Smart metering policy framework post 2025
Summary
The government requires energy suppliers to take all reasonable steps to complete domestic smart meter installation by 2030, replacing the current targets framework which expires end-2025. Suppliers must resolve smart meters operating in traditional mode within 90 days and pre-emptively replace assets before 2G/3G shutdown by 2033. Annual deployment plans with binding milestones become mandatory from January 2027.
Why it matters
This is redistributive policy — smart meters reduce operational costs for suppliers and enable time-of-use pricing, but installation costs flow through to all consumers via price controls. The framework treats symptoms of expensive energy (helping consumers manage usage) rather than addressing supply constraints or market structure.
Key facts
- •90-day maximum to restore smart meters operating in traditional mode
- •100% domestic penetration target by 31 December 2030
- •Binding deployment plan milestones from 1 January 2027
- •Communications hub replacement required before 2G/3G shutdown end-2033
- •Suppliers below 20,000 domestic meter points exempted from deployment plans
Timeline
Areas affected
Related programmes
Memo10,000 words
We’re consulting on proposals to set the policy framework for energy suppliers to deliver service improvements by ensuring smart meters operate as they should, and to continue installing smart meters after 31 December 2025, when the existing annual installation targets come to an end. The consultation seeks views on proposed obligations to: * improve smart meter operations * complete the domestic rollout by the end of 2030 * submit annual deployment plans Read our [consultation privacy notice](https://www.gov.uk/government/publications/desnz-consultations-privacy-notice/privacy-notice-relating-to-consultation-responses-received-by-desnz). --- ## General information ### Why we are consulting The government is committed to improving the consumer experience of smart meters and to ensuring that all consumers can benefit from smart meters as soon as possible, to support the Clean Power 2030 Mission. The existing Smart Meter Targets Framework, set out in the gas and electricity supply licence conditions, was designed to ensure timely delivery of the smart meter rollout by setting energy suppliers minimum annual smart meter installation targets. By the end of 2025, the existing targets require suppliers to have delivered smart meters to 74.5% of relevant domestic premises in Great Britain, at which point the existing Targets Framework comes to an end. In addition, the Operational Licence Condition, set out in the gas and electricity supply licence conditions, has been the main regulatory tool requiring suppliers to ensure that installed smart meters remain operational. However, there were 3.5m smart meters operating in traditional mode across Great Britain at the end of March 2025, which represents 9% of all smart meters. We are consulting on proposals for Licence Condition amendments that include strengthening the smart metering Operational Licence Condition to deliver service improvements, a 2030 obligation on energy suppliers to complete the domestic rollout, and a requirement on energy suppliers to submit annual deployment plans. ### Consultation details #### Issued: 8 August 2025 #### Respond by: 11:59pm on 3 October 2025 #### Enquiries by email to: smartmetering@energysecurity.gov.uk #### Consultation reference: Smart metering policy framework post 2025 #### Audiences: This consultation is expected to be of most interest to consumer groups, energy suppliers and installers, as well as other supply chain stakeholders, such as smart meter and In-Home Display manufacturers, Meter Asset Providers, Distribution Network Operators and anyone affected by or interested in the performance of smart meters. We have engaged with Ofgem in developing this consultation. This consultation is not limited to these stakeholders; any organisation or individual is welcome to respond. #### Territorial extent: This consultation applies to the gas and electricity markets in Great Britain. Responsibility for energy markets in Northern Ireland lies with the Northern Ireland Executive’s Department for the Economy. ### How to respond When responding, please state whether you are responding as an individual or representing the views of an organisation. If you are responding on behalf of an organisation, please make it clear who the organisation represents and, where applicable, how you assembled the views of members. Your response will be most useful if it is framed in direct response to the questions posed, though further comments and evidence are also welcome. When considering responses to this consultation, the government will give greater weight to responses that are based on argument and evidence, rather than simple expressions of support or opposition. We are inviting responses to this consultation via the online e-consultation platform, Citizen Space. We strongly encourage responses to be submitted online using the online e-consultation platform, Citizen Space, where possible, as this supports timely and efficient analysis of responses. [Respond online](https://energygovuk.citizenspace.com/energy-security/smart-meter-policy-framework-post-2025) Or, in the event that you are unable to do so: Email to: smartmetering@energysecurity.gov.uk ### Confidentiality and data protection Information you provide in response to this consultation, including personal information, may be disclosed in accordance with UK legislation (the Freedom of Information Act 2000, the Data Protection Act 2018 and the Environmental Information Regulations 2004). If you want the information that you provide to be treated as confidential please tell us, but be aware that we cannot guarantee confidentiality in all circumstances. An automatic confidentiality disclaimer generated by your IT system will not be regarded by us as a confidentiality request. We will process your personal data in accordance with all applicable data protection laws. [See our privacy policy.](https://www.gov.uk/government/publications/desnz-consultations-privacy-notice/privacy-notice-relating-to-consultation-responses-received-by-desnz) We will summarise all responses and publish this summary on [GOV.UK](https://www.gov.uk/search/policy-papers-and-consultations?parent=department-for-energy-security-and-net-zero&content_store_document_type%5B%5D=closed_consultations&content_store_document_type%5B%5D=closed_calls_for_evidence&organisations%5B%5D=department-for-energy-security-and-net-zero&order=updated-newest). The summary will include a list of names or organisations that responded, but not people’s personal names, addresses or other contact details. ### Quality assurance This consultation has been carried out in accordance with the [government’s consultation principles](https://www.gov.uk/government/publications/consultation-principles-guidance). If you have any complaints about the way this consultation has been conducted, please email: bru@energysecurity.gov.uk. ## Interpretation In this document: ‘communications hub’: a communications hub is installed in homes and businesses to connect the DCC’s secure network to smart gas and electricity meters and allow smart meters and in-home displays to connect to each other. The communications hub typically sits next to or on top of the electricity smart meter. ‘customer-driven churn’: refers to consumers switching between energy suppliers as a result of the consumer’s active choice. ‘Data Communications Company (DCC)’: is the holder of the Smart Meter Communication Licences (currently Smart DCC Limited) and is regulated by Ofgem. It is responsible for linking smart meters in homes and small businesses with energy suppliers, network operators and energy service companies, via a centralised data and communications network. DCC has an outsourced service model, with a number of Fundamental Service Providers, which include the Communications Service Providers (CSPs), who help to build the Smart Metering data and communications infrastructure. The CSPs manage and maintain the secure communication networks that remotely relays messages to and from smart meters within a set region. They include: Arqiva (Communications Services Provider North); O2 UK (a subsidiary of VMO2) (Communications Services Provider South and Central); and