Clarify & Strengthen CRS Providers Requirements

  • 1
    Initial Assessment
  • 2
    Solution Development
  • 3
    Consultation
  • 4
    Decision
  • 5
    Awaiting Implementation
  • 6
    Implemented
Step 6 of 6
Implemented
Summary
The RECCo MSI review focused on the analysis and assessment of; Code compliance, performance, impacts and insights from lessons learned feedback from impacted stakeholders. These assessments thematically articulated changes and improvements identified to assure industry market participants that clear and appropriate action is, and will be, taken to prevent, detect and mitigate the risks and impacts of another event, and prepare for the right response to any future incidents. This Issue has been raised to address learnings from the P1 switching incident in July 2023.

Latest update and next planned activity

Date of latest update
Latest Update
This Change Proposal was implemented on 28 February 2025.

Impacts Overview

Impacted Consumers
Electricity Gas Domestic Non-Domestic
Impacted REC Parties and Market Participants
Energy Supplier Distribution Network Operator Gas Transporter Other
Impacted REC Documents
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

Problem Statement
On 6th July 2023, a Major Switching Incident occurred with the Central Switching Service ((CSS) operated by the Switching Operator and CSS Service Provider, the Smart Data Communication Company (DCC)). It prevented the successful completion of that day’s planned electricity and gas, supply switches and new registrations. The CSS was stabilised post-incident and any new requests submitted after 9 a.m., 6th July were processed successfully. Through the collective action of the Switching Operator and industry parties, the CSS sent the missing industry messages to give effect to the intended switches and new registrations during the period of the 2nd to the 8th of August 2023. Priority 1 (P1) Major Switching Incidents of this nature are required to be resolved within 4 hours; however, DCC reported it took 1,605.6 hours in this instance. This incident had significant impacts on multiple industry parties and end consumers, demonstrating a clear need for improvement in the arrangements managing switching services and response to major incidents. The Retail Energy Code Company ((RECCo) with the assistance of its Code Manager) completed an end-to-end incident review; to identify the root cause, consider the efficiency and effectiveness of the incident management response, assess the improvements required, and identify appropriate actions for risk mitigation. With the overarching objective that by delivering the identified review recommendations, these actions should limit the possibility, or minimise the impact of, any future major switch incidents.
Proposed solution summary
  1. Root Cause Communication: That the DCC, in its role as Switching Operator, delivers, clear, accurate, timely information on the incident root cause, as soon as possible, once it has obtained a reasonable understanding. Both to offset the risks of uncertainty and limited information introduce, ensuring Switching parties (like Supplier, TPIs and Networks) have the right information to enable meaningful engagement, assist their end-consumers, and all impacted Market Participants can more proactively manage the incident impacts, including making appropriate plans in response to the incident and its resolution. Switching Operator's End-Consumer Communication: Introduce a requirement for the DCC, in its role as the Switching Operator, to provide end-consumer appropriate information for REC Parties and Non-REC Parties use to determine communication and action for their Consumers.
  2. Switching Operator, Switching Incident Impact Assessment: This change should clarify the existing Switching Operator’s broader obligation to assess an incidents impact on the wider Switching Arrangements (set out in REC Schedule 26, Switching Service Management Schedule (SSMS), section 1.7, or Major Switching Incidents starting at section 2.9), to ensure the Switching Operator facilitates the most effective, efficient (time, cost, resource) overall Switching industry solution is promoted and implemented. Incident Wider Switching Impact Assessment: Clarify that if a Major Switching Incident is not going to be resolved within defined Service levels (4 hours), then the DCC in its role as Switching Operator should determine the impact on compliance with the REC end-to-end Switching Arrangements, and work with Ofgem, and the Code Administrators for BSC, UNC and DCUSA, and RECCo, to identify the cross code impacts/impacts on other Codes when managing an incident and developing an appropriate solution for industry, with least negative impact to end-consumers.
  3. Refresh and testing of Switching Operator’s (SO) incident related policies, processes, and procedures, to ensure they remain fit for purpose.
  4. Refresh and testing of Switching Operator’s (SO) incident related policies, processes, and procedures, to ensure they remain fit for purpose.

