The Customer Protection Code of Practice sets out the minimum standards that all Retailers must comply with in their dealings with Non-Household Customers. It also sets out the minimum standards of behaviour that we expect from Retailers, and compliance is a requirement of Retailers’ licences which is ultimately enforceable by Ofwat.
The amended change Proposal is intended to achieve the following policy aims:
- That those customers adversely affected by Covid-19 are provided with appropriate levels of support and protection.
- Customers who are able to pay should be incentivised to pay in a timely manner.
- Retailers should take the necessary steps to differentiate between those customers who genuinely need support and those who should be expected to pay.
On 28 October A Customer Protection Code Change Proposal was raised by the Consumer Council for Water. This proposed amendment to the CPCoP is intended to deliver greater protections for those business customers that have been required to close under relevant Government Covid-19 legislation (“the Change Proposal”).
On 12 November 2020 Ofwat and CCW published a joint statement noting that CCW had proposed an amendment to the CPCoP and that Ofwat would be seeking further information from Retailers to inform its thinking on this proposed amendment before issuing a consultation.
After considering the information submitted by Retailers, we agree with CCW that that there is scope to further strengthen customer protections within the CPCoP to ensure that those business customers adversely affected by Covid-19 are provided with appropriate levels of support. We consider, however, that the evidence suggests that changes to the CPCoP should be specifically focussed on:
- Clarifying the expectations of Retailers in terms of promoting and signing up customers to Covid-19 repayment schemes where appropriate;
- Ensuring that Retailers take reasonable steps to maintain contact with customers on Covid-19 repayment schemes to understand their circumstances and tailor their plans before any kind of debt collection action is pursued;
- Ensuring that Retailers are able to demonstrate that they have taken reasonable steps to engage with their customers before taking any debt recovery action; and
- Ensuring Retailers publish on a monthly basis data relating to the number of Non-Household customers are on repayment plans (Covid-19 and any other) and the level of enforcement action being carried out.
We are therefore proposing to amend the Change Proposal to strengthen protections for all customers adversely affected by Covid-19, including those that have been forced to close. We are seeking views on our proposed decision by 5pm on 9 December 2020.
Responses to the consultation should be submitted to [email protected], with the subject ‘CPCoP consultation – CP0009’.