Vodafone (national 4G provider). ‘DESNZ’ or ‘the department’: refers to the Department for Energy Security and Net Zero, that has published the consultation on behalf of the UK government. ‘domestic’: refers to premises at which a supplier of gas or electricity (or both) is taken wholly or mainly for a domestic purpose (see Gas Supply Licence and Electricity Supply Licence standard condition 6). ‘4G in the North’: refers to the planned extension of the fourth generation (4G) communication network into a defined northern region negotiated by Data Communications Company (DCC). ‘Guaranteed Standards of Performance’: refers to regulations that require energy suppliers to meet specific service standards, such as fulfilling requests for appointments, and provide compensation to consumers if they fail to do so. ‘Home Area Network (HAN)’: refers to a wireless network used within homes to connect smart metering system devices in the home which are communications hub, smart meters (electric and gas), In-Home Displays (IHDs) and Consumer Access Devices (CADs). ‘non-domestic’: Refers to designated premises in scope of the smart meter rollout. These are smaller sites with electricity meters in profile classes 1-4 or with gas consumption below 732 MWh per year. ‘Ofgem’: stands for the Office of Gas and Electricity Markets. It is the energy regulator for Great Britain and its role is to protect the interests of energy consumers. ‘Smart Energy Code (SEC)’: refers to a multi-party agreement which defines the rights and obligations of DCC, energy suppliers, network operators and other relevant parties involved in the end-to-end management of smart metering in Great Britain. ‘Smart Energy GB (SEGB)’: is the organisation responsible for the delivery of consumer engagement in relation to smart metering under Electricity and Gas Supplier Licence Conditions 45 and 39 respectively. ‘Smart meter operating in traditional mode’: refers to a smart meter where the respective energy supplier cannot obtain remote meter readings as expected, therefore the meter needs to be read manually or where the consumer cannot access their relevant energy information across the HAN including updated tariff information on a relevant consumer device. ‘SMETS1’ (Smart Metering Equipment Technical Specifications - first generation): refers to the first generation of the technical specifications for smart metering equipment qualifying to meet licence rollout targets. ‘SMETS2’ (Smart Metering Equipment Technical Specifications - second generation): refers to the second generation of the technical specifications for smart metering equipment qualifying to meet licence rollout targets. ‘the government’: refers to the UK government. ‘the Programme’: refers to the Smart Metering Implementation Programme which includes the department’s Smart Metering Team and the wider group of partners and stakeholders responsible for delivering the rollout. ‘the Targets Framework’: refers to the smart meter installation obligations which have been implemented and took effect from 1 January 2022. ‘Smart tariffs’: refers to energy pricing plans that vary the cost of electricity based on the time of day ‘Virtual WAN (VWAN)’: refers to an arrangement where, providing the consumer consents to the use of their broadband, smart meters can connect to the DCC via the internet. DESNZ and DCC have been working together to implement this arrangement for consumers that live in premises that have no WAN coverage. ‘we’: refers to the UK government. ‘Wide Area Network (WAN)’: the WAN is used for communication between smart meters and the DCC via a communications hub, enabling (amongst other things) suppliers to receive meter readings remotely. ## Executive summary Smart meters are an essential upgrade to our national energy infrastructure. They bring significant benefits to consumers and underpin a modern, clean and flexible energy system. Smart meters help consumers take control of their energy use, cut their energy bills, and unlock the benefits of the transition to clean power. By supporting grid resilience and flexibility, they also play a vital part in the government’s commitment to deliver Clean Power 2030. The government is committed to ensuring that all consumers can benefit from smart meters as soon as possible. To support the Clean Power Mission and ensure no one is left behind, we are consulting on a framework to enable the vast majority of consumers to have smart meters by the end of 2030. To meet this ambition, the government previously introduced a four-year ‘Targets Framework’ from 2022 to end 2025, under which energy suppliers have been set annual smart meter installation targets, which collectively required energy suppliers to deliver smart meter coverage to 74.5% of the domestic sector by end 2025. Consumers are at the heart of the smart meter rollout. However, we know that not all consumers have received the quality of service that we expect across the country.[[footnote 1]](#fn:1) Improving the consumer experience of smart metering is a priority. We are working at pace alongside industry partners to improve smart meter services across all areas of Great Britain. The proposals set out in this consultation aim to deliver a step-change in consumer experience, provide certainty to industry, and drive the completion of the rollout to support the transition to Clean Power. That means making sure that smart meters work as they should, transitioning the smart meter network to use the 4G communications network before the 2G and 3G communications networks are switched off by 2033, and ensuring the vast majority of consumers benefit from a smart meter by the end of 2030. The principles guiding our proposals are: * delivering a high quality and improved consumer experience * providing certainty to enable investment and underpin the transition to Clean Power 2030 * providing delivery flexibility to the sector, whilst ensuring progress and accountability In this consultation, we are seeking views on the following requirements for energy suppliers to take all reasonable steps to: * ensure smart meters in traditional mode are back working in smart mode for consumers as soon as possible and no later than 90 days from the date energy suppliers are first aware * pre-emptively replace smart metering assets so that they continue to communicate when they will otherwise stop as a result of Wide Area Network (WAN) services ending, such as the switch-off of 2G and 3G mobile services by end of 2033 * complete the smart meter rollout by installing smart meters in remaining domestic premises by the end of 2030 We are also consulting on an underpinning requirement for energy suppliers to submit annual deployment plans to Ofgem, outlining supplier domestic activities to meet their installation, operational and replacement obligations. We are gathering evidence on In-Home Displays (IHDs) and other feedback tools, to better understand consumer and industry requirements for accessing real-time energy consumption data. This will help us consider the case for any potential further improvements to the consumer experience of smart metering in relation to consumption data feedback. Proposals with respect to resolving smart meters operating in traditional mode and clarifying obligations to pre-emptively replace smart metering assets apply to both domestic and non-domestic energy suppliers. Proposals to drive new smart meter installations in the non-domestic sector will follow in a separate consultation. We look forward to engaging with stakeholders and to work together to deliver our shared objective of delivering a universal smart metering service across Great Britain that works for everyone by the end of 2030. ## Introduction ### Smart metering rollout to date Smart meters are upgrading Great Britain’s energy system, bringing significant benefits to consumers, and playing a vital role in building a flexible and decarbonised power system. Consumers are at the heart of the smart meter rollout, as they bring an end to manual meter readings and estimated bills, whilst providing households with near-real time information which they can use to save energy and cut their bills. There is robust evidence from the rollout to date that consumers with smart meters are achieving sustained savings using their smart meters and In-Home Displays of 3% for electricity and 2.2% for gas credit.