Bernadette Faulkner

Amanda Solloway MP  
Minister for Affordability and Skills 

Department for Energy Security 
& Net Zero 
55 Whitehall 
London  
SW1A 2HP 

28th March 2024 

Ian Potter 
HM Assistant Coroner 
Inner North London 
St Pancras Coroner's Court  
Camley Street 
London  
N1C 4PP 

Dear Ian, 

I am writing to respond to the Prevention of Future Deaths report issued in relation to 
the death of Ms Bernadette Faulkner. You sent this report to the Minister of State for 
Housing, Planning and Building Safety, and it has been passed from the Department 
for Levelling Up, Housing & Communities to the Department for Energy Security & Net 
Zero for response.  

This is a deeply tragic and heartbreaking case, that the Department and I take very 
seriously. I was very saddened to hear about Ms Faulkner’s death and would like to 
express my personal condolences to Ms Faulkner’s family. 

The  independent  regulator,  The  Office  of  Gas  and  Electricity  Markets  (Ofgem),  is 
responsible  for  the  regulation  of  energy  suppliers  and  protecting  the  interests  of 
consumers.  

If a customer has any concerns about the safety of operating their meter, they should 
contact  their  energy  supplier  immediately  for  support.  Under  Ofgem’s  licence 
conditions,  suppliers  are  required  to  ensure  that  a  prepayment  meter  is  safe  and 
reasonably practicable for a customer’s circumstances. In its guidance, Ofgem set out 
that they would expect an assessment of this to include consideration of the location 
of a meter and how this may impact a customer’s ability to operate it. If at any time a 
supplier becomes aware that a prepayment meter is not safe to operate, Ofgem rules 
require suppliers to take action and offer to rectify this, which could include altering the 
position of the meter or providing an alternative method of payment for the customer.  

In relation to future protections, Ofgem introduced new rules in November 2023 that 
restrict suppliers from installing a prepayment meter involuntarily for certain vulnerable 
groups, including those over 75 years old with no additional support in the household. 
These  new rules  also  require  suppliers  to  make  at  least  ten  attempts  to  contact  an 
indebted customer and carry out a site welfare visit prior to any involuntary installation 
or remote switch of a smart meter taking place, to ensure the payment method will be 
safe in the customer’s circumstances. A remote switch involves remotely changing a 
smart meter from credit to smart prepayment mode. Under these new rules, suppliers 
are now also required to assess whether a prepayment meter continues to be safe for 
a customer on an annual basis as a minimum.  

                                                                 
 
 
                                      
  
 
 
 
 
 
 
 
   
  
  
 
 
 
 
 
 
 Alongside  this,  the  smart  metering  rollout  is  improving  prepayment  customers’ 
experience,  by  giving  consumers  a  means  to  top  up  their  credit  without  having  to 
access  their  meters. The  Department  will  continue  to  work  with  energy  suppliers  to 
drive them to deliver smart metering to as many households as possible.  

Following this case being brought to my attention,  I have spoken with senior Ofgem 
officials who have assured me that they are looking at this case in detail and will take 
any necessary actions to reduce the risk of such tragic incidents happening again. I 
also  welcome  the  actions  for  industry  that  have  been  set  out by  Energy  UK  in  their 
response to this report.  

I  also  welcome  Energy  UK’s  commitment  to  work  with  a  range  of  stakeholders, 
including the housing sector, to ensure more is done to identify those that need support 
and  deliver  interventions  that  keep  customers  safe.  This  is  a  useful  action  to  bring 
together  all  those  who  can  improve  support  for  vulnerable  customers  across  the 
energy  and  housing  sectors.  The  government  would  welcome  the  opportunity  to 
engage with these workshops, looking at relevant energy and housing considerations 
which could help vulnerable consumers. 

My officials would be very happy to discuss this case with you further, or put you in 
touch with relevant Ofgem officials,  if helpful. My officials will also work with Energy 
UK  on  the  delivery  of  the  actions  highlighted  in  their  letter,  such  as  the  proposed 
workshops on vulnerable customers, as appropriate. 