No documents available.

There is currently no Change Plan.

Original submission

Change details

Glenn Sheern - -
1 May 2024

Change details

Clarify & strengthen CRS Providers requirements
On 6th July 2023, a Major Switching Incident occurred with the Central Switching Service ((CSS) operated by the Switching Operator and CSS Service Provider, the Smart Data Communication Company (DCC)). It prevented the successful completion of that day’s planned electricity and gas, supply switches and new registrations. The CSS was stabilised post-incident and any new requests submitted after 9 a.m., 6th July were processed successfully. Through the collective action of the Switching Operator and industry parties, the CSS sent the missing industry messages to give effect to the intended switches and new registrations during the period of the 2nd to the 8th of August 2023. Priority 1 (P1) Major Switching Incidents of this nature are required to be resolved within 4 hours; however, DCC reported it took 1,605.6 hours in this instance. This incident had significant impacts on multiple industry parties and end consumers, demonstrating a clear need for improvement in the arrangements managing switching services and response to major incidents. The Retail Energy Code Company ((RECCo) with the assistance of its Code Manager) completed an end-to-end incident review; to identify the root cause, consider the efficiency and effectiveness of the incident management response, assess the improvements required, and identify appropriate actions for risk mitigation. With the overarching objective that by delivering the identified review recommendations, these actions should limit the possibility, or minimise the impact of, any future major switch incidents. This Issue seeks to deliver 54 review recommendations. 1) Communicating the right message on root cause & for end-consumer comms [review ref. T007 – The Technical Response – Root Cause Info, IM013 – Impact on consumers – end-consumer appropriate info] Affected parties confirmed there were limited, incremental root cause communications along the duration of the incident, until resolved, when a detailed incident root cause was confirmed as part of the incident closure report (6th October, 92 days after the start of the incident). Both the delays in sharing, and the limited information shared, not only caused confusion, concern and left many without the tools to understand what was going on. It made a complicated situation more challenging both for Suppliers to meaningfully engage and assist their end consumers, and for all impacted Market Participants to manage the situation, including making appropriate plans in response to the incident and its resolution. 1) Clarification of existing SO Switching Impact Assessment requirement [review ref. IM015 - Impact on Energy Businesses + & IM017 - Impact on Licences and Codes - SSMS clarification of broader Switching arrangements & IM017 - Impact on Licences and Codes] The DCC, in its role as Switching Operator, does not have a Code requirement to provide analysis on the impact of incidents on Code requirements. To meet the objectives of the REC it is essential that a clear articulation of the incident, its impacts, and the impacts of the actions taken to resolve it on compliance are identified. Where switches and new registrations do not proceed on the expected date, there are impacts to the end-consumer expecting the switch to proceed, and also to Switching parties via downstream, subsequent Switching processes/data/systems covered by REC and across various energy industry codes [including those managing energy trading, reconciliation and settlement, the gas Uniform Network Code (UNC), and electricity Balancing & Settlement Code (BSC), and the electricity Distributor Connection Use of System Arrangements (DCUSA) which can be impacted by registration and settlement issues felt under REC/BSC]. Not only were Suppliers effectively unable to utilise objections, but the incident also saw issues across the switching landscape processes, including; open/closing Meter Reading Disputes, Erroneous Transfers and Settlements. These impacts, if not mitigated by the incident solution implemented, have the potential to lead to potentially unnecessary impacts to businesses as they try to mitigate impacts to them and their end consumers, around avoiding incorrect or late bills, suppliers paying for the wrong period/volume of energy under settlements, or the end consumer being sent to the wrong Supplier. During the incident, there seemed confusion about the broader requirement to ensure any proposed incident solutions considered the impact on the wider Switching Arrangements and who might best assist with this assessment. The purpose of this change is tTo ensure (where possible) the most effective, efficient (time, cost, resource) overall Switching industry solution, industry, with least negative impact to end-consumers, is promoted and implemented. Especially where the incident is not going to be resolved with the REC defined resolution service levels of 4 hours. 2) Communicating the right message ([review ref. COM022 – communicating the right message – SSMS clarification around maintenance of related policies, procedures, processes] RECCo should raise a change to the Switching Service Management Schedule 26, to provide additional direction on a requirement not just to develop a Category 3 procedure, but for DCC in its role as Switching Operator to periodically review, reissue and maintain a: - Switching Incident Management Policy, including defined roles & responsibilities (i.e., RACI) - Switching Service Management Policies & Procedures - Procedure for the review and updating of contact lists for CSS Users, SDSP’s and other interested parties. - Annual testing of Incident Management Policies, procedures, processes, and RACI - RACI clearly setting out hierarchy of needs dependent of Priority of Incident. - clear communications strategy included channels and cadence of meetings in addition to ongoing SOF. - A Major Switching Incident run book. DCC in its role as Switching Operator should complete annual testing of the incident responses processes for incident management.
