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by Karma Loveday

Retailers exempt from annual meter reads until September

On Friday, Ofwat implemented an urgent change proposal exempting retailers from their obligation under the Customer Protection Code of Practice (CPCoP) to use a meter read to provide an accurate bill to metered customers at least once a year. This is in light of meter reading difficulties being experienced by retailers, contractors and customers during pandemic restrictions.


The regulator made some slight adjustments to CP0008, which it consulted on in February, but the fundamentals of its proposals stood. Under the plans, the exemption is available until 30 September 2021, or until Ofwat notifies retailers in writing of another date. To qualify for the exemption, retailers must demonstrate they have made “all reasonable efforts” to contact the customer, and provide evidence that they have met the criteria for the exemption. This includes attempting to contact the customer on two separate business days, where possible using different contact methods.


Among the changes made from the February draft were:

• a provision to recognise “any preferences expressed by the non household customer” in terms of how contact is made, in light of privacy and data protection;

• clarification that a meter reader attending the premises would count towards one of the contact points;

• specification that retailers are to use the “best available data” to estimate bills;

• provision for retailers to provide a summary of the basis for the estimated bill to customers rather than a detailed methodology – “for example, ‘based on previous consumption, type of business premise’ etc”; and

• extension of the time available for retailers to produce records of compliance from two business days to five.


The February draft was itself an adjustment of the original CP0008 Code change proposal put forward by Castle Water, which sought to allow retailers to bill customers based on estimated consumption. Castle pointed to the mounting backlog of meters that required a read and retailers being unable to comply with the CPCoP while premises are closed and meters inaccessible. It proposed retailers be allowed to estimate consumption where Covid restricted reads, and where customers had been unable or unwilling to provide a read themselves, or non-responsive to retailer contacts.


Ofwat accepted the sentiment, but noted that meter reading is not banned under current Covid restrictions, and that its December Call for Inputs showed retailers faring very differently on gathering meter reads. It was also concerned that as drafted by Castle, “the change proposal may diminish the responsibility on retailers to adequately engage with their customers in an effort to obtain a meter read or even understand consumption at a premises…[and] could normalise the use of estimated consumption to calculate bills.”

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