Where we explore best practice in the switching process
Supply Effective from Date
Energy Suppliers should take all reasonable steps to switch a Consumer within five working days of the Relevant Date. The Energy Supplier should communicate the Supply Effective from Date as the Relevant Date can only be determined once the Energy Supplier has all the information needed to trigger the switch.
Price Comparison Websites are currently unable to reliably inform Consumers what their Supply Effective from Date will be at the Point of Acquisition.
Cooling Off
Consumers have the right to cancel their energy contract up to 14 days after the relevant date as per The Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013.
Price Comparison Websites and Energy Suppliers are both responsible for ensuring that Consumers are aware of their rights in relation to the Cooling Off Period.
At the Point of Acquisition, the Price Comparison Website should inform the Consumer of their right to change their mind about the contract they have agreed. Once the Relevant Date has been determined, the Gaining Supplier should inform the Consumer of the precise dates of their Cooling Off Period so there is no ambiguity or confusion.
Consent to bill
Energy Suppliers can choose to set a later Relevant Date if express consent to pay for charges accrued in the Cool Off period is not obtained.1
Price Comparison Websites should obtain the Consumer’s express agreement at the Point of Acquisition to pay for charges accrued during their time with the Gaining Supplier, should they choose to exercise their right to Cool Off.
1As detailed within paragraph 14A.3 (f) of the proposed Standard conditions of Electricity Supply Licence and 14.A.3 (f) of the proposed Standard conditions of Gas Supply Licence published 13th December 2021
Priority Services Register Information
Energy Suppliers are required to identify Consumers who qualify to be added to their Priority Services Register and to offer to add the Consumers information to said register during interactions with them.
To ensure a seamless Consumer Journey Price Comparison Websites should collect Consumer’s Priority Services Register information at the Point of Acquisition. Where Priority Services Register information is collected it should meet existing standards and requirements detailed within the Retail Energy Code as a minimum.
Objection Communications
The implementation of Faster More Reliable Switching is changing the scenarios where it is appropriate for an Energy Supplier to object to a switch occurring.
Price Comparison Websites should ensure that any information or communication issued to Consumers on the topic of objections is accurate and up to date.
Data Validation
Energy Suppliers are required to take all reasonable steps to ensure they hold a Valid Contract with a Consumer prior to a switch being instigated to prevent Erroneous Switches. The information Consumers provide at the Point of Acquisition should be validated against industry data where available, such as the Retail Energy Location, to ensure that switches using this sales channel are not increasing the risk of exceptions and delays for Consumers.
Standstill Period
At the point of implementation, the Standstill period has been set at 5 calendar days.
Standstill Periods are not anticipated to be a permanent aspect of Faster More Reliable Switching and cannot be accurately validated by Price Comparison Websites, the Energy Supplier will validate this when confirming the Supply Effective from Date.
Tariff availability
Incompatible meter types can trigger rejections and simplistic rules can exclude valid tariffs, for example a Consumer with a two-rate meter can still be charged on a single rate tariff. Tariff availability based on meter type, or functionality, is likely to evolve with the Smart Meter Rollout and Market Wide Half Hourly Settlement so continued engagement between Energy Suppliers and their commercial partners is encouraged to be ongoing.
Future Dated Switches
There are no regulatory changes impacting the Consumer’s ability to select a future dated switch however not all Price Comparison Websites currently provide the functionality to do this. It is recommended, particularly considering recent price volatility, that this is explored in the future as there may be Consumer benefits to delaying a switch for a brief period or being able to choose a Supply Effective From Date for personal circumstances.
Data Transfer (APIs)
Whilst Energy Suppliers should take all reasonable steps to switch a Consumer within 5 working days once the Relevant Date has been established, it is not considered in the spirit of the Switching Programme for unnecessary delays to occur prior to the Relevant Date being established. It is recommended that Price Comparison Websites avoid delays between gathering the Consumer’s instructions at the Point of Acquisition and providing this information to the Energy Supplier to determine the Relevant Date via an API rather than submitting batch file requests.