Energy Consumers Network
Note of Meeting 8
Date: Thursday 25 September 2025
Location: Consumer Scotland Offices, Edinburgh, and Online.
Attendees:
Chair - Lewis Shand Smith
Advice Direct Scotland - Pamela Stewart
Changeworks - Laura Webb/Morven Masterton
Community Energy Scotland - Jenni Marchant
Citizens Advice Scotland - Molly Shevlin/Stephanie Mander
Consumer Scotland - Barry Coughlan, Alastair Wilcox, Hannah Corbett
Energy Saving Trust - Beth Mukushi
Local Energy Scotland - Laura Campbell
Scottish Federation of Housing Associations - Cassandra Dove
Trust Alliance Group/Energy Ombudsman - Craig Wilson
Smart Energy GB - Christina Panayiotou/Lyndsey Croal
Foundation Scotland - Suzi Mercer
Secretariat, Consumer Scotland - Christopher Jones
Apologies
Development Trusts Association Scotland - Pauline Smith
Age Scotland - Adam Stachura
Fuel Bank Foundation - Matt Cole
Ofgem - Adam Cochrane-Williams
The Wise Group - Suzanne McWilliams
The University of Edinburgh - Dan Van Der Gorst
Welcome and introductions
1. The Chair welcomed members to the meeting.
Chair’s Update
2. With a number of new and guest members in attendance at today’s meeting, Chair provided an overview of the Energy Consumers Network (ECN). Chair highlighted the broadening role of the ECN, highlighting its recent new role with community energy organisations, including a number of these new bodies attending today, and its ongoing consumer role and feeding into the Scottish Energy Advisory Board (SEAB)
3. Since the last bi-annual meeting in May 2025, the ECN had hosted a subject-specific community benefit toolkit workshop with the aid of the Scottish Government’s team in this area. The aim of the workshop was to assist in the designing of a standardised toolkit to support and empower community groups to utilise community benefit in their areas. A Scottish Government note of that meeting and its findings had been shared with attendees before that meeting.
4. The Chair also provided an update on Scottish Government roundtables, that a number of ECN members had been invited to previously, regarding rural, consumers in vulnerable circumstances, and non-domestic consumers in Scotland.
Member’s Update
5. Changeworks - Advice Demand is ramping up due to time of year, provided an overview of advice services targeting rural, park homes and ethnic minority groups and Affordable Warmth Services.
6. Recognise that suppliers scrambling to use additional Warm Home Discount (WHD) Industry Initiatives funding before end of March 2026. Lots of support for energy advice but not advocacy on behalf of consumers, especially with complex cases. Question about when WHD funding had to be spent and whether it could be used for advice outside of the WHD scheme window (post March), advised that it could not. Retrofit funding increasing, including Area Based Schemes.
7. Highlighting that there have been changes to the Executive Team, which means that Morven Masterton will be taking on the role as the main ECN contact going forward. The Chair and ECN members made note to thank Laura Webb for her invaluable contributions to ECN to date.
8. Consumer Scotland – CS update focused on topical issues in the retail energy space, namely Debt Relief Scheme (DRS), and Radio Teleswitch Service (RTS) Switch-Off.
9. Provided an overview of Ofgem’s development of a DRS to tackle historic levels of debt in the domestic energy sector, now sitting at £4.4bn. Explained CS position to date had been to advocate for a scheme that worked for Scottish consumers considering historic affordability targeting challenges, devolved institutions and devolved debt landscape. DRS has now been split into 2 phases, first phase to target means-tested benefits recipients and second phase to target consumers with energy crisis debt that can’t be targeted in phase one. Second phase would require support from the advice sector to support consumers with income/expenditure forms to access debt relief in a limited frame of time. ECN queried whether the use of DWP data would include SSS data, in light of devolved disability benefits. The Digital Economy Act 2017 (DEA) provides a legal gateway for The Scottish Ministers to share data. As Social Security Scotland is an executive agency, it may need to be named explicitly, but there is a data sharing agreement between DWP and SSS (as has been used for other purposes) that may allow for devolved data to be shared for DEA purposes that negates the need of explicit reference.
