Citizens Advice response to Ofgem’s proposed Forward Work Programme 2026-27

Citizens Advice response to Ofgem’s proposed Forward Work Programme 2026-27 245 KB

We welcome Ofgem’s forward work programme and broadly support its proposed priority areas.

Under the priority on shaping a retail market that works for consumers, we support Ofgem’s proposals and particularly welcome the commitment to reducing debt and raising billing standards. It’s important that the Debt Relief Scheme is implemented without further delay and that improvements to billing standards are ambitious.

We welcome Ofgem’s intention to consider a move towards outcomes-based regulation, though we continue to call for this to include an overall Consumer Duty, similar to the one introduced by the Financial Conduct Authority’s (FCA). A move to this model will rely on effective monitoring, compliance and enforcement. We support the new compliance operating principles, and are keen to work with Ofgem on how our monitoring can support this. We remain concerned that enforcement cases can move too slowly, with investigations related to the prepay scandal still not completed 3 years after they began.

We also support Ofgem’s priorities around introducing new regimes for load controllers and third-party intermediaries. With the implementation of new protections for heat networks consumers, we expect consumer outcomes and confidence in the sector to improve. Ofgem’s initial areas of focus should be on reducing harm from disconnection, back-billing and reliability issues, driven by consumer research and data. It’s also important that heat network consumers are not considered separate to other energy markets; instead they should be integrated into Ofgem’s wider work wherever possible.

Under Ofgem’s work to enable infrastructure for net zero at pace, we welcome measures to strengthen accountability and consumer confidence. As the value of network price controls increases to fund necessary investment, Ofgem must hold network companies to a significantly greater level of transparency. We welcome Ofgem’s priorities on asset risk and system-wide energy resilience and on creating a more transparent innovation ecosystem.

Finally, on establishing an efficient, fair and transparent energy system, we support the areas of focus but feel there is scope for more ambition. For example, we are pleased with Ofgem’s continued commitment to the delivery of a Consumer Consent Solution, however we outline concerns around current progress failing to fully meet consumer needs and the original goals. We support code reform, though emphasise the need for continued harmonisation of procedures and processes.

We have provided more detail in response to specific proposals within Ofgem’s 3 strategic priority areas.