[[footnote 2]](#fn:2) This is particularly beneficial at a time of high global energy prices. In addition, the wider system savings enabled by smart meters flow back to help reduce all consumer bills. Prepayment customers see particular benefits from smart meters, which enable consumers to top-up remotely as well as track their balance easily, reducing the risk that they unknowingly run out of credit. Smart prepayment meters also make it easier to access government cost of living support. For example, the £400 Energy Bills Support Scheme discount was applied automatically for those on smart prepay between October 2022 and March 2023, with no need to redeem a voucher.[[footnote 3]](#fn:3) Smart meters help consumers unlock the benefits of clean power and clean technology like heat pumps, batteries and solar panels. Smart meters allow consumers to access the Demand Flexibility Service, which was launched by the National Grid Electricity System Operator (ESO) in winter 2022 and now runs year-round, and which rewards consumers for reducing their energy usage during Demand Flexibility Service events.[[footnote 4]](#fn:4) Smart meters enable consumers to access optional smart tariffs, which reward consumers for using electricity flexibly, and can be particularly beneficial for consumers using clean technology like heat pumps, batteries, solar panels and electric vehicles, for example saving electric vehicle customers up to £900 per year.[[footnote 5]](#fn:5) Smart meters also provide significant benefits for gas consumers. Mains gas is still prevalent in Great Britain, serving around 80% of premises and supplying a substantial portion of cooking and space heating energy needs. Gas forms a substantial part of both consumer savings and carbon reductions, and many of the benefits from smart meters – both for suppliers and for consumers – are realised when both fuels are served by smart meters, such as remote top-up for prepayment customers and more accurate billing without manual meter readings. The government is committed to decarbonising all sectors of the UK economy to accelerate the transition to net zero. A low carbon future will deliver benefits to the planet, the economy and energy security, and will significantly reduce household bills. Smart meters underpin the cost-effective delivery of the government’s commitment to achieve Clean Power 2030 and net zero greenhouse gas emissions by 2050. They enable a flexible modernised energy system, that changes the way we use energy and provides significant benefits to consumers and suppliers. A more flexible energy system will allow us to scale up the use of renewables and reduce reliance on imported fossil fuels, giving us greater control of our energy security. The data from smart meters is helping Distribution Network Operators (DNOs) to more actively plan and manage their networks, as well as respond to outages more quickly. The smart meter rollout has delivered significant benefits to date. As of the end of March 2025, 67% of all meters are now smart or advanced meters, and 91% of all smart meters were operating in smart mode.[[footnote 6]](#fn:6) By the end of 2025, the existing targets require suppliers to have delivered smart meters to 74.5% of relevant domestic premises in Great Britain, at which point the existing Targets Framework comes to an end. Smart meters installed to the end of 2024 will deliver a total Net Present Value (NPV) of £2.2 billion over the appraisal period, with each new installation from this point expected to deliver additional net benefits.[[footnote 7]](#fn:7) However, we know that not all consumers have received the quality of service that we expect across the country. Too many smart meters have not been operating in smart mode (data collated by the department show that 9% of smart meters were not sending automatic readings as at the end of March 2025). This means that some consumers are not receiving the full benefits of smart meters and we recognise that this can undermine trust in smart meters. Industry is responsible for installing smart meters and for ensuring they are working correctly, with suppliers responsible for smart metering assets, and the Data Communications Company (DCC) responsible for the smart metering communication network and service. ### Principles for the future framework As we look ahead to the next phase of the smart meter rollout, we want to deliver a step-change in consumer experience, ensure a smooth transition to 4G communications, and give industry certainty to enable appropriate investment to continue to roll out smart meters at scale. This will ensure that, by the end of 2030, nearly all homes and smaller non-domestic sites have working smart meters, to support the Clean Power 2030 Mission and to give consumers the positive experience they rightly expect and deserve. #### 1. Delivering a high-quality, improved consumer experience We want to deliver a high-quality, improved consumer experience of smart meters. This will ensure households and smaller non-domestic sites receive the full benefits of smart metering and help give those who still have traditional meters the confidence to agree to a smart meter installation. The first proposal, for suppliers to resolve smart meters operating in traditional mode within 90 days, aims to ensure that smart communications and the services they support are restored in a more consistently timely manner to consumers whose smart meters fall into traditional mode. The second proposal, for suppliers to pre-emptively replace smart metering assets before relevant communication services terminate, clarifies that communications hubs (and any other associated smart metering assets) should be pre-emptively replaced by energy suppliers under the Operational Licence Condition to ensure smart services are maintained when the DCC’s relevant Wide Area Network service contracts come to an end and are replaced by different services. This includes national SMETS1 services and 2G/3G communications services which most smart meter communications hubs in the Central and South regions currently use. All communications hubs using 2G/3G communications (and associated metering devices as relevant) will need to be replaced with devices that support 4G communication services by the end of 2033 in order to maintain smart connectivity. The above 2 proposals apply to both the domestic and the non-domestic sectors. In addition to the core proposals in this consultation, set out in Sections 1, 2 and 3, we set out our vision more broadly on priority actions needed to deliver an improved customer experience. This includes: * the development of Guaranteed Standards of Performance for smart metering by Ofgem * a continued role for Smart Energy GB in delivering a national consumer engagement campaign for smart metering * setting out government’s intention to accelerate the rollout in the Private Rented Sector, where smart meter coverage is behind average * working with Ofgem to ensure delivery of smart prepayment remains on track, including through considering the role of deployment plans * delivering a positive non-domestic consumer experience * we are also gathering evidence on IHDs and other feedback tools, to better understand consumer and industry requirements for accessing real-time energy consumption data - this will help us consider the case for further improvements to the consumer experience of smart metering #### 2. Providing certainty to enable investment and underpin the transition to Clean Power 2030 With the Targets Framework coming to an end this year, this consultation sets out a proposal for industry to complete the rollout by the end of 2030. This will give industry certainty and enable appropriate investment to continue to deliver the programme at scale. To support the Clean Power Mission and ensure no one is left behind, we aim to enable the vast majority of consumers to have smart meters by end of 2030. This proposal applies to the domestic sector. A consultation on proposals for the future rollout of smart meters in the non-domestic sector will follow separately. #### 3. Providing flexibility to the sector, whilst ensuring progress and accountability We recognise that, in the period beyond 2025, there is a wider range of smart-metering related activities energy suppliers need to deliver, which will impact suppliers differently according to their varying metering