Involuntary prepayment meters
A supplier can seek to install a prepayment meter or recalibrate a smart meter to prepayment mode without your written or verbal consent.
In all cases, suppliers should individually assess the suitability of each household for involuntary prepayment meter, including considering if it is ‘safe and reasonably practicable’ (see here). An involuntary prepayment meter cannot be installed for those highest at risk. They fall under the ‘do not install’ category.1Ofgem, Guidance: PPM (safe and reasonably practicable), 13 September 2023, para 3.7 A second group, those at medium risk, require further investigation by suppliers before proceeding with an involuntary prepayment meter or smart meter recalibration.2Ofgem, Guidance: PPM (safe and reasonably practicable), 13 September 2023, para 3.8 ‘High risk’ - involuntary prepayment meter cannot be installed
When a supplier considers that it is ‘safe and reasonably practicable’ for you to use a prepayment meter, and seeks to proceed with a prepayment meter, it must refrain from all involuntary installations for the highest-risk customers. These include households:
– where all occupants are aged 75 years and over (if there is no other support in the home);
– with children aged under two;
– which require a continuous supply for health reasons, including dependence on powered medical equipment – eg, heart/lung ventilators, dialysis equipment, stair lift, hoist, carelines, health alarms or refrigerated medication;
– includes someone with chronic, severe or terminal health conditions or those with a medical dependency on a warm home – eg, cancer, organ failure and cardiovascular/respiratory disease (such as emphysema and chronic bronchitis);
– where no one can access, operate and/or top up the meter due to physical or mental incapacity or for technical reasons.
If you fall into this ‘do not install’ category, raise a formal complaint with your supplier. Consideration should be given to guidance published by Ofgem.3Ofgem, Guidance: PPM (safe and reasonably practicable), 13 September 2023, para 3.8 ‘Medium risk’ – further assessment required before involuntary installing a prepayment meter
Before a supplier can proceed with an involuntary prepayment meter, it must refrain from all involuntary installations for medium-risk customers. These fall into the ‘further assessment needed’ category. In making its assessment of ‘safe and reasonably practicable’, the supplier must consider a number of characteristics/circumstances/conditions, alongside the assumption that this group is in financial difficulty and likely to self-disconnect. It should be noted that the personal circumstances and characteristics are not absolute nor exhaustive. They include households:
– with children aged under five years;
– where someone has a serious medical or health condition such as a neurological disease (eg, Parkinson’s, Huntingdon’s or cerebral palsy), respiratory condition, nutritional issue (eg, malnutrition) and mobility limiting condition (eg, osteoporosis, muscular dystrophy or multiple sclerosis);
– where someone has a serious mental or developmental health condition (eg, clinical depression, Alzheimer’s, dementia, Schizophrenia or learning disabilities and difficulties);
– temporary situations – eg, pregnancy or bereavement.4Ofgem, Guidance: PPM (safe and reasonably practicable), 13 September 2023, para 3.7 In these circumstances, suppliers must conduct an ‘ability to pay’ assessment and provide meter care and aftercare support. If you fall into this ‘further assessment needed’ category, raise a formal complaint with your supplier. Consideration should be given to guidance published by Ofgem.5Condition 28.7 SLC; Ofgem, Guidance: PPM (safe and reasonably practicable), 13 September 2023, para 5 Before an involuntary prepayment meter can be installed
Suppliers must follow certain processes before proceeding with an involuntary installation of a prepayment meter. The outstanding charges per fuel must be £200 or more (called the ‘debt trigger’) and be outstanding for three months or more after the date the bill was issued.6Condition 28.4, 28.22 SLC; Ofgem, Guidance: PPM (safe and reasonably practicable), 13 September 2023, para 5.2 Three months preceding any execution of an involuntary prepayment meter, suppliers must also:7Condition 28.7 SLC; Ofgem, Guidance: PPM (safe and reasonably practicable), 13 September 2023, paras 5.3 and 5.7 •make at least 10 attempts to contact you through various communication channels, at various times of day;
•conduct a site welfare visit at least once, with audio or body cameras;
•make translation services and accessible formats – eg, braille;
•retain any assessment documentation and audio or body camera recordings;
•consider the cheapest payment option when calculating your ability to pay and offer you an affordable, sustainable repayment plan;8Condition 28.9(b) SLC; Ofgem, Guidance: PPM (safe and reasonably practicable), 13 September 2023, para 5.6 •provide clear information relating to prepayment meter operation, including process and methods to pay and procedures in the event of disconnection;9Ofgem, Guidance: PPM (safe and reasonably practicable), 13 September 2023, para 8.1 •provide you with easy access to a Supplier Priority Services team.10Ofgem, Guidance: PPM (safe and reasonably practicable), 13 September 2023, para 8.1
Suppliers must accept information from you (or your representative) about your circumstances and your ability to pay,11Condition 27.8 SLC; Ofgem, Guidance: PPM (safe and reasonably practicable), 13 September 2023, para 6.1 including the conditions detailed in SLC 27. If all engagement attempts have been exhausted, including during site welfare visits, suppliers can exercise their discretion to obtain a warrant for a prepayment meter to be installed or for a smart meter to be recalibrated to prepayment mode. In doing so, suppliers must also use their internal ‘welfare officers’. Welfare officers are responsible for overseeing the safeguarding of consumer protection, particularly if they have not been able to establish with certainty your risk level and that it is ‘safe and reasonably practicable’ for a prepayment meter to be installed.12Ofgem, Guidance: PPM (safe and reasonably practicable), 13 September 2023, paras para 5.8 and 5.16 At the point of warrant installation/recalibration, suppliers must place a repayable £30 credit per meter (or equivalent non-disconnection period) as a short-term credit/measure to remove the risk of you disconnecting.13Ofgem, Guidance: PPM (safe and reasonably practicable), 13 September 2023, para 10.1 If it is subsequently determined that the involuntary prepayment meter is unsuitable, the prepayment installation/recalibration should be reversed to non-prepayment mode. If suppliers have been found to breach licence conditions and guidance, they must offer compensation reflective of any detriment suffered.14Ofgem, Guidance: PPM (safe and reasonably practicable), 13 September 2023, para 10.4 Assessment of ‘ability to pay’ for involuntary prepayment meter
As with customers who are in payment difficulty under SLC 27, suppliers must also take into account your ‘ability to pay’ before proceeding to an involuntary prepayment meter. Suppliers must:15Condition 27.8 SLC; Ofgem, Guidance: PPM (safe and reasonably practicable), 13 September 2023, para 6 •not threaten you with involuntary prepayment meter to try to secure a higher payment than is affordable;
•consider the cheapest payment option when calculating your ability to pay and offer you an affordable, sustainable repayment plan;
•consider alternative approaches to recovering the debt such as delaying repayment starting if the affordability assessment establishes that you can only currently afford to pay towards your ongoing energy usage.