10. RTS switch off was continuing with updated public figures from Ofgem of around 84,000 meters remaining in Scotland. Two phases of group code switch-offs had taken place to date, including households in Scotland. Ofgem were taking learnings from these phases to inform future group codes and how suppliers engage consumers in affected areas. Group code switch off would pause in Scotland from October to March 2026 as part of the risk-based approach during the winter months. Supplier meter replacements would continue during this period. Noted concerns with the slow provision of a remedial fund and the need to use Energy Redress Funding as a source of this. Noted how a number of questions about the fund that were summarised were still to be answered, including whether the fund would be retrospective for work already carried out, and the practicalities of a consumer accessing the fund as it must be delivered by a third party organisation. These questions were still to be addressed.
11. CS new starter Hannah Corbett (Hannah.corbett@consumer.scot) provided a brief overview of her current work, focusing on the needs of park homes and rural homes, Third Party Intermediaries, and non-domestic businesses. HC keen to speak to other stakeholders about these.
12. Energy Savings Trust (EST) – Demand for EST has remained reasonably high, including for Home Energy Scotland.
13. Programme of referrals starting with NHS partners, and working on simplifying consumer journey for HES. Already seeing big improvement based on internal metrics for consumers and suppliers. Improvements include a shift to having a named contact, written guidance, and removal of some of the documentation requirements. EST were continuing work on this with more improvements to come.
14. Community Energy Scotland (CES) – Provided a brief overview of their role at the COSLA Conference on 24 September. This included the news of the launch of the “Community Energy Launchpad”, a project that aims to help and support community capacity to learn more about community energy and explore options open to them through the Scottish Government’s Community and Renewable Energy Scheme (CARES). The Launchpad involves joint work with Development Trusts Association Scotland (DTAS), Local Energy Scotland (LES) and CES. There are 6 CES offices based in locations around Scotland.
15. Local Energy Scotland (LES) – Pleased to be working on Community Energy Launchpad project, believes it will serve to fill a large gap needed to provide resources and support for community groups interested in community energy.
16. LES Highlighting that the CARES Development Fund has also launched, to provide additional technical support for community groups at the start of their community energy projects. CARES has utilised GB Energy funding to increase staff to 13 development staff and 4 specialists with focuses on community benefits and community/shared ownership.
17. Shortly to announce around 40 projects that have been successful for funding. Very happy to see up tick and interest in community energy in the sector. Scottish Government have asked LES look at community benefits forum, to discuss opportunities and networking to learn from each other. They are aiming to publish register of community ownership and get useful case studies and stories. Annual report highlighting this and want to draw this data out and showcase community energy projects.
18. Citizens Advice Scotland (CAS) – Energy advice is the highest growing advice need facing CAS at the moment. Of those advice issues, energy costs is a year round issue with 1 in 7 people approaching a bureau looking for advice on energy affordability. The demand for such advice has jumped 65% in recent years. Additionally, the average energy debt presenting is £2,500, and £3,100 in rural areas.
19. CAS highlighting their future work, including feeding into DRS and also concerns on how this may impact the advice sector.
20. CAS continue to be concerned about RTS switch-off. At the same time, also seeing an uptick in people seeking advice on smart meters, up 28%. 60% of clients asking for energy advice were also asking about smart meters. CAS believe that this in part driven by RTS replacements which will introduce consumers to smart meters.
21. CAS drew members attention to publication of “Energy Brief”, a quarterly newsletter that highlighted all their energy related statistics and invited any members who were interested to receive this to reach out to Molly Shevlin who will also be the CAS ECN contact going forward.
22. Energy Ombudsman (EO) – Brief update as covering more on potential future of complaints journey in dedicated EO session later.
23. EO highlighting still in new remit of supporting up to small businesses, still ramping up levels of support and adviser capacity. EO also provides Alternative Dispute Resolution (ADR) for disputes with all energy brokers.
