If you're a Third Party Intermediary — an energy broker, consultant, or anyone who helps businesses buy energy — regulation is coming. Ofgem has been talking about it for years. Now it's actually happening.
Here's what you need to know and what you should be doing about it.
What's changing
Ofgem is introducing mandatory registration for all TPIs operating in the UK energy market. This means every broker, consultant, and energy adviser will need to be registered and comply with a set of conduct standards.
The key elements:
- Mandatory registration. You won't be able to operate as a TPI without being on Ofgem's register. This applies to all intermediaries, regardless of size.
- Conduct standards. Registered TPIs will need to meet minimum standards around transparency, fair treatment of customers, and handling of complaints.
- Commission disclosure. While the exact requirements are still being finalised, the direction is clear — brokers will need to be transparent about what they earn from each deal.
- Complaints handling. TPIs will need a formal complaints process and may fall under the jurisdiction of the Energy Ombudsman.
- Monitoring and enforcement. Ofgem will have powers to investigate, sanction, and de-register TPIs that don't meet the standards.
Why this is happening
The TPI market has had a transparency problem for a long time. Some brokers charge commissions of 5p/kWh or more without telling their clients. Some steer businesses toward suppliers that pay the highest commission rather than offer the best rate. Some lock clients into multi-year brokerage agreements they can't exit.
None of this is illegal under current rules because, frankly, there aren't many rules. TPIs sit in a regulatory gap — suppliers are regulated by Ofgem, but the intermediaries who sell their products mostly aren't.
Ofgem's view is that businesses deserve the same protections when buying energy through a broker as they get when buying direct. That's hard to argue with.
What it means for brokers in practice
If you're already operating transparently, most of this won't change how you work. You'll need to register, document your processes, and possibly adjust some disclosures. But the substance of what you do stays the same.
If you're not operating transparently — if your commission is buried, your market comparison is limited, or your client agreements are one-sided — you'll need to make changes. And the sooner you start, the less disruptive it will be.
Commission transparency
This is the big one. The industry is moving toward full disclosure of broker fees. If you're not already showing your commission on every quote, start now.
At Edge, our commission has been visible on every quote since day one. It's not a line in the terms and conditions. It's a column in the deal room, right next to the supplier rate and standing charge. When disclosure becomes mandatory, nothing changes for us or our clients.
Record keeping
Regulated TPIs will need to demonstrate that they searched the market properly, presented options fairly, and acted in their client's interest. This means keeping records of the quotes you sourced, the ones you presented, and the rationale for your recommendations.
If your current process involves calling a few suppliers, getting verbal quotes, and recommending one over the phone, you'll need to tighten that up.
Complaints process
You'll need a documented complaints procedure. Most established brokerages already have one. If you don't, put one in place now.
How bill validation helps with compliance
Here's where this connects to bill validation. One of Ofgem's core principles is that TPIs should be acting in their clients' best interests — not just at the point of sale, but throughout the contract.
Systematic bill validation is one of the clearest ways to demonstrate ongoing client care. If you're validating every bill, catching errors, and recovering overcharges, you have documented evidence that you're adding value between renewals.
Compare that to a broker who signs a deal, disappears for two years, and shows up at renewal time asking for another LOA. When Ofgem asks what value you're providing to your clients, validated bills and recovered overcharges are a concrete answer.
What to do now
Register early. When the registration window opens, don't wait. Being among the first registered TPIs signals professionalism to your clients and to the market.
Audit your transparency. Can your clients see your commission on every quote? If not, build that in now. The transition is easier when it's voluntary than when it's mandatory.
Document your processes. Market comparison methodology, quote presentation, client communication, complaints handling. Write it down.
Add bill validation to your service. It's good for clients, good for retention, and good for compliance. How it works explains the process, and you can try Edge free to see what systematic validation looks like in practice.
The brokers who prepare now will find regulation straightforward. The ones who wait will find it disruptive. The direction is clear — the only question is whether you get ahead of it or scramble to catch up.