Finally,  I  would  like  to  reiterate  my  sympathies  with  Ms  Faulkner’s  family.  The 
Government will continue to engage with Ofgem and industry on this issue, to ensure 
the relevant parties are doing all they can to support and protect consumers.  

Amanda Solloway MP 
Minister for Affordability and Skills

Ian Potter, HM Assistant Coroner 
St Pancras Coroner’s Court 
Camley St 
London 
N1C 4PP 

29/02/2024 

Dear Coroner,  

I am writing in response to the Prevention of Future Deaths Report which you sent me in 
my capacity as the CEO of Energy UK following the accidental death of Bernadette Grace 
Faulkner in December 2022.  I was deeply saddened by the news of this case, and on 
behalf of my colleagues at Energy UK and all our members I want to express my heartfelt 
condolences to Mrs. Faulkner’s friends and family. I thank the Coroner for bringing the 
case to my attention.    

Energy UK has taken the duty conferred by this report extremely seriously. Our members 
deliver nearly 80% of the UK’s power generation and over 95% of the energy supply for 
the 28 million UK homes and many businesses. I am confident that the industry supports 
this response and will work with the Government and the regulator to take appropriate 
action.    

It is important to note that Energy UK does not represent all the energy network 
companies, which also have an important role in metering arrangements. We can put the 
Coroner in touch with appropriate colleagues at the Energy Networks Association, should 
you feel that this would be helpful or necessary. We have however, reflected the relevant 
issues in terms of grid connections and metering in our note. 

Firstly, we would like to be clear that any customer who is concerned about the safety of 
their meter placement should contact their energy supplier immediately. Their supplier will 
be able to offer support, whether that is through moving the meter where possible, 
replacing the meter with smart technology, or sending staff to the property to manually 
read the meter. The energy company will also consider whether a prepayment meter 
(PPM) is in fact the right payment method for the customer, and if appropriate will discuss 
alternative options that would require less frequent physical access to the meter.  

As directed by the Coroner, our focus in this response is on identifying and taking action to 
reduce the risk associated with historic meter placements and help to prevent similar 
deaths in the future. We are confident that the existing extensive regulatory framework, 
overseen by Ofgem, should ensure today no supplier is installing new legacy prepayment 
meters at height. This is something we have been reassured of by our members.  

However, we recognise that the rules around metering have developed over time, as the 
market and technology have also evolved. In many cases meter locations will have been 
determined when a meter was first installed, potentially decades ago, meaning there will 
be historic incidents of legacy meters installed at heights. Addressing this population must 
therefore be our priority.  

Energy UK  
26 Finsbury Square 
London EC2A 1DS 

T: 020 7930 9390 
@EnergyUKcomms 
www.energy-uk.org.uk 

Energy UK is the trading name of the Association of Electricity Producers Limited, a company limited by guarantee, registered in England & Wales.  
Company Registration No. 02779199. Registered office, as above. 

 
 
 
 
 
 
 
  
   
 
 
 
 
 We note, however, that meter siting is a complex matter involving several parties. While 
meters themselves are operated by energy suppliers, most are situated within private 
property (suppliers, therefore, in most situations require customer permission to access) 
and the connections to the grid, which define where meters are located, are determined 
and owned by network operators. Alongside the placement of a meter, safety then also 
depends on a combination of the type of meter, the payment method, the characteristics 
of the customer and any support they may require. These factors mean that action and co-
ordination across a broad range of stakeholders is necessary to address historic incidents 
of traditional prepayment meters that are situated at height. 

We have, however, identified the following meaningful actions that we will take forward 
that we believe should, over time, substantially reduce historic risks, having convened our 
members and other stakeholders, where this was possible, to discuss what more could be 
done:  

•  Action 1. Raise customer awareness of safety issues. Energy UK will work with 
consumer groups, including Citizens Advice (the statutory energy advocate) and 
Smart Energy GB (the communications body for the smart meter rollout) to further 
promote the existing guidance for customers on meter safety and emphasise the 
importance of customers contacting their suppliers if they have concerns. This will 
also explain the support that is available.   

