Citizens Advice response to Ofgem’s Energy code reform: second implementation consultation

We welcome the majority of the proposals within the second code reform implementation consultation. We have made recommendations for certain of the proposals within our response but wanted to highlight the following:

• The currently-open Joint Department of Energy Security and Net Zero and Ofgem consultation on ‘Energy Code Reform: Consultation on Code Manager Licence Conditions and Code Modification Appeals to the Competition and Markets Authority’ refers to an objective for openness and transparency for the Code Manager within the licence regime, however, this principle should also apply to all operations of the Code Manager, the Stakeholder Advisory Forum, and any subcommittees or Performance Assurance Boards. We recommend that the codes and Terms of Reference of these bodies should include an objective for open and transparent governance as far as is practical. We expect these bodies to publish their decisions with explanations as well as to publish the details of other governance activities e.g. through minutes of meetings. 

• The changes to codes and code manager governance are substantial. The role and expected activities of Ofgem are likely to be equally substantial in facilitating and driving these changes. Sufficient resources need to be provided to Ofgem to enable an efficient and effective transition to new code management bodies.