Fair By Design responds to Ofgem consumer outcomes consultation on billing

Fair By Design submitted its response to Ofgem's consultation on consumer outcomes as they relate to billing on 19 August 2026¹. The charity said it is concerned about whether now is the right time for the regulator to remove prescriptive rules, and called for a core set of standards that all energy suppliers must follow¹.

Ofgem is moving towards a more outcomes-based approach to regulation, meaning it will be clearer about the outcomes it expects suppliers to achieve while being less prescriptive about how they deliver them¹. The consultation is the first step in Ofgem's phased approach to implementing seven consumer outcomes, the first being that "Consumers receive accurate, timely, accessible and understandable energy bills"¹.

Fair By Design said minimum standards would also be easier to communicate to consumers and advisers, and would help the Ombudsman judge whether a supplier had done what was expected of it¹. It called on Ofgem to work with it and other consumer groups to identify what those minimum standards should be, alongside introducing clear consumer outcomes¹.

The response draws on a session with the charity's lived experience panel, whose members described energy bills as opaque and overly complex, contributing to anxiety, disengagement and low levels of trust¹. Participants said they often looked only at the amount owed, found the terms debit and credit confusing, and reported difficulty understanding bills, particularly people with dyslexia, autism or lower literacy levels¹. Some reported positive experiences of supplier apps¹.

On payment methods, Fair By Design said its work on standard credit shows that even when suppliers are incentivised to act in a way that should lead to good consumer outcomes, this does not always happen¹. Suppliers are obliged under their licence conditions, and would make money, by encouraging consumers to move off standard credit and onto direct debit, it said¹. Ofgem's own research and the charity's own show that less than half of people who pay by standard credit understand that they are paying a premium to do so, and its recent analysis of energy bills found the premium is not always clearly explained, meaning consumers cannot make an informed choice about their payment method¹.

Fair By Design also welcomed Ofgem's commitment to be more proactive and to work closely with suppliers, saying the three-year investigation into British Gas forced installation of pre-payment meters "represents the worst of all worlds" because harm was not prevented at an early stage and the process to address it was protracted¹.

Why it matters for households

The consultation concerns how energy suppliers' billing practices are regulated, so any change to the rules affects how bills are presented and explained to households across Great Britain¹. Fair By Design's central argument is that an outcomes-based approach, on its own, may not deliver clearer bills: it points to standard credit, where a premium applies to paying by bill rather than direct debit, and says fewer than half of those paying it understand they are paying a premium at all¹. If minimum standards are not set, the charity argues, consumers and advisers have less certainty about what they can expect from a supplier¹.

The billing outcome under consultation covers accuracy, timeliness, accessibility and understandability of bills¹. The panel feedback cited by Fair By Design covers comprehension of debit and credit, standing charges, exit fees, credit balances held by suppliers, and how to challenge a bill¹. It also covers customer service, the Priority Services Register and switching, including concerns that comparison tools rely on estimates rather than actual consumption¹.

What happens next

Ofgem's consultation on consumer outcomes as they relate to billing is described as the first step in a phased approach to implementing seven consumer outcomes¹. No date has been reported for the outcome of this consultation or for the introduction of the remaining outcomes. Fair By Design has published its full response and said it is calling on Ofgem to work with it and other consumer groups on identifying minimum standards¹.