•  Action 2: Improve support for vulnerable customers with their energy 

meters. Energy UK will convene workshops with energy suppliers and other 
stakeholders (including energy networks, Ofgem, the Government, the housing 
sector and customer groups) to examine the current customer journey, and gain a 
better understanding of how to: 

identify customers who need support;  
- 
-  deliver safety focused interventions; and 
- 

improve data sharing to further support the identification of vulnerable 
customers.   

We will also continue to work with stakeholders to improve how we can share data 
about customers in vulnerable circumstances, to help target support and improve 
safety. 

•  Action 3: Accelerate the transition from legacy meters to smart meters. Smart 
meters offer significant scope to reduce many of the safety risks associated with 
inaccessible meter placement. They can greatly reduce the physical interaction a 
customer has with their meter. We will continue to work with Government and 
Ofgem to ensure that the smart meter programme is delivered, and that we have 
the right policy framework to ensure continued progress on replacing legacy 
meters, particularly traditional PPM meters. This could involve working with Smart 
Energy GB, Ofgem, Government and others to consider ways to ensure social 
housing and privately rented properties are not left behind in the transition to 
smart.   

Having now explored this issue in some depth with our energy supplier members, I am 
confident that we are committed to acting on this and can make progress on improving 
outcomes for customers. However, this is very much dependent on close working and 
ambition from a range of other stakeholders involved in metering processes and 
standards, such as the energy networks, some of whom have a (or the most significant) 
role in determining the placement of a meter. 

 
 
 
 
 
 
 
 
 
 
 
 We will continue to work with Ofgem, the Department for Energy and Security and Net 
Zero, the Department for Levelling Up, Housing and Communities, and with colleagues 
from charities and consumers groups to reduce this risk in the future. We would be very 
happy to share more information with the Coroner, or to make introductions to other 
stakeholders if required. I would welcome any questions and would of course be happy to 
discuss our response with the Coroner.   

Lastly, I would like to again reiterate my sincere sympathy for the loved ones of Mrs 
Faulkner – of course we will do what we can, working with our colleagues who share the 
responsibilities around metering, to prevent any future tragedies.   

Yours sincerely 

Chief Executive 

 
 
 
 
 
 
 
 
 
  
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 Energy UK’s response 

Contents 

1.  Introduction 
2.  Energy meter positions within homes in Great Britain 
3.  Safe use of PPM meters and supporting vulnerable customers 
4.  The smart meter rollout will improve customer safety 
5.  Identifying and supporting customers in vulnerable circumstances 
6.  Key actions to improve customer safety 

1. 

Introduction 

This response sets out the background and considerations that Energy UK has taken 
account of in arriving at our recommended actions for addressing incidents where, for 
historic reasons, legacy meters have been installed at height. In particular, smart meters 
can represent a significant step-change in safety, so it is important to explore some of the 
barriers to installing more smart meters and helping customers access the support that 
energy suppliers can provide. 

Energy UK is confident that through working closely with Government, Ofgem and others 
it will be possible to materially reduce the risk that customers might experience from 
engaging directly with their energy meter.  

2. 

Energy meter positions within homes in Great Britain 

While the existing extensive regulatory framework, overseen by Ofgem, should ensure 
that today no supplier is installing new legacy prepayment meters at height, the positions 
of existing meters in buildings today are largely a result of historical decisions. The 
number of homes in Great Britain with electricity supplied increased from 6% in 1919 to 
60% by the end of the 1930s.1 When these energy grid connections and metering 
arrangements were made the choice of location was often chosen to be close to the 
existing energy grid and for ease of connection. This means that many meters were 
installed near or around front doors or on the outside of properties. In some instances, 
these historic location choices did not, and still do not, enable good customer access. 

Since then, further changes to meter locations have been largely uncoordinated. For 
example, some customers have chosen to pay for their energy network to move their 
meters for convenience or aesthetic purposes, whereas others have built around their 
energy meters, for example, installing kitchen units around their meters. Such changes 
can make them harder to access. 

