Pass-through requirements for energy price support provided to intermediaries
How intermediaries such as landlords are required to pass through to end users energy price support provided by the Energy Price Guarantee, Energy Bills Support Scheme, Energy Bill Relief Scheme and Energy Bills Discount Scheme.
In the Energy Prices Act 2022, the government has established a requirement that energy price support is passed on to end users. This means that intermediaries that have been provided with support from the following schemes are required to pass the support obtained to the end users who are the intended beneficiaries of the relevant schemes:
The government introduced regulations to bring this into force in Great Britain on 1 November 2022. Regulations for pass-through requirements for the Energy Price Guarantee Northern Ireland and the Energy Bill Relief Scheme Northern Ireland came into force on 5 November 2022. The regulations for the Energy Bills Support Scheme Northern Ireland came into force on 12 January 2023. Regulations for the pass-through requirements for the Energy Bills Discount Scheme came into force on 26 April 2023.
This legislation puts obligations on intermediaries who provide energy but are not licensed energy suppliers. This may include but is not limited to:
student accommodation managers
social housing providers
local authorities (for council housing)
park site owners (for park homes)
marinas if using shore power (for boat homes)
electric vehicle charging operators
other residential building managers
This guidance provides an overview of the obligations on intermediaries to pass through the energy price support. It provides illustrative examples of how intermediaries may calculate the ‘just and reasonable’ amount to pass through to comply with the regulations. The guidance also summarises the process for enforcement if these obligations are not met.
In addition, it includes a template letter that intermediaries can use to send to end users to meet their obligation to share information. A further template letter is provided for end users to raise concerns with their intermediary if this information has not been provided or there is disagreement on the amount that the intermediary has passed through to the end user. Template letters provided are only illustrative, and intermediaries should refer to their obligations as set out in the Regulations.
There is separate guidance for heat networks which provides an overview of the obligations on heat suppliers to pass through the benefits of the EBRS and EBDS to heat network consumers. Illustrative examples, example letter templates, and a summary of the enforcement process are also included.
Updated the guidance on the pass-through requirements for energy price support provided to intermediaries to include scenarios for the Energy Bills Discount Scheme.
Updated the guidance on the pass-through requirements for energy price support provided to intermediaries to include the Energy Bills Discount Scheme information.
Pass-through requirements added for the Energy Bills Discount Scheme, including updates to the template letters.
Guidance on pass-through requirements for energy price support provided to intermediaries updated with details of the Alternative Fuel Payment and Non-domestic Alternative Fuel Payment scheme regulations.
Heat networks pass-through guidance and template letters updated to reflect the new Regulations, which came into effect on 6 December 2022, and include new obligations on all heat suppliers to send information to the Office for Product Standards and Safety.
Guidance updated to include Northern Ireland scheme.