Citizens Advice response to Ofgem’s Consultation on Deemed Contracts and Standard Licence Conditions 7.3 and 7.4
Citizens Advice welcomes the opportunity to respond to Ofgem’s proposed changes to their guidance on Deemed Rates. We agree that the proposed changes will enhance clarity in the areas outlined, and remove key ambiguities relating to SLC 7.3 and 7.4. We are strongly supportive of Ofgem’s proposal to introduce a comparative approach to bad debt recovery, aligning deemed contract and contracted consumers, but would encourage Ofgem to produce guidance which outlines situations in which a security deposit may be deemed acceptable, as well as what constitutes ‘reasonable’ recovery of bad debt.
However, we believe that the updated guidance fails to address two significant issues which are commonly experienced by non-domestic consumers on deemed contracts: billing frequency and change of tenancy. Therefore, while we support the proposed updates to the guidance, we also urge Ofgem to consider how to address these outstanding issues for consumers who are on deemed contracts.