A Major Switching Incident (MSI) impacts both; end consumers subject to a Switch (or New Registration), and switching parties. The impacts and risks depend on incident; duration, nature (services), scale (number of switches, market participants and end-consumers impacted and volume of energy), market designation (Domestic, Non-Domestic/SME/micro-business, industrial & commercial) and time of year (i.e., market specific events, like Apr/Nov contract rounds). Switching impacts can occur against REC defined processes/events, but there can also be downstream impacts to subsequent Switching processes set out across the GB energy regulatory framework, which need to work to ensure the customer is set up, receives the right bills, and the energy traded on their behalf, is bought and settled in an accurate and timely manner. The 6th of July 2023 Central Switching Services, Major Switch Incident “INC0216074” impacted a combined 200,756 supply switch messages and new registration messages, for gas and electricity, domestic and non-domestic end consumers. Impacting affected end consumers (impacted messages directly correlated to end consumers who were expecting a change of Supplier, or the start of a new energy supply), energy businesses (like REC parties Suppliers, networks (Electricity Distribution Network Operators, and Gas Transporters), and non-parties e.g., Third Party Intermediaries (TPIs/brokers)), and Switching Data Providers (SDSPs -i.e., xoserve, St Clements, C&C). Key impacts experienced by those affected by the MSI were; 1) Consumer confusion; whether their agreed switch had proceeded, who they should contact about any issues they were experiencing – including topping up their prepayment meter, billing or opening/closing meter readings, and what they could do (i.e., were they blocked from switching until the incident was resolved). 2) Majority of Suppliers both; a. concerned at the resourcing needs & costs required through incident especially as the impact is ultimately borne by end consumers. Expressing that both poor information and a poor action plan, meant an inability to clearly understand and proactively be able to plan resource requirements. For some Suppliers this meant either; reacting/responding to incident needs as they arose or worked longer hours to compensate. b. felt hampered and ill informed, affecting what they could do to help their end consumers (including their ability to meet their overarching licence requirements to “treat customers fairly”); due to the length of the incident, and the timing, quality, and completeness of the information available to them, including the proposed resolution. Resulting in resource, time, and finance costs to support, and the potential for reputational damage. 3) Impacted industry parties needed to deploy resource; for the solution assessment, data verification, and preparations to conduct resolution activity. These included parties like the SDSPs (including Xoserve), the central enquiry services, Shippers, Gas Transporters, and Distributors. They supported this work understanding the key need to ensure the wider Switching landscape systems, data, and processes, accurately reflected the Switch data processed in CSS. This came at a resource, time, and financial costs to support. 4) Customer complaints – for some Suppliers; not just made directly to them, but also complaints made to Citizens Advice and/or the Energy Ombudsman. 5) Knock-on consequences – reflection to the final adjusted, accurate CSS Switch/Registration data for the Market Stabilisation Charges (MSC). Examples of impacts experienced by impacted Suppliers included: • Small Increase to prepay end consumer urgent/emergency visits; to keep Smart Pre-pay end consumers on supply. • Goodwill end Consumer compensation payments made - a Supplier confirmed they have paid goodwill compensation in response to the effect on end consumers. Noting that whilst the circumstances did not trigger an automatic Supply Guaranteed Standards of Performance (GSoP) payment, the Supplier understood the impact on the effected end consumers, ahead of the incidents resolution resulting in the Switch completion. • Majority of Non-Domestic Suppliers have picked-up additional costs to serve, limiting end Non-Domestic End consumer financial detriment. This incident caused the impacts articulated above, but both the current volume of switches and the time of year (i.e., not at a time of non-domestic contract renewals), helped limit the detriment felt. A future incident runs the risk of more significant impacts to both industry and end consumers. This issue seeks to introduce changes to manage the risk, mitigating them where possible.
