Supplier Performance Report: January to June 2025

Key Take Aways

1. The Supplier Performance Report (SPR) provides biannual transparency on suppliers’ compliance within UK low-carbon energy and social schemes, crucial for understanding sector risks and performance.
2. Despite a 40% reduction in ‘Major’ non-compliance incidents from the previous period, 41 such incidents remain, indicating ongoing risks for systemic compliance issues.
3. The most criticised suppliers include Foxglove Energy, Octopus Energy, Rebel Energy, Square 1 Energy, and Utilita Energy, which continue to feature prominently in non-compliance metrics.
4. Scheme engagement issues dominate the causes of major incidents (66%), highlighting administrative lapses as a core concern for sector risk management.
5. Payment-related non-compliances comprise 20% of major incidents, with late payments and incorrect bank account payments being persistent issues needing tight financial controls.
6. The Green Gas Levy (GGL) spotlight shows that non-compliance, such as late payments and data submissions, remains prevalent, with operator errors impacting scheme efficiency and value for money.
7. Data accuracy issues, especially in FIT scheme CFR submissions, continue to be significant, affecting the integrity of scheme calculations and market transparency.
8. Suppliers exhibiting high volumes of minor non-compliances, notably Good Energy and OVO, suggest a pattern of recurring governance weaknesses, risking larger compliance failures.
9. Audit findings indicate that errors in data provision and administrative failures are the primary cause of non-compliance, underscoring the importance of internal control robustness.
10. The report signals a potential enforcement trajectory — escalating cases with persistent or serious failures could lead to penalties or licence revocations, tightening sector oversight.
11. The sector has demonstrated improvements, notably in the reduction of major incidents, yet the rate of non-compliance remains substantial and resilient, demanding ongoing regulatory vigilance.
12. The evolution of the SPR aims to provide clearer insights and enhanced oversight, linking compliance to broader risks and the sector’s capacity to deliver public value on decarbonisation and social schemes.

Key Statistics

• 41 ‘Major’ non-compliance incidents recorded during January-June 2025, down nearly 40% from 68 in the previous equivalent period.
• Among suppliers, Foxglove Energy led with 5 ‘Major’ incidents; Octopus Energy and Rebel Energy each recorded 3 incidents.
• Data issues account for 81% of non-compliance sources, scheme engagement for 13%, payment issues for 5%, and audit findings for 1%.
• Major incidents related to scheme engagement comprise 66% of total major non-compliances; payment issues 20%, and data issues 15%.
• Cross-scheme data non-compliances include 73 incidents, with 52 on FIT, 10 on ECO, 8 on RO, 2 on GGL, and 1 on SEG schemes.
• The top 5 suppliers responsible for ‘Minor’ incidents include Good Energy (25), OVO (20), British Gas (19), E.ON Next (14), and Scottish Power (13).
• Major ‘Major’ incidents since July 2023 show GGL with 64 incidents, GBIS with 39, and RO with 31, indicating scheme-specific vulnerabilities.
• 15 suppliers failed to confirm meter point data in the GGL scheme between January-June 2025, showing ongoing data submission challenges.
• 11 payment non-compliances occurred, with 55% on GGL and 45% on FIT, mainly involving missed deadlines or wrong bank payments.
• 33 scheme engagement violations were recorded, mostly relating to failure to meet obligations or missed deadlines.
• Audit non-compliances, all on ECO, primarily involve failing to provide accurate information or administrative errors.
• Overall incidents decreased by 4.3% compared to the previous year, yet total non-compliances remain high, signalling persistent systemic issues.

Key Discussion Points

• The significance of transparency through the SPR in identifying sector-wide compliance risks to inform financial and operational decision-making.
• The continued high prevalence of scheme engagement failures points to deficiencies in governance and administrative controls.
• Payment delinquency and incorrect bank payments underscoring the importance of financial controls and real-time monitoring for operational risk mitigation.
• The ongoing challenges with data accuracy, especially within FIT CFR submissions, highlight vulnerabilities in internal data governance frameworks.
• The importance of supplier engagement and the risk posed by recurring minor non-compliances, particularly among longstanding offenders like Good Energy and OVO.
• The potential for enforcement actions, including fines or licence revocations, following persistent or serious non-compliance patterns.
• The sector’s progress in reducing Major incidents, yet the remaining volume indicates a need for targeted improvements, particularly in scheme-specific operations.
• How non-compliance in the GGL scheme, such as late payments and data errors, affect scheme integrity and taxpayer/value for money.
• The critical role of internal controls and compliance oversight in managing high-volume data submissions and cross-scheme administration.
• The impact of audit findings on supplier reputations and the potential for wider financial or operational repercussions.
• The strategic importance of continuous regulatory engagement and robust enforcement to uphold public trust in decarbonisation and social programmes.
• The overarching need for an integrated compliance framework aligning regulatory expectations with operational controls to mitigate sector risks.

Document Description

This article is an in-depth review of Ofgem’s semi-annual Supplier Performance Report for January to June 2025. It provides comprehensive insights into supplier compliance performance within UK low-carbon energy and social schemes, highlighting recent trends, key risks, and areas for regulatory attention. The report evaluates the incidence and causes of non-compliance, identifies the most problematic suppliers, and discusses ongoing regulatory and enforcement strategies. Central to this article is the focus on operational risks, compliance governance, and the implications for sector stability and public value delivery, especially in the context of decarbonisation efforts.