and customer portfolios. We also recognise that, although we consider there is sufficient consumer demand for energy suppliers to meet and go beyond their current installation targets, the remaining pool of consumers yet to take up a smart meter will increasingly be made up of consumers who may be less engaged and harder-to-reach as the rollout progresses. At this stage, the government is proposing a regulatory framework that provides energy suppliers with a degree of flexibility to optimise their delivery programmes whilst meeting regulatory requirements. We expect suppliers to continue to proactively engage their consumers to generate demand for smart meters, and to increase their installer workforce where necessary to meet their requirements, including in regions that are currently underserved. We are proposing that energy suppliers will be required to submit annual deployment plans to Ofgem to show how they will meet their obligations to install smart meters and ensure they are operating correctly, including pre-emptively replacing relevant technology ahead of service end-dates, to meet the needs of their customers. It is proposed that the annual milestones for new installations and pre-emptive replacements in these plans are binding from 2027. We expect energy suppliers to take action in 2026 to ensure they meet their obligations by increasing the numbers of smart meters operating in smart mode and improving consumer experience, continuing new installations, and ramping up pre-emptive replacements, as well as by putting plans in place to ensure they will have sufficient workforces to deliver against their requirements to 2030 and beyond. The deployment plans will apply to the domestic sector. We will, however, continue to review progress by energy suppliers and are prepared to bring in less flexible measures if we consider that insufficient progress is being made towards completion of the rollout by the end of 2030 and improved smart meter operations. ### Related measures Government, working with key delivery partners, is overseeing a number of steps over and above those outlined in this consultation, to improve the availability of smart metering, improve the consumer experience, and support consumer demand. In addition to the measures described here, we will continue to consider other ways in which government policy can support the rollout, including further potential measures to support consumer experience, demand and conversion. #### Improving the availability and reliability of smart metering services 4G in the CSP-North: The Data Communications Company (DCC) has agreed the extension of 4G communications into the CSP-North. This enables suppliers to use either the 4G mobile network or the Long-Range Radio network in the CSP-North, in support of improved first-time installation success rates. DCC SMETS1 service contract extensions: The DCC has extended its contracts with core service providers to enable SMETS1 service provision to 2033. This will allow energy suppliers to maximise the asset life of installed equipment and reduce early replacements. Virtual WAN: In 2026 the DCC will launch a Virtual WAN service so that, with consumer consent, broadband can be used to connect homes without WAN coverage to the national communications network for smart metering. This means that all remaining consumers who do not have a WAN service, but have broadband, will be eligible for smart meters. 4G communications hub only exchange site visits arrangements: Government will confirm the conclusions to the February 2024 consultation on the DCC charging mechanism and associated regulatory changes on the SEC website in due course. Ofgem and government will also jointly be consulting on the centralised price calculation methodology for 4G Communications Hub only exchange site visits via Ofgem’s website. #### Consumer protections, experience and rights Guide to consumers’ rights and expectations: Government has published new guidance for consumers, setting out what they should expect from their smart metering experience. Guaranteed Standards of Performance: Ofgem is consulting on Guaranteed Standards of Performance for smart metering to support faster appointment fulfilment, smoother installations, faster support and resolution of post-installation issues, and ensure meters operate in smart mode, which if not met will result in automatic compensation for consumers. Consumer engagement: The national smart metering campaign, run by not-for-profit organisation Smart Energy GB, has played a vital role in driving the uptake of smart meters to date. There will continue to be a need for a large-scale national consumer engagement campaign led by Smart Energy GB to support rollout activity. Tenants’ rights: We are exploring ways to strengthen the rights of domestic tenants in getting smart meters. In-Home Displays: We are also using this consultation to gather evidence on IHDs and other feedback tools, to better understand consumer and industry requirements for accessing real-time energy consumption data. This will help us consider the case for further improvements to the consumer experience of smart metering. Smart metering installation experience: We are also publishing a call for evidence to seek industry’s views on how to enhance the consumer installation journey towards Clean Power 2030, including by looking at the potential to drive efficiencies or integration in both smart meter and low carbon technology (LCT) installations. #### Further interventions to support consumer demand for smart meters Flexibility and low carbon technology: The Clean Power 2030 Mission is expected to drive higher demand for smart metering benefits, such as smart tariffs, particularly for users of low carbon technology, as well as leveraging benefits provided by the Market-wide Half Hourly Settlement.[[footnote 8]](#fn:8) We note that, in line with the government’s Warm Homes Plan, we expect low carbon technology use to rapidly increase across Great Britain in this period. We would encourage suppliers to make full use of these opportunities by deploying smart-contingent tariffs and related incentives. Energy Company Obligation (ECO) / Great British Insulation Scheme (GBIS): Advice on the benefits of smart meters is provided to recipients of retrofit measures under ECO4 and GBIS, and voluntary pledges to install a smart meter are being implemented following the mid-scheme consultation.[[footnote 9]](#fn:9) We have also committed to continue to explore ways to integrate smart metering further within any successor ECO scheme. Other energy efficiency funds: Similar to ECO4 and GBIS, we ensured advice on the benefits of smart meters was provided to recipients of retrofit measures under the Home Upgrade Grant, the Local Authority Delivery scheme, and the Social Housing Decarbonisation Fund. Future Homes Standard: Government has consulted on enhanced guidance so that new homes in England are built smart meter ready from the outset and will publish its response to the consultation in Autumn 2025.[[footnote 10]](#fn:10) Energy Performance Certificates: We have met our commitment to include a check for the presence of a smart meter when a full or reduced assessment of a home’s energy and environmental performance takes place, with advice on how to get a smart meter reflected on the Energy Performance Certificates (EPCs) of properties where one is not present.[[footnote 11]](#fn:11) Further to this, we are working towards reforming EPCs, including considering how and where to best reflect smart capability within future metrics.[[footnote 12]](#fn:12) Electric vehicles: We are working with stakeholders to raise awareness that smart meters enable smart tariffs which could help reduce energy bills for electric vehicle users, such as recently updated advice on the Energy Savings Trust website.[[footnote 13]](#fn:13) Heat pumps: We are working to ensure that relevant information is provided to householders installing a heat pump, with messaging now provided to consumers receiving the Boiler Upgrade Scheme support. Smart Export Guarantee: We have moved away from deemed export payments under the Feed In Tariffs scheme; a smart meter or an export meter capable of half-hourly readings is required under the replacement Smart Export Guarantee scheme. ## Delivering a high-quality, improved consumer experience The government is committed to improving the consumer experience of smart metering and is working at pace alongside industry partners to share best practice and improve smart meter connectivity across all areas of Great Britain. As of the end of March 2025, 91% of all smart meters were operating in smart mode, with the remainder operating in traditional mode;[[footnote 14]](#fn:14) a 1.3% percentage point improvement between September 2024 and March 2025.