Clarification and Amendments to Annulment Definition in Schedule 23 – Alignment with SLC Obligations (Alternate)
Summary
Inconsistent interpretations of the Annulment definition in Schedule 23 are leading to disputes between suppliers. We are, therefore, seeking to further clarify the use of annulments to ensure that the customer is placed firmly at the heart of this process.
Latest update and next planned activity
Date of latest update
Latest Update
20/02/2026 The Authority has published their decision to reject R0287A and approve the R0287, in line with the Code Manager and the Change Panel's recommendation. The Authority's decision has been published below.
Impacts Overview
Priority and rationale
High
Priority last updated on 17 Sep 2026
Solution development
Problem Statement
The current wording of the Annulment definition in the REC Schedule 23 – Registration Services is insufficiently aligned with the obligations set out in Ofgem’s Electricity Supply Standard Licence Conditions (SLC). This has led to inconsistent interpretations of the usage of the Annulment process.
No documents available.
There is currently no Change Plan.
Original submission
Change details
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26 Nov 2025
Change details
Clarification and Amendments to Annulment Definition in Schedule 23 – Alignment with SLC Obligations (Alternate)
Inconsistent interpretations of the Annulment definition in Schedule 23 are leading to
disputes between suppliers. We are, therefore, seeking to further clarify the use of
annulments to ensure that the customer is placed firmly at the heart of this process.
With the appropriate protections in place, we believe this approach will deliver a
positive outcome for customers, regardless of which supplier they
choose to engage with.
We propose that the Annulment definition explicitly outlines:
• When and how annulments should be used.
• That annulments are appropriate to deliver a positive customer experience to
action a customer request without the customer having to contact both the
gaining and losing supplier when a switch is in progress.
• That the annulments process should be permitted in circumstances where:
Domestic customer only:
▪ a customer has informed their existing supplier that they have not
intentionally entered a contract with another supplier (i.e. preventing
erroneous switches under SLC 14); and
▪ a customer changes their mind and wishes the losing supplier to inform the
gaining supplier on their behalf that they wish to remain with
their existing supplier (i.e. supporting the rights of the customer under SLC
14A);
Non-Domestic customer only:
▪ a customer has informed their existing supplier that they have not
intentionally entered a contract with another supplier (i.e. preventing
erroneous switches under SLC 14)
That in each case, the annulment request would be actioned prior to the switch
request status changing to Secured Active and the supplier must obtain the
customer’s explicit consent to terminate the switch.
In our view this clarification is essential to ensure industry continues to have an efficient
annulment process that delivers customer requests quickly and accurately and to
offer the best customer experience during the switching journey.
disputes between suppliers. We are, therefore, seeking to further clarify the use of
annulments to ensure that the customer is placed firmly at the heart of this process.
With the appropriate protections in place, we believe this approach will deliver a
positive outcome for customers, regardless of which supplier they
choose to engage with.
We propose that the Annulment definition explicitly outlines:
• When and how annulments should be used.
• That annulments are appropriate to deliver a positive customer experience to
action a customer request without the customer having to contact both the
gaining and losing supplier when a switch is in progress.
• That the annulments process should be permitted in circumstances where:
Domestic customer only:
▪ a customer has informed their existing supplier that they have not
intentionally entered a contract with another supplier (i.e. preventing
erroneous switches under SLC 14); and
▪ a customer changes their mind and wishes the losing supplier to inform the
gaining supplier on their behalf that they wish to remain with
their existing supplier (i.e. supporting the rights of the customer under SLC
14A);
Non-Domestic customer only:
▪ a customer has informed their existing supplier that they have not
intentionally entered a contract with another supplier (i.e. preventing
erroneous switches under SLC 14)
That in each case, the annulment request would be actioned prior to the switch
request status changing to Secured Active and the supplier must obtain the
customer’s explicit consent to terminate the switch.
In our view this clarification is essential to ensure industry continues to have an efficient
annulment process that delivers customer requests quickly and accurately and to
offer the best customer experience during the switching journey.
Inconsistent interpretations of the Annulment definition in Schedule 23 are leading to
disputes between suppliers. Resolving such disputes takes up valuable time for
stakeholders, including suppliers, RECCo and Ofgem.
In addition, for some cases, depending on the interpretation of the process by
the supplier, we understand customers are being asked to take more than one action to
stop a switch proceeding by having to contact the gaining supplier, even after they have
told the losing supplier they wish to stop the switch, rather than the losing supplier
using the annulment process to inform the gaining supplier of the customer’s request
on their behalf.
With the introduction of faster switching, there is less time for customers to undertake
this additional action, and in addition, the ability for the customer to get through to the
gaining supplier will likely be influenced by the performance of the gaining supplier’s
enquiry service. This impacts the customer switching experience.
