Our Response to Ofgem’s Switching Programme: Regulation and Governance – Way Forward and statutory consultation on licence modifications

Gemserv acknowledges the ambition and intent around the creation of a “best in class” code. We also recognise the challenge associated with that particular vision. We see evidence of innovative thinking in how the REC is being developed and enthusiastically support this approach. However, we believe there is a golden opportunity to go further and make the REC a truly transformative platform for energy governance. While continuing to deliver for today’s market and market participants, we also need to set the right direction for the market of tomorrow and for the type of market participant and consumer that has yet to be defined.

In representing existing retail energy code Parties, we have already contributed significantly to the design and drafting of the REC. Through this involvement, we have been fortunate to share the thinking and insights of a wide range of Suppliers. The, sometimes considerable, differences that exist in Suppliers’ requirements will set unrealistic expectations. Indeed, we fully appreciate there will be perceived “winners” and “losers” in a new design and this perception will naturally drive resistance to change. However, we must challenge this resistance and demonstrate that in a fair, modern and consumer-focused market there is opportunity for all types of Party. Gemserv has seen this market paradox at first hand in its Innovation Workshops: there can be consensus between Suppliers operating on different business models and on different scales. We have brought our findings together in a series of thought leadership papers that show how the motivated can engage in an innovative market promoting competition among Suppliers, and value for money for the end consumer.

Gemserv’s own opinion and understanding of digitalisation has undergone considerable revision since our recent acquisition of a business specialising in that environment. Market design and governance can no longer be developed on the basis of known technologies. We need to develop on the basis of creating a framework capable of accommodating unknown and, to some extent, currently unimaginable technology. With data offering new and innovative opportunities in the market, we need to be open to the power of digitalisation. We need to understand the full implications and a proper data strategy needs to be established, to avoid the development of arrangements that inhibit the Code Manager from offering new and innovative solutions, aimed at improving the working and efficiency of retail arrangements.

To read the full response please click below:

Our Response to Ofgem’s Switching Programme: Regulation and Governance – Way Forward and statutory consultation on licence modifications



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