24. Also now the redress provider for heat networks. Still in its infancy but will be reviewing what insight and data comes out of this new role.
25. Foundation Scotland (FS) – Providing an overview of Foundation Scotland. Reflecting on a busy year for practice, delivery and policy space. In policy space a lot going on, but particular focus includes Transmission Guidance that came out in April 2025, and Community Benefit Good Practice principles.
26. These were last updated in 2019 for solely onshore wind, and the SG consultation was to update for all generator types. After the Scot Gov consultation closed, DESNZ launched their transmission Community Benefit consultation. DESNZ was focused on mandating payments, and delivery of payments.
27. FS focused on advocating a compliance framework, communities are different and the community benefit provisions need to be able to fit to their differences. Some concern there may be a race to the bottom if there was a list of minimum requirements for community benefits. Additionally, concerns about DESNZ consultation that capacity building wasn’t being talked about in the right way.
28. Scottish Federation of Housing Associations (SFHA) – RTS continues to be an issue for a number of social tenants. Engineering capacity for meter replacements had built up but from what SFHA is seeing this may be dropping down again with issues with some social landlords and tenants struggling to get appointments in a timely manner.
29. Social landlords still waiting on energy efficiency standards and some waiting for net zero heating fund, which needs to be drawn down by March 2026.
30. Heat networks continues to be a large part of SFHA’s work. A key ask is that the regulations are proportionate for not-for-profit providers, which many heat network providers are. There is a risk that consumer protection or compensation may request things that aren’t possible, including compensation payments. Unclear how these might be funded by an organisation that would be not-for-profit other than increasing costs on its own users who it would also be compensating.
Changes to the Consumer’s Complaint Process - Energy Ombudsman
31. Presentation on an overview of potential changes to the powers and role of the Energy Ombudsman (EO) in light of proposals from DESNZ.
32. EO presented a brief overview of structure and history of the EO, and its volume of cases currently with around 90,000 cases a year, of which 58% related to billing, 14% customer service, and 12% smart meters.
33. EO discussed the current process for dealing with an energy supplier complaint, including (a) current 8 week waiting period before referral; (b) supplier notifying consumer of rights and consumer approaching EO; and (c) any EO proposed supplier remedy needing to be actioned within 28 days.
34. Potential EO reforms are included as part of the DESNZ Review of Ofgem. The then Energy Consumers Minister, Miatta Fahnbulleh MP, explained that the current system makes it too difficult for consumers to access proper compensation, placing onus on consumers to self-refer to EO, often with consumers not accessing compensation they are entitled to due time pressures and complexity of the system. The Call for Evidence that closed in February 2025 included specific focus on the role of EO. Expectation that there will be recommendations and further consultation expected in Autumn 2025.
35. From the Call for Evidence, proposals to reform EO process fall into 3 categories:
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- Auto-Compensation – similar to other consumer markets, implementation of automatic payments for excessive call waits, failure to adjust direct debits and not responding to EO remedies. EO view is these are quick, pro-active. Potentially blunt instrument that recognises an average level of detriment, and can generate complaints of its own if smaller payment does not satisfactorily resolve issues for consumers (seen in telecoms sector). EO emphasised that this should not erode the role of the EO and consumers’ ability to choose to approach it.
- Reducing the Wait – Current 8 week window may be reduced to 4 weeks. Based on consumer fatigue of current journey, one month viewed as reasonable. Consumer choice on whether to escalate is still important factor. Hope this will resolve cases more quickly, with EO noting that many cases they receive are not complex
- Implementing Decisions – EO remedies are contractually binding on suppliers, with 92% of remedies implemented on time. However, there are occasions of non-implementation. New proposal to ensure swift remedy and compliance with decisions. It is possible this may include statutory footing for the EO, though not clear exactly what this may look like at this moment (e.g. primary legislation, secondary legislation, licence condition changes – some doubt on this last option as current SLC breaches have not necessarily improved rate of implementing decisions).