From 2021, for new buildings, guidance from DESNZ (then BEIS) sets out specific non-
binding recommendations for energy meters to be installed such that they can be 
accessed directly.2 There is also now clearer guidance from the various energy networks 

1 The Science Museum (2020) Electrifying: The Story of Lighting Our Homes 
2 DESNZ (2020) Smart meter installations in domestic new build premises 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 outlining the required parameters for a customer choosing a safe location for an energy 
meter placement.3 

Despite this history of uncoordinated and unrecorded meter placements which are outside 
their control, energy suppliers are working to protect the safety of their customers in a 
number of ways. This includes installing smart meters to reduce the amount of direct 
engagement with an energy meter for meter readings. Through smart meters and their 
service offers, energy suppliers have significantly improved the accessibility of meter 
functionality remotely and, therefore, customer safety. 

Some customers who pay by pre-payment meter (PPM) require manual credit updates via 
their meter. For these customers, where a supplier becomes aware that it is not safe and 
reasonably practicable for the customer to pay by prepayment, they must offer to take 
steps such as offering to replace the legacy meter with a smart meter, offering to move the 
customer into credit mode, or offering to move the meter. 

An energy supplier cannot, however, move a customer’s connection to the energy grid 
within the property. The connection to the energy grid is the responsibility of the 
distribution network operator. There may be some flexibility in the vicinity of the existing 
meter location so that the supplier can move a meter, without materially changing the 
connection to the energy grid. Some suppliers have estimated this to be around 1m2 with 
the meter remaining on the same wall. This is likely to be within close proximity to the 
meter board on which the meters are already located. 

Where a customer wants to move a meter a significant distance, this will not always be 
possible to do safely within the space available and based on the guidance provided by 
energy networks, the costs to the customer can be significant, quoted examples start at 
about £1000 and can reach £3500.4  

The movement of meters can also require engagement with multiple parties alongside the 
network operator, supplier and resident. For example, freeholders, landlords and 
neighbours may all need to be involved, with permissions sought depending on the nature 
of the work and the customers’ tenancy.  

3. 

Safe use of PPM meters and supporting vulnerable customers 

In autumn 2023, Ofgem updated its guidance relating to safe use of PPM meters. The 
new Code of Practice5 highlights the steps a supplier is required to take to identify a safe 
and reasonably practicable energy metering arrangement.  

The Code sets clear expectations of suppliers about when it is acceptable to move a 
customer involuntarily to a PPM meter, and it requires high standards for how such 
customers are to be treated. It sets out the customers for whom PPM meters will not be 
safe. It also outlines the steps an energy supplier needs to take in different circumstances 
to establish potential vulnerability, including checking the Priority Services Register (PSR)i 
and other indicators available to an energy supplier across a range of customer 
scenarios.6 The Code sets out the considerations a supplier should make in assessing 
whether a PPM meter is safe and reasonably practicable, where the information is made 
available to energy suppliers.ii As set out above, if a supplier becomes aware that a 
prepayment meter is not safe and reasonably practicable, they must offer to take steps 

3 For example from Cadent, Electricity Northwest, UK Power Networks 
4 For example from Cadent, Electricity Northwest, UK Power Networks 
5 Ofgem (2023) Involuntary Prepayment Meter (PPM) Decision 

 
 
 
 
 
 
 
 
 
 
 
 
 such as offering to replace the legacy meter with a smart meter, offering to move the 
customer into credit mode, or offering to move the meter. 

Since November 2023, energy suppliers are also required to contact their PPM customers 
(taking into account their communication preferences) on an annual basis as a minimum, 
to assess whether PPM remains safe and reasonably practicable. 

Ofgem has also set out new obligations on suppliers to prioritise vulnerable customers 
who need immediate support, including representatives acting on their behalf such as a 
charity.14 Energy suppliers are expected to have processes in place to ensure that 
customers in vulnerable situations find it easier to contact their supplier. The new rules 
mean that customers should be offered various methods of contacting their supplier in a 
clear manner that meets their needs and ensures that they can be reached in a timely 
fashion. 