[[footnote 15]](#fn:15) Correspondingly, Ofgem customer service data from January 2025 shows that satisfaction with smart meters rose from 72% in July 2024 to 76% in January 2025, with dissatisfaction also reducing from 10% to 7%.[[footnote 16]](#fn:16) We want to see this positive progress continue, and at a faster pace. The proposals set out in this consultation will strengthen consumer experience by driving installations, unlocking the benefits of smart metering for consumers who have not yet taken up the offer, and by placing clear requirements on energy suppliers to take more urgent action on maintenance, repair and replacement activity that will keep consumers benefitting from smart meters long into the future. ### Guide to consumers’ rights and expectations Alongside strengthening requirements on energy suppliers, the government recognises the importance of consumers understanding what to expect from their smart metering experience, and how to resolve issues when they arise. In parallel to this consultation, we have launched new guidance for consumers which sets out what all consumers should expect from their end-to-end smart metering experience. This guidance also provides information on how consumers can get the most from their smart meters and what to do if things go wrong. The new guidance will inform a Consumer Charter for smart metering when other rights and protections referred to in this consultation have come into effect. ### Guaranteed Standards of Performance for smart metering The ambitions set out in this consultation are supported by proposals in development by Ofgem to introduce Guaranteed Standards of Performance for smart metering. These proposals were published by Ofgem in an initial policy consultation which ran from 28 March to 9 May 2025, and their statutory consultation was published on 8 August 2025 to close on 12 September 2025. The Guaranteed Standards of Performance proposals will work to address key issues in consumers’ journey with smart metering, alongside the proposals detailed in this consultation. The first of the proposed Guaranteed Standards of Performance would support consumers who would like to take up the offer of a smart meter but have not yet done so, by ensuring suppliers compensate consumers who are not offered an installation appointment date within 6 weeks of the request being made. This will support the proposed 2030 obligation for suppliers to take all reasonable steps to complete the domestic smart meter rollout by end of 2030. In addition, Ofgem propose a second Guaranteed Standard of Performance, which would require compensation for those consumers who booked an appointment, but where their energy supplier’s representative did not possess the necessary skills or resources to fulfil the smart meter installation. These new standards seek to minimise consumer detriment during the smart meter booking and installation experience, which would also support the proposed 2030 obligation. Where a consumer has a smart meter operating in traditional mode for a significant length of time, Ofgem propose that some of these consumers would also have a right to compensation via a new Guaranteed Standard of Performance. Separately, these consumers would also be protected by a Guaranteed Standard of Performance which would require energy suppliers to respond to and support their consumers within 5 days where the consumer contacts their energy supplier to report that their smart meter is not working as intended. Both standards will work to enhance consumers’ experience with the smart metering rollout and thus improve the rollout’s reputation and the likelihood of remaining consumers without a smart meter taking up the offer. Proposals on Guaranteed Standards of Performance are subject to consultation by Ofgem and are not in the scope of this consultation. However, Ofgem and DESNZ have worked together to ensure that the proposals in this consultation are compatible with these proposed additional consumer protections and will continue to do so as policy is refined. It is government’s view that a regime comprising both Guaranteed Standards of Performance and the measures proposed in this consultation will provide an appropriately strong incentive for energy suppliers to improve the consumer experience of smart metering, both in terms of driving coverage through first-time installations and ensuring that suppliers take prompt action to maintain the operation of smart meters, as well as compensating consumers where certain expectations are not met. We consider it is right both for consumers to be able to access redress when issues occur, and for energy suppliers to be held to account through clear and robust obligations set out in Licence Conditions. ### A continued role for consumer engagement campaigns The national smart metering campaign, run by not-for-profit organisation Smart Energy GB, has played a vital role in driving uptake to date, with industry-verified statistical analysis showing that 50% of smart metering installations are attributable to Smart Energy GB’s activities.[[footnote 17]](#fn:17) The supplier-funded campaign’s multi-channel and tailored engagement approach has ensured that consumers benefit from clear, consistent messaging on the benefits of smart metering, supplemented by more targeted communications. Delivering a national campaign through Smart Energy GB has also ensured value for money and economies of scale for energy suppliers, who benefit from the reach of the national campaign and can build on its messaging in their own direct communications to consumers. The next phase of the smart metering rollout will focus on delivering installations for the remaining third of consumers, including some of the harder-to-reach consumers, alongside significant supplier activity to replace SMETS1 meters and 2G and 3G communications hubs. Compelling national consumer engagement and clear calls to action for consumers will remain critical, and we envisage a strong continued role for Smart Energy GB in delivering this. After the end of the current Targets Framework (end of 2025), we envisage that Smart Energy GB will need to: * continue to drive consumer demand for first time installations in both domestic and microbusiness properties * provide support for harder-to-reach customer segments and specialist audiences and assist consumers on low incomes and with prepayment meters to realise the benefits of smart metering * drive consumer acceptance of the transition to 4G communications and to encourage affected consumers to book an appointment to switch out their smart meter or communications hub * support consumer understanding of the actions they can take to resolve meters not operating in smart mode and drive engagement with energy suppliers to address these issues * support consumer awareness and action so that consumers respond promptly and positively to supplier engagement for any other scheduled maintenance activity * leverage emerging policy across DESNZ to improve smart meter uptake and benefits realisation, driving consumer awareness of and engagement with wider opportunities such as smart tariffs and the key role smart metering plays as part of the journey to net zero Furthermore, there remains an essential role for Smart Energy GB to evidence the level and key drivers of consumer demand in the domestic and non-domestic markets through regular tracker surveys and supplementary research. We consider that Smart Energy GB’s objectives remain relevant to delivering the completion of the rollout by 2030, and that Smart Energy GB can continue to carry out these activities without updating Supplier Licence Conditions. ### Progressing the rollout in the Private Rented Sector The government wants all consumers to benefit from smart metering, no matter their living circumstances. The domestic Private Rented Sector continues to be a more challenging area for the smart metering rollout. The proportion of privately rented properties with smart meters has consistently lagged behind other types of housing tenures. Data from Ofgem’s Energy Consumer Satisfaction Survey (January 2025) found that 62% of private renters owned a smart meter, compared with 70% for social renters and 69% for homeowners.