Impact on the gaining and the losing supplier –
The SLCs allows a domestic customer to change their mind during the 14-day cooling
off period without paying an exit fee and may return to their previous or a new supplier at
any point during that period. If the losing supplier submits a new switch request instead
of using the annulments process, this can increase operational costs for both the
gaining and losing suppliers once the switch status changes to SecuredActive.
These additional costs may include:
• The customer being switched to another supplier for just a one or two day period.
• Both Suppliers processing opening and closing meter reads, billing and resolving
any read disputes.
• Risk of Prepayment customers going off supply
disputes between suppliers. Resolving such disputes takes up valuable time for
stakeholders, including suppliers, RECCo and Ofgem.
In addition, for some cases, depending on the interpretation of the process by
the supplier, we understand customers are being asked to take more than one action to
stop a switch proceeding by having to contact the gaining supplier, even after they have
told the losing supplier they wish to stop the switch, rather than the losing supplier
using the annulment process to inform the gaining supplier of the customer’s request
on their behalf.
With the introduction of faster switching, there is less time for customers to undertake
this additional action, and in addition, the ability for the customer to get through to the
gaining supplier will likely be influenced by the performance of the gaining supplier’s
enquiry service. This impacts the customer switching experience.
Impact on the gaining and the losing supplier –
The SLCs allows a domestic customer to change their mind during the 14-day cooling
off period without paying an exit fee and may return to their previous or a new supplier at
any point during that period. If the losing supplier submits a new switch request instead
of using the annulments process, this can increase operational costs for both the
gaining and losing suppliers once the switch status changes to SecuredActive.
These additional costs may include:
• The customer being switched to another supplier for just a one or two day period.
• Both Suppliers processing opening and closing meter reads, billing and resolving
any read disputes.
• Risk of Prepayment customers going off supply
An effective solution would be to update the Annulment definition implemented in
2024. This change should further emphasize the consumer focus within the switching
journey and ensure consumers have the right to have switches stopped without having
to contact both the gaining and losing supplier - supporting delivery of a
positive customer experience in the faster switching world.
This should include:
• Clear criteria for when annulments are appropriate. Specifically:
Domestic customer only:
o Where a customer has informed their existing supplier that they have not
intentionally entered a contract with another supplier (i.e. preventing erroneous
switches under the obligations set out in Standard Licence Conditions
14.2(d),14.4(c) and 14.10); and
o When a customer changes their mind and wishes the losing supplier to inform
the gaining supplier on their behalf that they wish to remain with their existing
supplier (under the requirements set out in Standard Licence Conditions 14A.1
(b))
Non-Domestic customer only:
o Where a customer has informed their existing supplier that they have not
intentionally entered a contract with another supplier (i.e. preventing
erroneous switches under the obligations set out in Standard Licence
Conditions 14.2(d),14.4(c) and 14.10)
In addition, that in each case the annulment request is made prior to the switch request
status changing to Secured Active.
• The relevant protections for consumers: i.e. that the losing supplier must have
obtained consent from the customer to terminate the switch, document the
reason for the customer consenting to the annulment and retain the evidence for
at least one year.
• Explicit guidance on how the losing supplier provides evidence that the process
is being used appropriately and only for appropriate reasons with customer
consent. Consistent terminology and process expectations to avoid misinterpretation by
suppliers and market participants leading to disputes.
We propose following changes to the legal text:
Please see submission form for proposed legal text
2024. This change should further emphasize the consumer focus within the switching
journey and ensure consumers have the right to have switches stopped without having
to contact both the gaining and losing supplier - supporting delivery of a
positive customer experience in the faster switching world.
This should include:
• Clear criteria for when annulments are appropriate. Specifically:
Domestic customer only:
o Where a customer has informed their existing supplier that they have not
intentionally entered a contract with another supplier (i.e. preventing erroneous
switches under the obligations set out in Standard Licence Conditions
14.2(d),14.4(c) and 14.10); and
o When a customer changes their mind and wishes the losing supplier to inform
the gaining supplier on their behalf that they wish to remain with their existing
supplier (under the requirements set out in Standard Licence Conditions 14A.1
(b))
Non-Domestic customer only:
o Where a customer has informed their existing supplier that they have not
intentionally entered a contract with another supplier (i.e. preventing
erroneous switches under the obligations set out in Standard Licence
Conditions 14.2(d),14.4(c) and 14.10)
In addition, that in each case the annulment request is made prior to the switch request
status changing to Secured Active.
• The relevant protections for consumers: i.e. that the losing supplier must have
obtained consent from the customer to terminate the switch, document the
reason for the customer consenting to the annulment and retain the evidence for
at least one year.
• Explicit guidance on how the losing supplier provides evidence that the process
is being used appropriately and only for appropriate reasons with customer
consent. Consistent terminology and process expectations to avoid misinterpretation by
suppliers and market participants leading to disputes.