4.  

The smart meter rollout will improve customer safety  

The smart meter rollout is already replacing legacy, traditional meters addressing the 
safety risk of manual meter readings and manual credit updates. Across all energy 
suppliers, as of September 2023, 33.9 million smart meters have now been installed in UK 
homes and businesses by energy suppliers since 2012.7 

Unlike legacy gas and electric energy meters, which register a running total of energy 
used, smart meters can record half-hourly price and consumption data, as well as 
providing automatic meter readings to energy suppliers. Through a link to a portable 
display (an in-home device), smart meters also give customers real-time information that 
helps them to monitor and reduce consumption and costs. This transparency does not 
require physical interaction with the meter.  

Smart meters in prepay mode can be read or topped up remotely which means they 
require much less direct physical engagement from customers than legacy meters. The 
customer does not need to leave their home to top up their meter, which increases safety 
if the customer has mobility issues or is otherwise unable to leave their home. Further, on 
the portable in-home display which is provided to view spending there is a function to 
manually input credit PPM top-ups. This protects the customer from having to engage 
directly with their energy meters in most instances. 

Energy suppliers in collaboration with the Royal National Institute for the Blind (RNIB) 
have developed an accessible in-home display to allow more customers, including those 
who are blind or partially sighted, to access the benefits of smart metering.8 This device 
that uses braille and lights to boost the accessibility of smart meters. Some vulnerable 
people or those living with disabilities may find that the accessible in-home display meets 
their needs better than a regular in-home display.  

Smart meters also work in both credit and PPM modes (unlike the conventionally distinct 
technologies) and can be changed remotely. This means that if a customer has a 
vulnerability which will make them unable to safely add credit to their meter, such as 
cognitive decline, learning difficulties or mental health and wellbeing challenges it reduces 
both the scope for unsafe engagement with an energy meter and the risk of a period of 
self-disconnection where a top-up is not possible.  

7 DESNZ Q3 2023 Smart Meters Statistics Report 
8 Smart Energy GB (2024) The accessible in-home display 

 
 
 
 
 
 
 
 
 
 
 
 Barriers to the installation of smart meters  

The original ambition of Government was to have a smart meter in every home and 
microbusiness by 2020. However, the optionality of the rollout for customers along with 
operational delivery challenges has limited the number of smart meters in homes. The 
current target set for suppliers is for smart meters would achieve 74.1% of homes by 
2025.  

Challenges to delivering the rollout included the delays in response to the COVID-19 
pandemic when installers were prohibited from visiting customer premises during the first 
lockdown (March to May 2020). Restrictions on installation activity varied until April 2021. 
There are also groups of consumers that are less likely to have smart meters. Survey data 
show that people aged 18 to 24 and people in private rented accommodation are less 
likely to have smart meters installed9.  

Ultimately however, the route to customers having smart meters installed, and thereby 
addressing historic incidents of legacy prepayment meters at height, requires customers 
to accept the offer. Customers may be vulnerable and with existing meter arrangements 
may be made safer by the installation of a smart meter, yet still decide not to accept a 
smart meter. It would not be in the gift of the supplier to install a smart meter, even if the 
existing arrangement is at height, if the household does not choose to accept the offer. To 
illustrate the challenges facing suppliers in the rollout many customers have been 
contacted in excess of 20 times to arrange an installation and have still been 
unsuccessful. 

There are myths about smart meters that are unfounded and are contributing to reducing 
the number of installations. These include health, safety and data protection concerns 
which have been addressed by Government and the regulator in detail.1011 However, they 
remain key reasons why some customers choose not to accept smart meters. 

Energy UK believes that there is, however, scope to increase and prioritise the delivery of 
the smart meter rollout in relation to improving metering safety. The rollout is a complex 
challenge, and one in which suppliers have invested heavily. Any prioritisation within the 
rollout would require careful design to ensure it was appropriately targeted and did not 
result in competitive distortions. However, through working with the Government, it is our 
view that there is scope for policy changes that will improve safety by speeding up key 
elements of the smart transition.  

