Energy and Water Disputes: Bills, Meters, Switching and Vulnerable Customers

Energy back-billing under Ofgem SLC 21B, meter accuracy, direct debit credit balances, vulnerable-customer protections under SLC 25, and water Guaranteed Standards. The Energy Ombudsman and WATRS routes.

Energy Ombudsman / WATRS (CEDR)

2 sub-sectors covered

UK energy and water are tightly regulated sectors with clear consumer protections, dedicated ombudsmen, and well-developed back-billing and guaranteed-standards regimes. Most disputes are won by citing the specific Ofgem licence condition (energy) or Ofwat guarantee (water) the supplier has breached, and by using the supplier's contemporaneous internal notes via a Subject Access Request to establish the timeline.

The Energy Ombudsman is the binding ADR scheme for energy. WATRS (the Water Redress Scheme, administered by CEDR) is the binding ADR scheme for water. Both are free to consumers and member-funded.

Key Legislation

Gas Act 1986
Electricity Act 1989
Water Industry Act 1991
Ofgem Standard Licence Conditions (esp. SLC 21B back-billing; SLC 22 complaint handling; SLC 25 vulnerable customers; SLC 27 direct debit; SLC 31 metering)
Ofgem Guaranteed Standards of Performance Regulations 2015 (SI 2015/699)
Consumer Rights Act 2015 (Part 1 Chapter 4)
Consumer Contracts Regulations 2013 (SI 2013/3134)

Complaint Route

Energy Ombudsman / WATRS (CEDR)

Always complain to the company directly first. Give them 8 weeks to respond. If unresolved, escalate to the relevant ombudsman or ADR scheme listed above. EvenStance guides you through every step.

The most common energy and water disputes

Back-billing. Ofgem SLC 21B prohibits energy suppliers from charging consumers for energy used more than 12 months before the supplier issued an accurate bill, where the delay was attributable to the supplier. The rule applies across domestic and microbusiness customers. Common patterns: estimated bills replaced years later with corrected back-bills; metering errors discovered late; switching errors that surface on the new supplier's first cycle.

Meter accuracy. Where the consumer disputes the meter reading or the meter itself, the supplier must arrange an accuracy check under SLC 31. Disputed readings are escalated through the supplier's internal process; if unresolved, the consumer can request an independent meter test through Ofgem's process.

Switching. Energy switching runs under Ofgem's faster-switching framework, with the new supplier typically completing the switch within five working days. Erroneous switches (consumer switched without authorisation) must be reversed and any consequent loss compensated. Water customers are largely not able to switch domestic suppliers; the regional monopoly persists. Non-household water customers in England can switch under the Water Act 2014 framework.

Vulnerable customers. SLC 25 requires energy suppliers to identify and support vulnerable customers through the Priority Services Register. The PSR provides advance notice of planned outages, priority repair, accessible communications, and protections against disconnection.

Direct debit overcollection. Where the supplier sets a direct debit at a level materially above estimated usage, leading to a substantial credit balance, the consumer has a right to a refund of the credit under the Energy UK Direct Debit Principles and SLC 27. The supplier must refund credit balances on request and review direct debit levels at least annually.

Water leakage and Guaranteed Standards. For water, leakage of unmetered or under-metered usage is typically resolved through the supplier's leakage allowance. Water companies must comply with the Guaranteed Standards Scheme under the Water Industry Act 1991, with fixed-sum payments for missed service standards (response times, supply interruptions, sewer flooding, low pressure).

The first fob-off and the rebuttal that works

Energy and water suppliers' first responses cluster around two patterns. First, the supplier issues a templated apology and offers a small goodwill payment. The rebuttal is the specific licence condition: SLC 21B for back-billing, SLC 25 for vulnerability, SLC 27 for direct debit, SLC 31 for meter accuracy. Cite the licence condition by reference in the formal complaint and demand the supplier address it explicitly.

Second, the supplier blames a third party (the meter operator, the previous supplier, the network operator). The rebuttal is that the supplier holds the customer-facing relationship and the licence-condition obligations. Where a third party caused the underlying issue, the supplier remedies the consumer and pursues the third party itself.

Escalation path

For energy: complaint to the supplier, eight-week internal handling window, Energy Ombudsman referral (12 months from the deadlock letter or expiry of the internal window). Energy Ombudsman award is binding on the supplier up to £20,000 plus reasonable expenses and apology/service requirement.

For water: complaint to the supplier; CCWater (the Consumer Council for Water) acts as a free advocacy and mediation service; WATRS is the binding ADR scheme. WATRS awards are binding on the supplier up to £20,000.

For systemic issues: Ofgem and Ofwat regulate the supplier conduct; complaints do not produce individual redress at the regulator but feed enforcement.

What it costs and how long it takes

Energy Ombudsman and WATRS are free to consumers. Energy Ombudsman case-handling time has shortened materially in 2025-2026; mid-2026 turnaround was widely reported as around six weeks for many cases, down from the longer waits in the 2023-2024 backlog. WATRS typical turnaround is six to twelve weeks.

How EvenStance helps with energy and water

Frank's energy and water flow drafts the formal complaint citing the specific SLC or Guaranteed Standard, runs the eight-week clock, and prepares the Energy Ombudsman or WATRS submission. The Subject Access Request flow generates the SAR to the supplier for the contemporaneous account notes, meter readings, and direct debit calculations.

Sub-sectors Covered

Energy - Gas & Electricity SupplyWater & Sewerage

Frequently Asked Questions

Can my energy company back-bill me?

Not for usage more than 12 months before an accurate bill was issued where the delay is the supplier's fault. Ofgem SLC 21B is the operative rule. Cite it by reference in your formal complaint.

My direct debit is too high. Can I get the credit back?

Yes. The supplier must refund a credit balance on request and must review direct debit levels at least annually. SLC 27 and the Energy UK Direct Debit Principles apply.

My water supplier missed an appointment. Am I owed anything?

Under the Guaranteed Standards Scheme (Water Industry Act 1991 framework), fixed-sum payments apply for specified service failures including missed appointments. The amounts are published annually; check your supplier's current published guaranteed standards.

The supplier says the meter is accurate but I disagree. What can I do?

Request an independent meter test through your supplier under SLC 31. If the meter is found to be inaccurate, the supplier corrects the bills. If you remain dissatisfied with the supplier's handling, complain formally and escalate to the Energy Ombudsman after eight weeks.

I am vulnerable and the supplier disconnected me. Is that lawful?

Energy suppliers must comply with SLC 25 on vulnerable customers and follow specific protections against disconnection in winter and for households with vulnerable occupants. Where the supplier has not properly identified vulnerability and applied protections, the complaint to the supplier and the Energy Ombudsman has substantial merit.