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Response to Ofgem’s consultation ‘Confidence Code Review 2016’

30 September 2016

Citizens Advice response to Ofgem's proposal for changes to the Confidence Code.  [ 150 kb]

Citizens Advice are pleased to respond to Ofgem’s Confidence Code Review 2016.

The whole of market (WoM) requirement was introduced within the Confidence Code (the Code) in March 2015, requiring price comparison websites (PCWs) to show all tariffs by default. This new requirement was originally introduced to address concerns about about PCWs ‘hiding’ cheaper deals from consumers for which the sites did not earn commission.

The policy intent behind the CMA remedy to remove the current WoM requirement is to generate competition within the energy market and to bring energy PCWs in line with other markets.

In our response to the provisional CMA remedies earlier this year, we raised concerns about the decision to remove the WoM requirement, and suggested that as a result of the change there may be a negative impact to the level of engagement and trust amongst energy consumers.

We understand and support Ofgem’s rationale for undertaking an intermediate step, before consulting on the removal of the WoM code requirement for PCWs.

In response to Ofgem’s proposal within this consultation, to replace the default WoM requirement with a default partial view, Citizens Advice wish to reiterate the importance of ensuring the right measures are in place to prevent any negative impact on consumers.

We strongly support the need for transparency and clarity for consumers when the default WoM view is removed. We also strongly suggest that all the changes that have been proposed within this consultation are closely monitored, and appropriate consideration is given if it becomes evident that the consumer experience has deteriorated.