[[footnote 18]](#fn:18) Additionally, data from the English Housing Survey 2023-24 showed 47% of privately renting households reported having an electricity smart meter, compared to 59% for owner occupiers and 53% for social renters at the time.[[footnote 19]](#fn:19) This is a statistically significant difference that has been consistent over time. While the reforms proposed in this consultation will support consumers across Great Britain in obtaining, and getting the most from, their smart meter, the government acknowledges that further intervention is needed to support consumers who rent their homes to take up the offer of a smart meter. There are several reasons why smart meter uptake is lower in the Private Rented Sector, including operational and technological constraints, as well as renter-specific factors such as tenants who move home frequently. However, uncertainty amongst some landlords and tenants over a renter’s right to request a smart meter remains a key barrier.[[footnote 20]](#fn:20) Tenants who pay the energy bills have the ability to request a smart meter from their energy supplier. However, some tenancy agreements contain provisions which restrict the ability of tenants to unilaterally arrange the installation of smart meters. Ofgem’s guidance for the rental sector states: “If you pay for the gas or electricity in your rented property, you can choose to have a smart meter. If your tenancy agreement says you need your landlord’s permission to alter metering at your property, they should not unreasonably prevent it.”[[footnote 21]](#fn:21) While it may only be a minority of landlords who include restrictive clauses in tenancy agreements, the fact that some do creates general uncertainty for tenants who, for whatever reason, may be reluctant to enter into dialogue with their landlord. This can lead to renters who are interested in getting smart meters not taking action to book an installation. The government wants to explore ways to strengthen the rights of domestic tenants in getting a smart meter, while also being cognisant of the reasons why a minority of landlords may seek to refuse smart meter installations in properties they own. We are currently undertaking sector-specific stakeholder engagement with consumer organisations, energy suppliers and organisations representing landlords and renters across both the private and social rental sectors to refine policy proposals and identify the most appropriate implementation route. ### Delivering the benefits of smart prepayment Smart meters operating in prepayment mode offer significant benefits to consumers – enabling top ups online, by app or by phone, as well as allowing consumers to track their balance easily. Smart meters also allow suppliers to better monitor and respond to consumers at risk of self-disconnection, and provide support when they do self-disconnect, through remote configuration of emergency and friendly hours credit. As of the end of December 2024, 12% of domestic smart meters were in prepayment mode (PPM), which is broadly in line with traditional prepayment meters in the domestic market (two-thirds of PPM meters are now smart meters).[[footnote 22]](#fn:22) Government will continue to closely monitor the deployment of smart meters for prepayment customers to ensure consumers using traditional prepayment meters are not left behind in the transition, recognising that these consumers often stand to gain the most from their smart meters. We note that energy suppliers already have strong commercial incentives to install smart meters for prepayment customers, given the operational cost savings and improved customer service this allows. Alongside this, we recognise the vital role that relevant, tailored consumer engagement continues to play in communicating the benefits of smart metering to consumers who prepay for their energy. We continue to advocate for energy suppliers, Smart Energy GB and consumer groups to provide inclusive, tailored messaging for consumers using traditional prepayment to encourage them to take up the smart offer and to build trust, alongside a clear call to action in the national campaign. Areas of low smart meter and high traditional prepayment meter coverage have a correlation with inner city areas, and often with Private or Social Rented Sector occupancy. For example, in 2023-24, 32% of households in London were private renters and 21% were social renters, compared with 17% and 16% in the rest of England respectively.[[footnote 23]](#fn:23) As of the end of May 2025, domestic smart meter coverage in London was 60%, compared to a GB average of 68%.[[footnote 24]](#fn:24) We therefore anticipate that our work to strengthen the rights of domestic tenants in getting a smart meter will have a positive impact on smart prepayment coverage. We also note that a substantial proportion of smart meters replacing traditional prepayment meters are installed in credit mode. This indicates that smart meters are giving consumers greater flexibility in choosing how to pay for their energy - empowering them to change the way they pay without needing to change their meter.[[footnote 25]](#fn:25) Energy suppliers should continue to ensure they give consideration to the replacement of traditional prepayment meters when planning their overall approach to smart meter deployment. Section 3 of this consultation proposes a requirement on energy suppliers to complete annual deployment plans, submitted to the regulator, Ofgem. This is to allow Ofgem to monitor progress and hold suppliers accountable. We will work with Ofgem to explore ways to ensure supplier delivery of smart prepayment remains on track, including through the use of deployment plans. ### Helping consumers better monitor their energy usage A key benefit of smart metering is the ability for consumers to access near real-time data about their energy consumption. Consumers can use this information to better understand how they use energy and to take informed decisions on how to reduce their energy consumption, benefitting both the individual in terms of saving money, and the wider network in terms of carbon savings. Independent evaluation by the Behavioural Insights Team (2023) and DESNZ research (2024) found energy consumption savings for consumers with smart meters that were consistent with the Programme’s 2019 Cost Benefit Analysis assumptions of 3% for electricity credit and 2.2% for gas credit.[[footnote 26]](#fn:26) When installing a domestic smart meter, energy suppliers are required to offer an IHD which is compliant with the Smart Metering Technical Specification (SMETS2). This is a device with a screen which gives accurate information about energy consumption in pounds and pence. Consumers do not have to accept this offer, although the vast majority do. Energy suppliers can offer alternatives – such as mobile apps or their own devices – but they must not mislead the consumer concerning the availability and benefits of an IHD. Where a consumer accepts the IHD, the energy supplier is responsible for maintaining the IHD for the first 12 months following installation. The government understands that some consumers experience issues with their IHD which can undermine their smart metering experience, and, in some cases, consumers are not offered one at all by their energy supplier. We expect all energy suppliers to comply with their obligation to offer IHDs to consumers when installing smart meters. We also expect to see all energy suppliers take action to ensure IHDs are working, welcoming the further commitments made by 11 suppliers who have adopted the ‘Smart meter In-Home Display voluntary replacement principles’ to ensure that their customers can access repairs and replacements after the 12-month warranty period has elapsed.