Citizens Advice response to consultations on code reform implementation and code manager licencing

As the statutory consumer advocate for energy consumers Citizens Advice has engaged in the detailed work of industry codes for many years and we have a unique perspective of their operation. 

They represent a fundamental part of the whole energy system and they govern and facilitate significant changes which affect all end consumers of energy.

Across both consultations from Government and Ofgem we welcome much of the direction of code reform including:

  • which codes will be consolidated 

  • the intention to revise code objectives and improve code modification processes

  • the constitution of the Stakeholder Advisory Forum (SAF)

  • the requirement for code managers to be not for profit bodies

  • the levels of prescription in the code manager licence

  • the consideration of the role of statutory consumer advocates in future processes

In the two responses we set out areas for clarification and a number of recommendations including:

  • Identifying areas of codes for part consolidation early on

  • Introducing a consumer benefit code objective to align with Ofgem’s statutory duties and a consumer interest licence condition

  • Providing a formal appeals route for code manager budgets

  • Providing additional checks and balances to the performance regimes of code managers where there are not licenced or codified financial incentives

  • Requiring a consumer champion to code manager boards in line with the FCAs Consumer Duty

Citizens Advice response - Energy code reform: implementation consultation 168 KB

Citizens Advice response - Energy Code Reform: Consultation on Code Manager Licensing and Secondary Legislation 172 KB

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