Ofgem's TPI code is no longer a vague future threat. The framework is taking shape, the consultation responses are in, and mandatory registration is on the horizon. If you're an energy broker, consultant, or anyone who helps businesses buy energy, the time to prepare is now — not when the deadline lands.
This is a practical checklist. Not a legal briefing, not a policy summary. Just the things you need to have in place so that when registration opens, you're ready.
The background in 30 seconds
Third Party Intermediaries have operated in a regulatory gap for years. Suppliers are regulated by Ofgem. Consumers have protections. But the brokers and consultants in the middle? Largely unregulated. Ofgem's TPI code changes that by introducing mandatory registration, conduct standards, and enforcement powers.
For a deeper look at the regulatory changes and their implications, see our earlier piece on TPI regulation in 2026. This checklist focuses on what to do about it.
1. Commission disclosure
What the code expects: Brokers will need to disclose their commission to clients in a clear, standardised format. The direction of travel is full transparency — not buried in terms and conditions, but visible at the point the client makes a decision.
What to do now:
- Show your commission as a separate line on every quote. Not aggregated. Not hidden in the unit rate. A standalone figure the client can see before they commit.
- Record the commission per kWh and the total estimated value over the contract term.
- Make this standard practice now so it's not a scramble later. Clients who already see your commission will barely notice the regulatory change. Clients who find out for the first time because the regulator forced you to disclose it will be less pleased.
At Edge, commission has been a visible column in the deal room since launch. If you're building your own quoting system, add the column now.
2. Whole-of-market comparison (or documented limitations)
What the code expects: If you claim to search the whole market, you need to actually search the whole market. If you work from a panel of preferred suppliers, you need to disclose that — and explain what it means for the client.
What to do now:
- Document which suppliers you have agreements with.
- If you work from a panel, state clearly in your client materials how many suppliers are on the panel and whether there are major suppliers excluded.
- If you claim whole-of-market, be prepared to demonstrate that your quotes cover every accessible supplier.
- Keep a record of every quote sourced for every client, including quotes that weren't presented — and the reason they weren't presented.
3. Client agreements and LOAs
What the code expects: Clear, fair terms. No hidden lock-ins. No clauses that prevent the client from switching broker. LOAs that are limited in scope and duration.
What to do now:
- Review your LOA template. Does it clearly state what it authorises and what it doesn't? Is there a time limit? Can the client revoke it easily?
- Review your terms of business. Are there any clauses that lock the client into using you for future renewals? Any penalties for leaving? These are likely to be prohibited or heavily restricted under the new code.
- Make sure your LOA only authorises access to information and quote requests — not contract signing authority, unless the client has explicitly and separately granted that.
4. Record keeping and audit trail
What the code expects: TPIs will need to demonstrate that they acted in their client's interest. That means records — not memories, not verbal assurances. Documented evidence that the process was fair.
What to do now:
- For every client engagement, keep records of:
- The quotes you sourced and from which suppliers
- The quotes you presented to the client
- The client's decision and any rationale discussed
- Your commission on the chosen contract
- Any advice you gave about contract type, length, or timing
- Use a CRM or deal room that logs this automatically. If you're working from email threads and spreadsheets, the record-keeping burden will be significant when the code kicks in.
5. Complaints handling
What the code expects: A documented complaints procedure that clients can access. Possibly referral to the Energy Ombudsman for unresolved disputes.
What to do now:
- Write a complaints procedure if you don't have one. It doesn't need to be long — just clear about how clients raise a complaint, how you investigate, and what the escalation path is.
- Publish it on your website and include a reference to it in your terms of business.
- Keep a log of complaints received and how they were resolved. The regulator will want to see that you take complaints seriously and act on them.
6. Staff competence and training
What the code expects: People giving energy advice should be competent to do so. The code may require evidence of training or professional development.
What to do now:
- Document any training your team has completed — industry qualifications, supplier training, product knowledge sessions.
- If your team advises on specific products (flexible purchasing, green tariffs, pass-through contracts), make sure they can explain them accurately.
- Consider formal qualifications. The Energy Institute and other bodies offer courses that may become de facto requirements under the new code.
7. Ongoing client care
What the code expects: TPIs should demonstrate value throughout the contract, not just at the point of sale. This is where the code goes beyond commission disclosure and into service standards.
What to do now:
- Track renewal dates and proactively reach out before contracts expire.
- Validate client bills — this is the most concrete way to demonstrate ongoing value. Checking every bill, catching errors, recovering overcharges. It's documented, measurable, and directly beneficial to the client.
- Report back to clients regularly. Even a quarterly email showing their contract status, any billing issues flagged, and upcoming renewal dates demonstrates care.
Bill validation is arguably the strongest compliance tool a broker has. It generates documented evidence of client care that no regulator can argue with. For the full picture on how validation works, see how it works.
8. Data protection
What the code expects: Compliance with GDPR and data protection laws when handling client energy data.
What to do now:
- Review your privacy policy. Does it cover the energy data you collect, how you store it, and who you share it with?
- Make sure client data is stored securely and only accessed by authorised people.
- If you share data with suppliers for quoting purposes, ensure clients know this (the LOA typically covers it, but check).
The bottom line
Most of this checklist is just good practice. Transparent commissions, fair terms, proper record keeping, ongoing client care. If you're already doing these things, the TPI code formalises what you do rather than forcing you to change.
If you're not doing some of these things, start now. The regulatory timeline may shift, but the direction won't. Brokers who are already compliant will find registration straightforward. Brokers who aren't will face a stressful catch-up.
And if you want to add automated bill validation to your compliance toolkit — demonstrating ongoing client care with documented evidence on every bill — try Edge free and see what it looks like in practice.