We propose following changes to the legal text:
Please see submission form for proposed legal text
The annulment process was introduced as part of the faster switching programme to
support the customer in taking action to prevent a switch concluding where they
contact the losing supplier. However, the Annulment definition put in place at the
time was ambiguous, referring to Standard Licence Conditions that in fact contained
no references to the Annulment process. In November 2024, Change Proposal R0119 –
Annulment Definition – was introduced to provide further guidance within REC
Schedule 23, clarifying that the annulment process may be used in
circumstances where the customer requests that a switch is cancelled and gives
consent for the losing supplier to take action to prevent the switch progressing. By
amending the wording of the Annulment definition in the REC schedule, and putting in
place appropriate protections, this change considerably improved the customer
experience of this otherwise neglected aspect of the faster switching journey.
The REC Schedule 1 Interpretations and Definitions document was also updated with
the following definition of Annulled:
Annulled - means that a Registration has been annulled by the Losing Supplier pursuant
to an Annulment Request where the Losing Supplier has received an instruction from
the Consumer to terminate the progress of a Registration. “Annulment” and similar
expressions shall be interpreted accordingly.
The intent of the R0119 change was to clarify the use of the annulment process for
parties. However, we consider that there is value in further refining the guidance to more
clearly align with the Supply Licence Conditions that govern the switching process and
ensure the objective of delivering a positive customer experience at every stage of
the switching journey is delivered. This change aims to clarify that whenever a customer
wishes to stop a switch from taking place, then the customer can do so by
instructing either the gaining or losing supplier for the following reasons:
Domestic Customer only:
• Where the customer has not entered into a contract with the gaining supplier
(preventing erroneous transfers under SLC 14); and
• Where the customer has changed their mind and wishes their switch to the
gaining supplier to be terminated (under SLC 14A).
Non-Domestic customer only:
ADDITIONAL INFORMATION
This change refers to the Ofgem SLC 14 Customer blocking and 14A Customer transfer
process and it covers the following scenarios:
Ofgem SLC 14 Customer blocking:
Where the customer has not entered into a contract with the gaining supplier
(preventing erroneous transfers under SLC 14); and
Ofgem SLC 14A Customer transfer:
Where the customer has changed their mind and wishes their switch to the gaining
supplier to be terminated (under SLC 14A).
support the customer in taking action to prevent a switch concluding where they
contact the losing supplier. However, the Annulment definition put in place at the
time was ambiguous, referring to Standard Licence Conditions that in fact contained
no references to the Annulment process. In November 2024, Change Proposal R0119 –
Annulment Definition – was introduced to provide further guidance within REC
Schedule 23, clarifying that the annulment process may be used in
circumstances where the customer requests that a switch is cancelled and gives
consent for the losing supplier to take action to prevent the switch progressing. By
amending the wording of the Annulment definition in the REC schedule, and putting in
place appropriate protections, this change considerably improved the customer
experience of this otherwise neglected aspect of the faster switching journey.
The REC Schedule 1 Interpretations and Definitions document was also updated with
the following definition of Annulled:
Annulled - means that a Registration has been annulled by the Losing Supplier pursuant
to an Annulment Request where the Losing Supplier has received an instruction from
the Consumer to terminate the progress of a Registration. “Annulment” and similar
expressions shall be interpreted accordingly.
The intent of the R0119 change was to clarify the use of the annulment process for
parties. However, we consider that there is value in further refining the guidance to more
clearly align with the Supply Licence Conditions that govern the switching process and
ensure the objective of delivering a positive customer experience at every stage of
the switching journey is delivered. This change aims to clarify that whenever a customer
wishes to stop a switch from taking place, then the customer can do so by
instructing either the gaining or losing supplier for the following reasons:
Domestic Customer only:
• Where the customer has not entered into a contract with the gaining supplier
(preventing erroneous transfers under SLC 14); and
• Where the customer has changed their mind and wishes their switch to the
gaining supplier to be terminated (under SLC 14A).
Non-Domestic customer only:
ADDITIONAL INFORMATION
This change refers to the Ofgem SLC 14 Customer blocking and 14A Customer transfer
process and it covers the following scenarios:
Ofgem SLC 14 Customer blocking:
Where the customer has not entered into a contract with the gaining supplier
(preventing erroneous transfers under SLC 14); and
Ofgem SLC 14A Customer transfer:
Where the customer has changed their mind and wishes their switch to the gaining
supplier to be terminated (under SLC 14A).
Impacts
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Switching experience
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Priority & timing
No
Yes, we believe this issue should be progressed under an urgent timetable to ensure
that all industry parties maintain consistent approach for the use of the Annulment
process, comply with their Supplier Licence Conditions (SLC) SLC14 customer
blocking and SLC 14A customer transfer process requirements and ensure that the
customer journey and experience is not impacted.
that all industry parties maintain consistent approach for the use of the Annulment
process, comply with their Supplier Licence Conditions (SLC) SLC14 customer
blocking and SLC 14A customer transfer process requirements and ensure that the
customer journey and experience is not impacted.
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No details provided
Switching experience