Fair treatment rules that shape every energy campaign

The Standards of Conduct: what they actually require

Ofgem's Standards of Conduct sit inside the supplier licence and apply to every regulated interaction, not just sales calls. Marketing teams need to internalise three obligations:

1. Act in a way consistent with fair treatment of every customer, including in advertising and promotional material.

2. Communicate clearly, simply and concisely, avoiding jargon that obscures cost or terms.

3. Do not exploit a customer's circumstances, vulnerability or lack of knowledge.

Notice these are outcome-based, not a checklist. Ofgem doesn't publish a list of banned phrases; it judges whether the overall effect misled or disadvantaged a customer. That means campaign sign-off has to ask "could this be read unfairly?" not just "is this technically true?"

Pricing claims: do's and don'ts

Energy pricing is unusually complex: unit rates, standing charges, dual fuel discounts, fixed versus variable tariffs, the Energy Price Cap set by Ofgem for default tariffs. Claims need to survive scrutiny against that complexity.

Do:

• State whether a quoted price is capped, fixed, or variable, and for how long.
• Show the standing charge (the daily fixed fee charged regardless of usage) separately from the unit rate.
• Base "average household savings" claims on Ofgem's published typical consumption values, not cherry-picked usage profiles.

Don't:

• Say "cheapest on the market" without a verifiable, time-stamped comparison basis.
• Advertise a headline rate that excludes standing charges or exit fees.
• Use "guaranteed savings" language when savings depend on the customer's actual usage pattern.

A useful real-world reference: the ASA has previously ruled against energy ads for implying guaranteed savings without adequate qualification. Reviewing published ASA adjudications before a campaign goes live is a cheap, fast compliance check.

Doorstep and telesales scripts

Doorstep selling in energy is heavily scrutinised because it targets customers in their own homes, often without time to compare offers. The Consumer Contracts Regulations 2013 give customers a 14-day cancellation right for doorstep and distance sales, and this right must be disclosed clearly, not buried in small print read quickly at the end of a call.

Script requirements in practice:

• Sales agents must identify themselves, the company they represent, and the commercial purpose of the visit or call, upfront.
• Agents cannot imply they are from the customer's current supplier, from Ofgem, or from a government scheme, unless true.
• Any comparison to the customer's existing tariff must be based on accurate, current information, not assumption or guesswork.
• The right to cancel within 14 days must be stated verbally and confirmed in writing.

Ofgem has previously fined suppliers for doorstep mis-selling where scripts implied urgency ("this offer ends today") to pressure vulnerable customers into signing up. Urgency claims are a recurring enforcement flashpoint: if there's no genuine, verifiable expiry, don't imply one.

Standing-charge disclosure: the 2026 flashpoint

Standing charges have become one of the most contentious topics in UK energy retail, since they're charged even to customers who use zero energy, disproportionately affecting low-usage and low-income households. Ofgem has run consultations on reform, and marketing teams need standing-charge transparency baked into every price-facing asset:

• Standing charge and unit rate must be shown with equal prominence, not one in large font and the other in a footnote.
• Any "no standing charge" tariff must clearly explain how the cost is instead recovered (typically a higher unit rate).
• Annual estimated cost figures must use Ofgem's published typical domestic consumption values (TDCV) so comparisons are apples to apples across suppliers.

This is a good moment to check Ofgem's own consumer-facing tariff comparison guidance, since compliant marketing usually mirrors the same disclosure format Ofgem expects suppliers to use in official tariff information labels (TILs).

Vulnerable-customer protections

Ofgem requires suppliers to identify and protect vulnerable customers, defined broadly as anyone whose personal circumstances (age, health, financial resilience, literacy, language) make them less able to protect their own interests. This isn't a niche compliance corner; Ofgem estimates a large proportion of UK households show at least one characteristic of vulnerability (Ofgem, Consumer Vulnerability Strategy, figures updated periodically, treat any specific percentage as an estimate and check the current publication).

Marketing implications:

• Campaigns targeting "switch and save" offers cannot exclude or disadvantage customers on the Priority Services Register (a free support register for customers who are elderly, disabled, chronically ill or otherwise at higher risk).
• Debt and payment-plan promotions must not pressure customers already in financial difficulty into products (like unaffordable direct debit increases) that worsen their position.
• Sales channels reaching known vulnerable segmentssegmentsDividing a market into distinct groups of customers who share similar needs, characteristics or behaviours, so each group can be served with a tailored approach.View full definition → (e.g., care homes, sheltered housing) require extra scrip safeguards, such as mandatory "cooling off" reminders and simplified language.

Pre-launch compliance checks: a practical workflow

Before any energy marketing asset (ad, script, email, landing pagelanding pageA standalone web page built for a single campaign goal, designed to maximise conversions by removing distractions and focusing visitors on one action.View full definition →) launches, a compliance-by-design checklist should cover:

1. Claims substantiation: every price or savings claim traceable to a dated, verifiable source (own tariff data, Ofgem price cap figures, TDCV).

2. Standing charge visibility: shown with equal weight to unit rate, on every asset that quotes a price.

3. Cancellation rights: 14-day right clearly stated for doorstep/distance sales assets.

4. Vulnerability screening: does the campaign risk excluding, confusing or pressuring vulnerable segmentssegmentsDividing a market into distinct groups of customers who share similar needs, characteristics or behaviours, so each group can be served with a tailored approach.View full definition →?

5. Legal sign-off against the CAP Code and Ofgem Standards of Conduct, documented, not just verbal.

6. Script rehearsal/testing: doorstep and telesales scripts tested for implied urgency, misrepresentation, or unclear identification of the seller.

Building this into a sign-off gate, rather than a post-launch fire drill, is the difference between a fine and a footnote.

🎬 [VIDEO: "How Ofgem regulates energy suppliers" - youtube.com - search Ofgem's official channel for explainer content on licence conditions and consumer protection enforcement]

Key Takeaways

• Ofgem's Standards of Conduct are outcome-based: the test is whether a customer was treated fairly overall, not whether individual words were technically accurate.
• Pricing claims must disclose standing charges with equal prominence to unit rates, and savings claims must be based on verifiable, current comparisons using Ofgem's typical consumption values.
• Doorstep and telesales scripts must state seller identity, purpose, and the 14-day cancellation right under the Consumer Contracts Regulations 2013, and must avoid implied urgency.
• Vulnerable-customer protections, including the Priority Services Register, must actively shape campaign targeting and script design, not just customer service policy.
• Build compliance checks (claims substantiation, standing-charge visibility, vulnerability screening, legal sign-off) into pre-launch workflow, not post-launch correction.