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Statutory Consultation - Involuntary PPM

26 July 2023

Statutory Consultation - Involuntary PPM

Citizens Advice welcome this consultation, which has the potential to improve the regulatory landscape for people affected by prepayment meters. We support the proposals to integrate the Prepayment Meter (PPM) Code into the supplier license conditions. As part of this process, Ofgem should amend the code in the following ways:

● Include children under the age of 5 in the Do Not Install category.
● Include the treatment of certain serious mental and developmental health conditions in the Do Not Install category.
● Clarify the treatment of chronic obstructive pulmonary disease (COPD) and its constitutive conditions in the Code by moving it into the high risk category.
● Clarify the timetable for the 10 contact attempts to engage with the consumer.

As we outlined in our response to March’s call for evidence on prepayment rules and protections, the impact of high energy prices and the wider cost of living crisis has meant that the risks associated with force-fitting a prepayment meter are far more significant now compared to when the rules around involuntary PPM were first introduced. As such, we believe that Ofgem is taking the correct steps to supplement principles-based regulation with more detailed guidance in this area. We support formalising these changes by integrating them into the supply licenses.

Enforcement and monitoring will be vital to ensure that these changes deliver meaningful and lasting improvements in suppliers’ actions and in outcomes for consumers. We have been encouraged both by Ofgem’s recent approach to monitoring and enforcement through tools such as Market Compliance Reviews, and by the proposed monitoring arrangements set out in the statutory consultation. Together, these provide a more secure basis to safeguard vulnerable consumers in the future.

However, the success of these changes will rely on prioritising monitoring and enforcement, especially over the course of the first winter that they apply (2023/24) to ensure meaningful changes have been implemented by suppliers and are leading to better outcomes for consumers.