In particular we think there is potential for greater clarity on what should be done in 
situations where for historic reasons a legacy prepayment meter has been placed at 
height, but a customer refuses a smart meter and is unwilling or unable to move the 
location of their meter but wants to continue paying by prepayment. 

5. 

Identifying and supporting customers in vulnerable circumstances    

Smart meters and connected technologies via the internet make it easier for suppliers to 
understand customer circumstances and identify potential vulnerabilities. However, the 
main and most effective way for suppliers to respond to a customer’s needs is via a 
disclosure process led by the customer.  

The energy sector is committed to continually improving service for all customers, 
particularly those in the most need. Energy UK’s independently-chaired Vulnerability 

9 NAO (2023) Update on the rollout of smart meters summary 
10 Public Health England (2023) guidance on smart meters and radio waves and health 
11 BEIS (2017) Review of the Data Access and Privacy Framework 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 Commitment12 was established in 2019, and has been developed in consultation with 
energy suppliers, consumer and charity groups, and the energy regulator, with input from 
customers themselves to support people in vulnerable circumstances over and above 
existing regulations. The Vulnerability Commitment is open to all energy suppliers and 
aims to drive continuous improvement based on three key principles: Accessibility, 
Collaboration and Innovation. 

It is independently chaired and scrutinised; each year an expert panel assesses each 
supplier’s performance against the Vulnerability Commitment. 

13 suppliers which in total supply energy to around 90% of UK homes are currently signed 
up to the Vulnerability Commitment. It includes a number of provisions that signatories 
have to meet – from providing a range of channels of communication that are suitable and 
appropriate for a customer's needs to offering a free phone number that can be given to 
customers in financial hardship where appropriate, as well as taking all reasonable steps 
to design relevant customer communications and processes in a manner that supports 
customers to feel comfortable disclosing vulnerabilities.  

Energy suppliers are also expected to offer relevant and updated training to their front-line 
staff on how to look for signs of vulnerability. The Commitment ensures that signatories 
are showing innovative ways to improve their services for vulnerable customers.  

Energy suppliers are also working with support of Ofgem to update the legal basis that 
underpins how they collect and share data about customers on their Priority Service 
Register (PSR). If PSR data is collected and stored under conditions that are recognised 
for ‘Substantial Public Interest’ it can also be shared with water companies and network 
operators, and can give customers a more holistic, improved and tailored package of 
support from utilities providers. It also significantly increases the likelihood of identifying 
vulnerable customers through cross-industry data sharing. 

The Government is also interested in improving the way that people can sign up for the 
PSR across all regulated utilities, with a to a ‘tell us once’ approach to data sharing. 
Energy UK and our members are supporting these initiatives that will give customers more 
control and transparency when it comes to sharing their data. As an industry, we are keen 
to explore further with Government and Ofgem what can be achieved through better join 
up of the roles of data controller and market designer, for example utilising Government 
data to improve the PSR and the ability of suppliers to identify vulnerabilities proactively 
and target social policy interventions (including improving safety, but also others) without 
relying so heavily on the current format of customer disclosure. 

Barriers to identifying and supporting customers in vulnerable circumstances  

Customer engagement and willingness to share personal (often sensitive) information is a 
significant barrier to progress. Energy suppliers have worked hard to go above the 
minimum obligations set out in the licence conditions, sharing best practice and working 
closely with charities and consumer groups.  

However, it is important to note that ensuring that the meter location is safe will continue 
to be significantly dependent on energy suppliers having access to better, more in-depth 
information about their customers’ circumstances and needs. For a significant proportion 
of customers with traditional PPM meters, energy suppliers have little to no information on 
their circumstances provided by the customer.  

12 Energy UK (2023) Vulnerability Commitment 

 
 
 
 
 
 
 
 
 
 
 
 6.   

Key actions to improve customer safety 

We have, therefore, identified three key actions that we believe have the potential to drive 
improvements and tackle historic meter placement issues further and faster. To maximise 
impact, these actions will require collaboration with a wide set of stakeholders. We will 
continue to work with Ofgem and DESNZ the Department for Levelling Up, Housing and 
Communities (DLUHC), and with colleagues from charities and consumer groups to 
reduce risks in the future. 