- Automatic-Referral – Research from EO suggests that only 1/3rd of consumers who could come to EO do so, potential lack of awareness and a perception of hassle are key hurdles. Further, only 43% of cases are correctly signposted to EO by suppliers. Therefore, proposed two major changes – (1) at week-8 or deadlock, draft case created using data received from supplier; and (2) consumer contacted by EO to ask if they would like to proceed. Currently undergoing a Test & Learn phase to launch with 2 large suppliers this autumn. There are expected to be teething problems to be worked through by all parties.
Engaging Everyone on the Journey to a Smart Future - Smart Energy GB (SEGB)
36. SEGB explaining its roll in Britain’s smart meter rollout, its position as an independent not-for-profit organisation funded by industry, with a board formed by a mix of consumer and energy supplier representatives.
37. To date, SEGB’s modelling shows that their campaign activity has driven around 50% of smart meter installations. It is SEGB’s role to build consumer demand for smart meters, encourage energy behaviour change, assist those in vulnerable circumstances and engage with stakeholders.
38. On numbers for the rollout to date, 99% of people are aware of smart meters, and more than 39 million smart meters have been installed across GB, with 69% of meters in GB being smart meters based on June 2025 data from DESNZ. SEGB undertakes insight and analysis work, including smart energy outlook survey that asks around 10,000 people in GB twice annually. Includes qualitative research that is tailored to specific audiences, and also undertakes ‘deep dives’ which analyse how different groups respond to SEGB campaign activity. Also undertake weekly energy market tracker to measure response to current energy situation and market environments.
39. Turning to consumers in vulnerable circumstances, SEGB undertakes the following specific activities as part of its work programme:
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- Dedicated strategy for reaching consumers in vulnerable circumstances;
- Advocates at board level and within senior leadership;
- Partners in charity and third sector with specific experience;
- Share best practice with industry and stakeholders;
- Cross organisational working group;
- Inform their campaign work through research and insight on needs of consumers in vulnerable circumstances.
40. Specific examples of this work include the free resources for communities, including BSL videos of smart meter explainers, and multi-lingual resources. SEGB also partner with organisations including Age Cymru, Iceland, and EFL so that there message can meet people where they are.
41. SEGB discussed their role within RTS switch-off today. SEGB stressed it is independent of suppliers and Ofgem, and has supported media and messaging of the campaign before the June phased switch-off deadline (note, most messaging was done under Ofgem branding). SEGB note recent work they have been doing with MSPs, providing resources and assets. SEGB will receive some inquiries from MSPs about RTS, but due to SEGB’s function they will signpost to suppliers or the advice sector for further support.
42. SEGB setting out how they would like to partner with ECN members to reach consumers in vulnerable circumstances. SEGB interested in direct to consumer community engagement:
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- Engaging and recruiting local partners and community organisations;
- Identify and support community events that are already taking place that they can support and potentially reach consumers in vulnerable circumstances too;
- Addressing consumer specific barriers;
- SEGB have access to Ofgem data (confidentially) on areas where consumers have not yet received a meter replacement and can potentially work with consumer groups in these areas to help reach some of these consumers;
- SEGB can help demonstrate flexibility as phase out plans evolve, and are keen to receive any further elements or ideas for delivery that SEGB may have no considered.
43. During the Q&A ECN members highlighted some risks with the Ofgem messaging to date on where suppliers may be switching off group codes next, and where this changes it damages the reputation of charities (undermining credibility). ECN members noting that the confidence in the consumer journey has been harmed by pauses and changes with deadlines moving and changing, underlines why messaging is so important for an orderly switch-off.
Ofgem Energy System Cost Allocation and Recovery Review – Consumer Scotland (‘CS’)
44. The structure of energy system costs and how are potentially changing. Major investments are needed now to secure long-term benefits, but existing sunk costs still need to be recovered to maintain investor confidence. Previous reforms (TCR and Access SCR) improved cost reflection in charges but didn’t fully address fairness concerns. Public perception of unfairness remains, especially around standing charges. Transparency improves consumer sentiment; better information reduces negative perceptions.
45. There are some key questions for Ofgem’s Call for Input:
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- What costs should be recovered via energy bills vs. general taxation?
