Our response to Ofwat consultation on Customer Protection Code of Practice – Tranche 2 changes

We welcome the opportunity to submit our views on this consultation on the Customer Protection Code of Practice (CPCoP) Tranche 2 changes.

Key points

We are supportive of Ofwat’s proposals to increase the protections afforded to business customers by the CPCoP in the Tranche 2 consultation.

We are pleased that Ofwat has fully considered the majority of the requests for change we put forward in our response to the Call For information in June 2023. Many of our requests were informed by the recommendations from our report on ‘Business Customers’ Experience of the Water Retail Market – Five Year Review’.

We support the proposals to:

• Extend protections afforded to micro businesses to small business customers
• Introduce additional protections for vulnerable customers by requiring retailers to develop a vulnerability strategy
• Improve collection and sharing of customer contact information in emergency or unplanned events
• Increase customer awareness of the market and their ability to switch or renegotiate contracts through messaging on bills and the Open Water website
• Require retailers to provide more information to customers to help resolve switching request blocking issues
• Require retailers to submit annual statements of compliance within the CPCoP

We would like to see the following further changes:

• We do not believe that customers should have to wait for up to six weeks to receive a final bill and think this should be reduced to a maximum of four weeks.
• We want to see retailers issue at least two bills a year to their metered customers, based on actual meter reads, and we submitted a separate code change request to Ofwat in December 2023 on this.
• We want to see retailers refunding annual credit balances to their customers and we continue to work with Ofwat to push the objectives from our Credit Where its Due campaign
• We strongly believe there should be a set timescale of six months for dealing with code changes. Any deviations to this should be by exception and not a reason to refrain from setting a defined period by which Ofwat will evaluate, consult and make a decision on a change proposal. We repeated this request in our response to the Tranche 1 CPCoP consultation.