The following outcomes should help better prepare for, and prevent, future incidents, and in the unfortunate event of another major switch incident, more efficiently, effectively manage and resolve it. 1. Root Cause Communicating the right information on outcome: That the DCC, in its role as Switching Operator, delivers, clear, accurate, timely information on the incident root cause, as soon as possible, once it has obtained a reasonable understanding and the inclusion of more consumer-friendly communications. Both to offset the risks uncertainty and limited information introduce, ensuring Switching parties (like those servicing consumers Supplier, and TPIs, and but also networks) have the right information to enable meaningful engagement, assistance for their end-consumers, and also that all impacted Market Participants can more proactively manage the incident impacts, including making appropriate plans in response to the incident and its resolution. [related to review ref. T007 – The Technical Response – Root Cause Info, and IM013 – Impact on consumers – end-consumer appropriate info] 2. SO, Switching Incident Impact Assessment outcome: In our opinion, the DCC has a responsibility to consider the cost and impact of an incident against industry, like REC defined processes, systems, data, and services, and should ensure its proposed solutions consider these impacts. A solution that seeks to purely solve the issue for REC Switching systems only, can have an unnecessary impact (resource, time, cost) across the wider Switching landscape. This change should clarify the existing Switching Operator’s broader obligation to assess an incidents impact on the wider Switching Arrangements (set out in REC Sch 26, Switching Service Management Schedule (SSMS), section 1.7, or Major Switching Incidents starting at section 2.9), to ensure the Switching Operator facilitates the most effective, efficient (time, cost, resource) overall Switching industry solution is promoted and implemented. [related to review ref. IM015 - Impact on Energy Businesses - SSMS clarification of broader Switching Arrangements obligation] 3. Incident Wider Switching Impact Assessment outcome: Clarify that if a Major Switching Incident is not going to be resolved within defined Service levels (4 hours), then the DCC in its role as Switching Operator should determine the impact on compliance with the REC end-to-end Switching Arrangements, and work with Ofgem, and the Code Administrators for BSC, UNC and DCUSA, and RECCo, to identify the cross code impacts/impacts on other Codes when managing an incident and developing an appropriate solution for industry, with least negative impact to end-consumers. [related to review ref. IM017 - Impact on Licences and Codes – strengthen SSMS requirement analysis of impacts on REC end-to-end Switching Arrangements] 3.4. Refresh and testing of Switching Operator’s incident related policies, processes, and procedures, to ensure they remain fit for purpose: clarity of requirements to ensure the SO periodically reviews, reissues, maintains, evaluates, and tests their; a. Switching Incident Management Policy, processes, and procedures: with the inclusion of defined roles & responsibilities (i.e., RACI, to assist rapid incident resolution), and a major switch response process. With a scheduled annual test. b. Switching Service Management Policies & Procedures c. Incident communications strategy: to include the channels to be used, and cadence of incident meetings (separate to the established Switching Operator forum). d. Procedure for the review and update of contact lists for CSS Users, SDSP’s and other interested parties. e. Methodology and criteria to assess the priority of incident resolution hierarchy. [related to review ref. COM022 – communicating the right message – SSMS clarification around maintenance of related policies, procedures, processes]
The RECCo MSI review focused on the analysis and assessment of; Code compliance, performance, impacts and insights from lessons learned feedback from impacted stakeholders. These assessments thematically articulated changes and improvements identified to assure industry market participants that clear and appropriate action is, and will be, taken to prevent, detect and mitigate the risks and impacts of another event, and prepare for the right response to any future incidents. Our findings, conclusions, and recommendations have been shared with the DCC (Data Communications Company), and reported to both the REC Board, and the REC Performance Assurance Board. The report recommendations form the basis for planned action by RECCo and DCC. The DCC actions will be managed under a Performance Assurance Technique that the REC Performance Assurance service will oversee, tracking progress through to completion, to ensure independent oversight and assurance. This Change Proposal is the subject of 4 of the review’s recommendations. For further details please see the full RECCo Review Report, published on the RECCo website; Summary and Detailed Appendix. Once the DCC (Data Communications Company) formally closed the Priority 1 (P1), Major Switch Incident (MSI) against the CSS (Central Switching Service) on 12th September 2023, it issued both a Post Incident Report Summary (8th Sep 2023), and full Incident Review Report (6th October 2023), to the REC Code Manager, allowing publication to PAB and to the wider industry via the REC Portal. For accessibility these reports are available on a dedicated REC Portal news page - CSS Major Incident July 2023 - REC Portal.