[[footnote 27]](#fn:27) Since the principles were launched, through engagement with industry, we understand that consumer advocates have received fewer complaints relating to IHD provision, and government has received fewer correspondence cases highlighting problems. We intend to continue to monitor this issue closely and drive further improvements where necessary. Many energy suppliers and third-party providers already offer non-IHD feedback tools, such as apps, which are in addition and can be complementary to the IHD. We expect these will continue to provide consumers with a growing number of benefits, from ways to inform decisions on energy efficiency home retrofit, to providing feedback tailored for those on smart tariffs, to accessing better, more targeted support from their energy supplier. For example, it is already the case that low carbon technologies such as batteries and photovoltaic panels come with apps that display real-time energy information in ways that supplement information available via an IHD. However, considering available evidence, it remains the government’s position that the IHD is still the best option for a universal, baseline feedback tool and means of making energy consumption data and tariff information available to multiple members of a household. For example, it does not rely on internet access or user confidence in using mobile apps, and information on the screen can be easily accessed by all members of a household. In addition, the specification for IHDs is set out in SMETS2, ensuring that consumers receive a standardised product which is interoperable between energy suppliers. The scope and range of other feedback tools are broad and not subject to smart metering regulations. While this allows for innovation and diversification of products that may be well-suited to a wide range of applications, government is mindful of both the risks and opportunities of this approach for consumers. We therefore intend to consider further strengthening and future-proofing consumer protections in relation to IHDs and other feedback tools and will explore the ways in which feedback data is made available to consumers. We are keen to build our evidence base to better understand consumer and industry requirements for accessing real-time energy consumption data. This will help us consider the need for appropriate interventions relating to IHDs or other feedback tools, such as apps, online accounts or physical devices, whether now or in future. Should we reach a view that further intervention is needed following our analysis of the evidence collected, we will consult on policy options. We welcome views on the following evidence questions. ### Consultation questions Q1. What evidence can you provide on both the cost savings and energy consumption savings to consumers of non-IHD feedback tools in comparison to IHDs? Are these realised for all groups of consumers? Q2. Thinking about the current role of IHDs and how this could evolve; is there evidence of the role that additional functionality may play in supporting a more flexible and dynamic Clean Power system? Q3. What evidence can you provide on additional, broader benefits to consumers of non-IHD feedback tools in comparison to IHDs? Please make reference to specific functionality and features of non-IHD feedback tools in your response, where appropriate. Q4. What evidence can you provide on the specific needs of vulnerable and low-income consumers in relation to feedback tools, including IHDs? ### Delivering a positive non-domestic consumer experience of smart metering Smart meters are being rolled out to smaller businesses and public sector sites as well as into homes. The non-domestic smart meter rollout covers 3 million meters across a range of sectors from retail and hospitality to schools.[[footnote 28]](#fn:28) As with the domestic rollout, the government is committed to improving the smaller non-domestic consumer experience of smart metering to support organisations to realise the benefits of their smart meter. Alongside the proposed inclusion of non-domestic suppliers in strengthened requirements on suppliers ([see Section 1 of this consultation](#section-1-ensuring-consumers-benefit-from-operating-smart-meters)), this includes: * Ofgem’s consultation which is inviting views on applying the proposed Guaranteed Standards of Performance to microbusiness energy consumers with smart meters * work with suppliers to tailor the domestic ‘Guide to consumers’ rights and expectations’ to a non-domestic context which can complement Ofgem’s proposals * continued Smart Energy GB campaign activity to microbusinesses, using a range of tailored channels and messages * a requirement on energy suppliers (since 1 October 2024) to provide all smaller organisations with smart meters with free and regular information on their energy use to help them monitor and manage costs * continued activity by government to drive best practice with respect to supplier delivery of this requirement, with suppliers having launched a range of innovative functionalities to support organisations to engage with their smart meter data ## Section 1: Ensuring consumers benefit from operating smart meters As we look ahead to the next phase of the smart meter rollout, we want to deliver a step-change in the consumer experience and ensure a smooth transition to 4G communications. ### Background We want to deliver a high-quality, improved consumer experience of smart meters. It is critical that energy consumers receive the full benefits of the smart meters they have installed, and that consumers yet to take up the offer of having a smart meter installed have confidence in smart meters and their benefits. This is in both consumers’ and suppliers’ interests and is the best way of ensuring a smart meter rollout that is optimised for supporting future challenges and the government’s 2030 Clean Power Mission. Too many smart meters are currently operating in traditional mode and, looking to the future, millions of smart metering assets need to be replaced ahead of service end-dates in order to maintain smart services for consumers. In the absence of government intervention, it is expected that fewer consumers would benefit from smart meters being maintained in smart mode, and that those consumers whose smart meters fall into traditional mode would see this persist for longer. This would create a number of negative consequences, including: * insufficient operating smart meter coverage to meet the objectives of the Clean Power 2030 Mission and so support sufficient flexibility opportunities * labour market impacts as replacement rate timescales are compressed, resulting in higher peak capacity requirements with consequences on the cost and time needed to ramp up resource rates * reduced rollout benefits as fewer consumers would have operating smart meters, compounded by a potential fall in uptake of first time installs as a result of negative consumer sentiment - expected impacts would include, reduced energy market interaction as fewer consumers capitalise on energy consumption insights, reduced uptake of smart services and technology as fewer consumers have the platform to benefit * inequity in the distribution of costs and benefits across the consumer base as benefits would mainly accrue to those consumers with smart meters operating in smart mode We are therefore proposing amendments to the Supplier Licence Conditions and the DCC Licence, to provide clarity on the levels of service consumers can expect to see, and on the dates ahead of which suppliers must act in order to ensure smart services are maintained. This will provide all consumers with a consistent experience and will give certainty to industry to underpin the investment needed to improve at pace the number of smart meters operating in smart mode and to ensure they continue to do so. #### Smart meters operating in traditional mode Smart meters that operate in traditional mode result in estimated bills for consumers unless a consumer provides manual meter readings. Smart meters operating in traditional mode limit both consumers and service providers (and other users) from realising the full benefits of smart meters. We need to maximise the opportunities that working smart meters underpin such as from flexible energy usage, the effective use of low carbon technologies, electrical vehicle (EV) chargers, and updating tariff information. A number of wider supplier and network benefits are expected to flow down to consumers and an increasing proportion of smart meters in traditional mode will mean they do not materialise to the same extent. The percentage of smart meters operating in traditional mode was c.9% at the end of March 2025, with consumers often left with smart meters operating in traditional mode for too long.