- How should costs be split between:
- Gas vs. electricity?
- Domestic vs. non-domestic consumers?
- Within domestic groups (e.g. by payment method)?
- Should redistribution or targeted support be used to ensure fairness?
- Ofgem urges stakeholders to consider these through the lens of the cost stack and whether charges align with cost drivers.
46. Currently, a consumer bill is broadly split between he following costs and charges, with some specific insights:
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- Wholesale costs;
- Network costs – Gas network costs are mostly recovered volumetrically despite being largely fixed.
- Supplier operating costs
- Policy costs (e.g. social and environmental levies) – currently these form around 17% of typical electricity bill in Scotland, but only around 7% of a typical gas bill. Note, commodity-related policy costs can be considered a component of wholesale costs, as they reduce direct fuel costs by providing a subsidy which de-risks investment in low carbon energy production. In so doing, they change the price at which the market clears and thereby reduce the total market cost to consumers by more than the aggregate value of the subsidy.
47. Considering the broader context of Ofgem’s Cost Allocation review, it intersects with a number of other reforms (REMA, TNUoS reform, DuoS reform). The implementation of it will have to be phased over several years, and scope of it will ultimately be shaped by the responses to this Call for Input and government’s flexibility to tackle different topics.
48. CS highlighting a number of potential issues that will need to be addressed:
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- To what extent should non-commodity policy costs be recovered from billpayers?
- How to overcome barriers to cross-government and inter-government co-operation in maximising the impact of social policy (particularly in relation to the knowledge and sharing of data to enable appropriate scheme design and delivery)?
- How to account for the intangible costs of the energy system?
- Distributional fairness (by location, by party, over time) – how to define “fair”?
- Least cost cf. best value – how to define “value”?
49. CS turning to their view on where they believe Ofgem should start. Ofgem set out their objectives or principles in its Call for Input, however CS believe Ofgem should instead adopt other principles based on a paper prepared for the European Commission in 2020 being:
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- Cost reflectivity: Costs paid by consumers should reflect the impact they have on the network, including any benefits they provide (eg in the form of flexibility), so that tariffs are non-distortionary; decisions by users concerning connection and use of the network should not be influenced by non-cost reflective tariff components;
- Cost recovery: DSOs and TSOs should be able to efficiently recover incurred operational and investment costs, including connection charges and system service costs through network connection, access, and use-of-system tariffs;
- Non-discrimination: There should be no undue discrimination among network users. Charge allocation should be done on the basis of network costs caused or avoided due to the actions of the network user;
- Transparency: the methodology for calculating tariffs should be transparent and accessible to all stakeholders;
- Predictability: Tariffs should be sufficiently predictable for the network users to enable their estimation of incurred network connection and access costs, and to facilitate investment decisions;
- Simplicity: Tariffs should be easy to understand as far as possible, in order to support transparency and predictability, thus providing the adequate information for network users to take their investment and operational decisions.
50. CS raised a number of questions that Ofgem will need to answer about the options to recover energy system costs from domestic consumers. How this is answered risks a misalignment of costs and charges that can lead to inefficiencies in the system and unfairness to consumers. For example, recovery of fixed costs through volumetric charges creates system-level inefficiencies and implicit cross-subsidies between high use and low use users, and if suppliers carry increased risk through volumetric cost recovery this can lead to additional risk premium being added to bills. However, some of these clash with topical consumer concerns e.g. recovery of fixed costs through standing charge increases has led to a perception of unfairness.
51. CS believes this ultimately means that the review is about efficiency and fairness in the distribution of costs and charges. What is the nature of costs and risk that suppliers ought to be exposed to. Better alignment of costs and charges may reduce costs for all, and can improve targeting and efficacy of redistribution / support payments. Suppliers should in general have control over how their tariffs are set, e.g. see TCR effect on standing charges and unit rates to reduce volume risk. Suppliers will retain flexibility in tariff design to best serve commercial interests and customer need, but Ofgem’s role in setting the default tariff cap remains key.