•  Action 1. Raise customer awareness of safety issues. Energy UK will work 

with consumer groups, including Citizens Advice (the statutory energy advocate) 
and Smart Energy GB (the communications body for the smart meter rollout) to 
further promote the existing guidance for customers on meter safety and 
emphasise the importance of customers contacting their suppliers if they have 
concerns. This will also explain the support that is available.   

•  Action 2: Improve support for vulnerable customers with their energy 

meters. Energy UK will convene workshops with energy suppliers and other 
stakeholders (including energy networks, Ofgem, the Government, the housing 
sector and customer groups) to examine the current customer journey, and gain a 
better understanding of how to: 

- 
- 
- 

identify customers who need support;  
deliver safety focused interventions; and 
improve data sharing to further support the identification of vulnerable 
customers.   

We will also continue to work with stakeholders to improve how we can share 
data about customers in vulnerable circumstances, to help target support and 
improve safety. 

•  Action 3: Accelerate the transition from legacy meters to smart 

meters. Smart meters offer significant scope to reduce many of the safety risks 
associated with inaccessible meter placement. They can greatly reduce the 
physical interaction a customer has with their meter. We will continue to work 
with Government and Ofgem to ensure that the smart meter programme is 
delivered, and that we have the right policy framework to ensure continued 
progress on replacing legacy meters, particularly traditional PPM meters. This 
could involve working with Smart Energy GB, Ofgem, Government and others 
 to consider ways to ensure social housing and privately rented properties are not 
left behind in the transition to smart.   

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 i Ofgem (2023) PPM Guidance (Safe and Reasonably Practicable) The steps that suppliers are required to take in certain 
instances to ascertain if a prepayment meter is reasonably practical 

•  Recording the location of the meter when installed or inspected; 
•  Reviewing appropriate notes on the customer’s accounts to ascertain whether any vulnerability which means it is 

not safe and reasonably practicable for the customer to have a PPM is recorded; 

•  Making multiple attempts to contact the customer by various means and at various times of day to discuss the 

option of paying through a PPM;   

•  Where a discussion with the customer had not been possible or if, following discussion, there was still uncertainty 

about whether it would be safe and reasonably practicable for the customer to pay through a PPM, the supplier 
should take reasonable steps to visit the customer at their premises, which could include making visits at various 
times of day    
Checking whether there has been a change of occupancy; 

• 
•  Attempting to check with any appropriate advice or other agency such as local authority or housing association; 

and 

•  Obtaining authorisation of an appropriate seniority prior to moving a customer to a PPM. 

ii Ibid. The information an energy supplier should consider with regards safe and reasonable practical includes: 

a)  Whether the customer is able to understand and operate the PPM and visit top-up points (where needed) to add 

more credit. (For example, whether the customer has a physical or mental disability that prevents them from being 
able to appropriately use a PPM).   

b)  Whether the customer lives quite a distance from any top-up outlets (This may not apply if a customer does not 
want or need to top up by cash, and has actively asked to pay by alternative top-up methods, but consideration 
must be given to instances of technical issues with smart PPM in particular in relation to top-up being required 
manually in case the smart functionality of the meter fails). What constitutes ‘quite a distance’ is likely to vary 
depending on the customer’s circumstances. For example, it may not be reasonably practicable to provide a PPM 
meter if a Domestic Customer needs to travel over two miles to top up the credit and does not have a car).   

c)  Whether the customer requires a continuous supply for health reasons, such as dependency on medical equipment 

requiring an electricity supply.   

d)  Whether the PPM is situated in a position (such as high on a wall) that means the customer could not operate the 

PPM.   

e)  Whether the PPM would have to be situated outside or in a room to which the household does not have continuous 

access.  

f)  Any advice/guidance received from the Health and Safety Executive (HSE). 

DESNZ Q3 2023 Smart Meters Statistics Report