Citizens Advice response to Energy price cap: Proposed changes to the Contracts for Difference cost allowance consultation

Citizens Advice CfD reconciliation response 49.1 KB

We do not support the proposal to introduce a reconciliation in the CfD allowance. The latest available evidence set out in the August 2025 call for input presented analysis which showed no evidence of systematic under-recovery by suppliers. The case for change in this consultation is not made on the basis of any new empirical evidence indicating that there is now evidence of systematic under-recovery, but on a hypothetical increase in future risk due to the expected expansion of the scheme. It is our view that a reconciliation mechanism should only be considered if and when empirical evidence demonstrates material under-recovery in practice, that exceeds what can reasonably be absorbed through the headroom allowance.