Ofgem Call for Input on the Third-Party Intermediaries market review - Which? response

Which? welcomes this opportunity to respond to Ofgem’s Call for Input on the Third-Party Intermediaries market review. We fully support Ofgem’s new role as regulator, as it provides a crucial opportunity to address long-standing issues within the sector and improve consumer outcomes. 

Our response highlights four priority areas for the market review to explore: 

1. Increasing transparency and consumer awareness: A lack of clarity regarding pricing, commissions, and supplier affiliations undermines consumer trust. We recommend that the market review considers the case for mandatory transparency standards, such as requirements for TPIs to disclose these details upfront and clearly explain their market coverage. 
2. Improving protections for vulnerable consumers: Currently, there are no consistent approaches to identifying and supporting vulnerable individuals. The market review should consider what measures are needed to guide these consumers toward suitable products and offer better protection, particularly as the market for more complex smart tariffs expands. 
3. Improving complaints handling and access to redress: The sector lacks systematic complaints procedures for domestic consumers. For TPIs that provide ongoing services, such as auto-switching, we recommend enforceable standards and timelines for complaints handling and mandatory access to free, accredited Alternative Dispute Resolution services. TPIs that primarily offer information or advice, such as price comparison websites, should provide clear guidance on where consumers can turn if they experience issues with the energy providers or services they select. 
4. Enforceable Standards and Authorisation: We believe voluntary codes are insufficient. A mandatory authorisation regime is essential to ensure consistent standards, hold TPIs accountable, and protect consumers from harm. 

Finally, while the TPI sector is vital for supporting the energy transition, the development of smart tariff comparison tools is currently hindered by commercial and technical barriers. However, we are not aware of systematic evidence on the nature of these barriers. We urge Ofgem to ensure the market review establishes a clear view of the barriers to development of these much needed services so that action can be taken to tackle them. DESNZ is also currently assessing whether consumers who receive government assistance for low-carbon technologies should be defaulted onto time-of-use tariffs. If this policy goes ahead, ensuring that consumers can seamlessly and rapidly review their options will be essential.