Proposal 17 – Ensuring that consumer protections are fit for purpose

1 December 2019

Government and Ofgem to take the lead on consumer protections for all aspects of the EV customer journey.

Consumer interactions with EVs and smart charging cuts across a range of sectors, from tightly regulated established sectors to new, largely unregulated ones. This means that many EV services are currently only covered by general consumer law, which brings a risk of consumer detriment as the roles and responsibilities in the sector evolve. 

To understand exactly if and where further intervention is needed – both now and in the future – a thorough review of the consumer protections relating to smart charging and EV services must be undertaken. 

Consideration should be given to the following points:

• The review should include a function mapping exercise, charting the roles and functions of each type of company involved in the EV customer journey, in order to identify whether consumers require further protection;
• The review will need to consider future roles that companies may play, alongside current ones;
• Particular consideration needs to be given to consumers in vulnerable circumstances;
• Existing work programmes that are looking at consumer protections (such as the Future Energy Retail Market Review which is looking at aspects of home charging) will need to be integrated; and
• The review should be launched in 2020 and be finalised by the end of 2021 at the latest, allowing enough time to undertake a detailed, in-depth review while ensuring that it is done in a timely manner.