[[footnote 29]](#fn:29) The percentage of smart meters operating in traditional mode has been gradually reducing since autumn 2024 as a result of actions taken by suppliers. There has been a 1.3% percentage point improvement between September 2024 and March 2025 (from 10.6% to 9.3%), following Ofgem’s compliance engagement initiated against 6 large suppliers in July 2024 under the existing Supply Licence Conditions.[[footnote 30]](#fn:30) We welcome the recent increase in the percentage of smart meters operating in smart mode. We expect to see this momentum sustained and to see meaningful improvements in the operating percentage by the end of 2025. The business case for smart metering is predicated on energy suppliers installing, and energy consumers benefiting from, operating smart meters. Energy suppliers are subject to existing Licence obligations which seek to ensure that smart meters are maintained in smart mode. The DCC are subject to existing obligations which seek to ensure a minimum level (99.25%) of smart meter coverage. The root causes of smart meters operating in traditional mode are multifaceted and vary in their extent and ease of resolution, with the majority requiring an engineer to visit the consumer premises. Causes include: * Smart Metering Systems unable to communicate via the WAN or HAN, which may be due to coverage and connectivity limitations/performance variation, technology faults, device software updates being required or environmental and/or radio interference * installed meters yet to be connected to the national smart meter network managed by Smart DCC - this is common in new build premises but can also be seen where technical, communication or operational issues arise, stemming from equipment faults or weak/inconsistent network connectivity for example * where the customer has switched energy supplier, and their new supplier has yet to connect to and commence operation of the smart meter either because of process delays by the gaining supplier or because it had not been commissioned with the DCC national network by the original installing supplier or was already operating in traditional mode prior to the switch to the new supplier We recognise that there is regular cross industry consideration of the causes of smart meters falling into traditional mode. We welcome the information sharing and focus on common issues resolution we have seen in smart meter governance forums. This remains an important means of focusing collectively on consumer benefits being realised. It remains the case that the volume and percentage of smart meters operating in traditional mode is too high. We want consumers to have confidence in their smart metering service, that the installation will leave a consumer with a working smart meter from the outset and in how quickly a smart meter operating in traditional mode will be recovered should that arise unexpectedly. #### Pre-emptive replacements to avoid smart meters operating in traditional mode In the coming years, as commercial and technical changes are implemented, there are distinct risks to consumers’ retention of smart services – stemming from the DCC’s SMETS1 communication services terminating and the Mobile Network Operators closure of 2G/3G services by the end of 2033. In both instances, urgent action is needed to replace millions of communications hubs (and associated equipment as needed) before the service end-dates. Through our bilateral engagement, we know that many industry parties are focused on planning for and effectively resourcing a smooth transition from SMETS1 to SMETS2 systems and from 2G/3G services to 4G services. The extension in commercial arrangements out to 2033 of parts of DCC’s SMETS1 communication service that would have ended in 2029 ensures suppliers have more time and flexibility to plan this transition so that it is efficient and effective for consumers. The existing Operational Licence Condition requires suppliers to have replaced communication hubs (and metering as necessary) to maintain HAN and WAN communications. We consider however that there are benefits in setting out further detail and requirements in Licence Conditions to support consumer outcomes and suppliers’ efforts to successfully manage changes in the communication services available. In turn, this will afford government greater confidence the necessary actions will be taken in a timely way to the benefit of consumers. ### Proposal 1: Time bound recovery of smart meters operating in traditional mode #### Summary of proposal The existing Operational Licence Conditions require suppliers to take all reasonable steps to maintain the HAN and ensure that they do not act to compromise the WAN connection once it has been established. The current drafting does not explicitly focus on consumer outcomes and what suppliers should do when smart services are no longer maintained. We propose to amend the Operational Licence Conditions in Supplier Licence Conditions to require that suppliers take all reasonable steps to ensure any smart meters operating in traditional mode are operating in smart mode as soon as possible and no later than 90 days from the date they first become aware of an issue. This would, for example, be expected to result from internal monitoring or the failure to successfully take a remote reading but could also be as a result of situations such as a consumer raising the issue or on change of supplier. Introducing a maximum timeframe for recovery of smart services will strengthen the existing Operational Licence Condition by setting a service standard for consumers and clear expectations for industry to focus on operational readiness to triage and fix smart communications in support of this obligation. It is proposed to be consistent with the broader Operational Licence Conditions which apply equally to domestic and non-domestic suppliers, large and small suppliers. The principle of the policy is that consumers should reasonably expect a smart service and have equivalent expectations on redress timescales where that is not the case. This proposal aims to provide clarity about the standard of service consumers can expect from suppliers if their smart meters lose smart services and aims to complement proposals for new smart meter Guaranteed Standards of Performance issued by Ofgem.[[footnote 31]](#fn:31) It is expected to support a continued acceleration in the percentage of smart meters operating in smart mode as result of the improved triage efficiencies and recovery timescales this proposal should drive. We consider that this proposed Licence amendment is in consumers’ and energy suppliers’ interests and is the best way of enabling an optimised percentage of smart meters operating in smart mode as needed to support the government’s 2030 Clean Power Mission which is based on an expectation of high levels of operating smart meter coverage by the end of 2030. #### 90-day timeframe We consider that 90 days is a reasonable period to recover or replace a Smart Metering System (SMS). This is on the basis that most resolutions require a site visit to replace at least part of the SMS, once suppliers, DCC and other parts of industry have triaged and identified how to rectify the root cause of the smart meter falling into traditional mode. There are arguments for shortening this 90-day period on the basis that we want any consumer detriment to be minimised. Historically a proportion of smart meters operating in traditional mode have been fixed remotely, and given this precedent, we could expect that a proportion could be resolved remotely in future and so potentially more quickly than the 90-day requirement. However, we consider that a 90-day period provides an achievable target that will improve consumer services. Ultimately this would reduce the period of time that consumers’ energy bills are being calculated based on estimated or manually read consumption as opposed to automatic calculations and so reduces the impact that estimated bills have for example, overpayments accumulating unnecessary credit, or underpayments causing a large debt to repay. It is crucial therefore that any incident triage is undertaken swiftly and comprehensively. We propose the 90-day target should be triggered as soon as suppliers become aware the SMS is not operating in