Citizens Advice response to Ofgem’s consultation on consequential licence modifications in the event the UK leaves the EU without a deal
The proposals are focused on clarifying existing definitions and on removing cross-references to EU legislation and EU bodies that will no longer be relevant.
These technical adjustments should, however, also be assessed in the context of the overall legal framework for the UK’s withdrawal from the EU:
Where Ofgem takes action to maintain alignment with the EU internal energy market, GB stakeholder engagement should be structured to ensure that insights are fed into the initial policy design as early as possible.
A holistic approach is particularly important for policies with direct consumer impact, such as the management of smart meter data and the thresholds for industrial emissions.