accreditation scheme to register TPIs to remove the burden of Suppliers having to individually audit TPIs.As a Third Party Intermediary, I want clear obligations so I can become accredited and assure that Suppliers and Non-Domestic Consumers are receiving best practice standards within the market..
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