Impacts

Electricity, Gas, Domestic Prepayment, Domestic Credit, Microbusiness, Small and Medium Enterprise (SME), Industrial and Commercial (I&C)
Switching experience, Billing accuracy, Other (please provide details in Additional information box below)
Ability to switch on time, effectively stuck until switch processed, • Bad switching experience, • Billing errors – disputed reads, • Erroneous transfers – not being spotted and resolved on time, • Limited non-domestic product offerings. On 6th July 2023, a major incident occurred with the CSS, impacting c193,000 supply switch messages and c9,000 new registration messages for gas and electricity supply customers. The CSS was stabilised post-incident and any switches submitted after 9 a.m., 6th July were processed successfully. DCC (& its sub-contractor Landmark) developed and implemented a plan to ensure the CSS was accurately updated to reflect the correct switch status. This was achieved through batch updates, which processed all the missing switch/new registration messages to market participants, and which was completed by 8th August 2023. This was 33 days after the original incident.     DCC, in its role as the Switching Operator, formally closed the Major Switch Incident (CSS Priority 1) on 12th September 2023 and issued a Post-Incident Report Summary to the REC Code Manager within the required time, allowing publication to the REC Performance Assurance Board (PAB) and the wider industry via the REC Portal1.  DCC has committed to publishing a more detailed post-incident review by 6th October 2023. This will be available for market participants to access via the REC Portal during the week commencing 9th October. This is separate from RECCo's own review.  
Schedule 26 - Switching Service Management
Switching Incident Management Policy – incl. related processes and procedures
Switching Service Management Policy – incl. related processes and procedures.
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Central Switching Service (CSS), CSS Certificate Authority, Switching Operator
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Energy Suppliers, Distribution Network Operators, Gas Transporters
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TPIs
No
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Priority & timing

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Activity

Proposed solution summary changed to Root Cause Communication: That the DCC, in its role as Switching Operator, delivers, clear, accurate, timely information on the incident root cause, as soon as possible, once it has obtained a reasonable understa…
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Implementation Date has been updated to 28 Feb 2025.
james.hardy has been allocated as Lead Analyst.
vaishnsharma has been allocated as SME.