Energy consumers: ministerial meetings minutes - November 2025

Attendees and apologies

• Gillian Martin MSP, Cabinet Secretary for Climate Action and Energy (Chair)
• Richard Lochhead MSP, Minister for Business and Employment (Co-Chair)
• Stacey Dingwall, Head of Policy and External Affairs, Federation of Small Businesses
• Doreen Reid, Energy Transition Team Leader for Heat, Scottish Enterprise
• Keith Masson, Head of Net Zero Transition, Highlands and Islands Enterprise
• Georgina Hines, Public Affairs Manager, Smart Energy GB
• Christina Panayiotou, Head of Specialist Audiences, Smart Energy GB
• Ken Cronin, Chief Executive Officer, UK and Ireland Fuel Distributors Association
• Paul Redmayne, Senior Policy Advisor Non-Domestic Retail Policy, Ofgem
• Daniel Parr, Head of Business Energy, Scottish Power
• Rhona Peat, Head of Retail Regulation, Scottish Power
• Craig Wilson, Policy and Public Affairs Manager, Energy Ombudsman
• Dena Barasi, Head of Policy, Regulation and Advocacy – External Affairs, EON
• Michelle Ferguson, Scotland Director, Confederation of British Industry
• Gareth Williams, Head of Policy, Prosper
• Kevin Dickson, Energy Development Specialist, South of Scotland Enterprise
• Sam Ghibaldan, Chief Executive Officer, Consumer Scotland
• John McFarlane, Head of Policy, Insight and Engagement, Advice Direct Scotland
• Beth Mukushi, Head of Programme Delivery, Home and Business Energy Scotland, Energy Savings Trust
• Jon Dixon, Energy Regulation and Governance Expert, Retail Energy Code Company
• Suchitra Hammond, Senior Strategy Manger, Retail Energy Code Company
• Ned Hammond, Deputy Director, Customers, Energy UK
• Baiba Delvere, Head of Regulation, Octopus
• Jessica Niven, Interim Deputy Director of Heat in Buildings and Policy Regulation Division, Scottish Government
• Jake MacDonald, Consumer Policy Team Leader, Scottish Government
• Lucia Ramon Mateo, Senior Policy Officer, Scottish Government
• Jack Buckley, Policy Officer, Scottish Government

Items and actions

Welcome, introductions and scene setting

Gillian Martin MSP, Cabinet Secretary for Climate Action and Energy, welcomed attendees to the roundtable and thanked stakeholders for working with officials on the issues faced by non-domestic consumers.

Attendees discussed issues around third party intermediaries (TPIs) and energy brokers; lower non-domestic smart meter uptake; and energy literacy and consumer advice for businesses and third sector organisations. 

Third-party intermediaries (TPIs) and energy brokers

Jon Dixon, Energy Regulation and Governance Expert at the Retail Energy Code Company (RECCo), provided an overview of the work that RECCo has undertaken on their voluntary code of practice for TPIs and the importance of securing improvements to the market now, recognising the time needed to pass legislation. 

Participants made the following observations:

• dissatisfaction with TPIs is higher in the energy sector compared to other sectors. Giving Ofgem regulatory power through legislation is essential but, in the interim, measures such as improved signposting are required
• small business face significant challenges, including high energy bills, that affect business sustainability and economic growth. Unfair contracts weaken their ability to take on new staff and pay wages, and better support would help small businesses navigate the market and bring down energy costs 
• small businesses should be afforded the same consumer protections as domestic customers. Currently there is no price cap, no cooling off period, no debt assignment protocol, and limited standards
• while legislation is developed, suppliers could and should proactively deliver improved internal standards and requirements to ensure they only work with reliable and trusted TPIs. Action could include setting limits on commission paid, for example
• the Energy Ombudsman already provides redress to consumers who have experienced difficulty with TPIs, and the number of complaints has increased significantly. The Ombudsman should ensure this evidence is shared with those developing the legislation and regulation

Scottish Government will work with stakeholders to identify what immediate action can be progressed while engaging with UK Government and Ofgem on the necessary regulatory and legislative changes.

Smart meters

Christina Panayiotou, Head of Specialist Audiences at Smart Energy GB, provided an update on work to engage small businesses on the benefits of having a smart meter.

Participants made the following observations:

• improvements have been made by some suppliers on the flexibility of installation to work around business needs. However, there are still practical barriers to having a smart meter installed for some organisations and suppliers should proactively work with businesses to develop solutions, including securing landlord agreement and addressing the need for constant energy in some premises
• geographical barriers remain, particularly for rural and island areas where uptake is very low and there are connectivity issues. This limits small businesses ability to proactively manage their energy and access other sources of clean energy. Suppliers and the DCC should work proactively to ensure all parts of Scotland are able to access the benefits of a fully functioning smart meter
• industry needs to recognise the different needs for domestic and non-domestic consumers, including through nuanced marketing campaigns. There are significant differences between sectors and a one size fits all approach will not work. Messaging should be tailored to specific sectors

Smart Energy GB should work with business and consumer organisations to ensure that messaging is tailored and clearly articulates why a smart meter will benefit the various sectors that make up non-domestic consumers. 

Energy literacy and consumer advice

The Cabinet Secretary asked participants to consider how consumer organisations can be more accessible to businesses and third sector organisations.

Participants made the following observations

• a single portal, where non-domestic consumers can access all advice and relevant guidance, would constitute a considerable improvement. Small businesses are time poor and cannot spend time reviewing multiple websites
• Business Energy Scotland (BES) has a strong offering of advice on energy efficiency and renewable energy, and could make a significant impact if their remit and resource was to be reviewed
• redress is a key pillar alongside advice and advocacy. Currently the number of complaints is increasing but this is only for businesses up to 50 employees. UK Government should give consideration to expanding the remit of the Energy Ombudsman to provide more support for small businesses.
• micro and small businesses often behave like domestic consumers and have the same level of knowledge regarding the energy market. It is vital that advice is easily accessible to them due to complex nature of the market

Scottish Government will engage with Consumer Scotland, Ofgem, and consumer organisations to ensure that Scottish businesses are included in their Energy Aware campaign and work with consumer organisations to improve energy literacy. 

Close

The Cabinet Secretary thanked participants for their contributions and closed the meeting.