Citizens Advice response to DESNZ’s Smart Secure Electricity Systems (SSES) Programme: Phase 1 Energy Smart Appliances Regulations Consultation
Citizens Advice welcomes the opportunity to respond to DESNZ’s consultation on the first phase of the Energy Smart Appliances (ESA) regulations under the Smart Secure Electricity Systems (SSES) Programme. Establishing minimum smart functionality standards across appliances in scope will be important for consumer confidence, interoperability and usability, and we are broadly supportive of this direction of travel.
Smart and flexible technologies have the potential to reduce bills and support system decarbonisation. However, these benefits will only be realised if appliances work in ways that are predictable, transparent and controllable in practice. Essential services such as heating must not become difficult to manage or understand as a result of smart or automated operation. Consumers need to know when and why their appliances behave differently, and to retain meaningful control, including the ability to override automated functions.
We welcome proposals on digital interfaces, metering, cybersecurity, assurance and flexibility guidance packs. These requirements will only deliver real benefits if they result in products that are accessible and usable for a wide range of households. Information must be clear and available in accessible formats, and accountability across manufacturers and importers must translate into clear routes to redress when things go wrong. The framework should also support interoperability and avoid locking consumers into a single provider or restricting repair.
We also highlight the importance of applying lessons from the EV smart charge point market to other appliances, particularly around load control, randomised delay and consumer expectations. Transparency about how delay, override and flexible operation work in practice will be critical to maintaining trust in smart technologies.
Finally, we note that the Initial Impact Assessment relies on optimistic assumptions about consumer engagement. Distributional impacts and Equality Act considerations should be kept under review, particularly for people who need predictable warmth, who may struggle with complex digital interfaces, or whose routines cannot easily shift in response to system signals.
Overall, the success of the ESA regulations will depend not only on technical compliance, but on whether they deliver systems that genuinely work for consumers in everyday life.