The Standard Licence Conditions on third-party intermediaries are not new. SLC 20.5 for electricity and SLC 20.6 for gas already restrict suppliers, in the microbusiness segment, to engaging only with brokers who are signed up to a qualifying alternative dispute resolution scheme. SLC 27.8A flows obligations down the chain: when a TPI acts on the supplier's behalf, the supplier remains accountable for the outcome. What is new is that the AI tools your brokers use are now an unavoidable part of that outcome.
What changes between now and the end of 2026.
Three things. The voluntary Ofgem TPI Code, administered by the Retail Energy Code Company, is on track to become statutory; suppliers will be expected to engage only with authorised TPIs and to demonstrate that their on-panel brokers meet the licence standard. The microbusiness fee-transparency requirements continue to bite, and Ofgem rejected REC modification R0137 in May 2025 in a way that signalled little tolerance for further softening. And the regulator's interest in AI-mediated outcomes — already visible in Consumer Standards casework — will reach the broker channel because that is where a meaningful share of SME and microbusiness contracts are actually decided.
What this means for the panel review you are about to run.
Your next TPI panel review needs three things it probably did not have last year. A list of every material AI tool each on-panel broker uses in the customer journey — quote engine, proposal generator, voice agent, affordability heuristic, CRM ranker. A statement, signed by the TPI, that those tools have been impact-assessed and that human review exists for adverse outcomes. And evidence that the broker is testing its tools against your published Code of Practice as well as the Ofgem TPI Code. None of this is exotic. It is the same discipline you already apply to your own AI — simply extended to the channel that handles your customers on your behalf.
Where Probari sits in this.
Probari treats RECCo, the Ofgem SLCs, the consultation on TPI authorisation and your own published Codes of Practice as the regulatory surface its agents check. Not as a static reference — as a live one. When a TPI's AI tool is added to a panel, the assurance evidence is captured against every code body that applies; when a code changes, the assessment is re-run. The supplier sees the same evidence chain for the broker channel that it sees for its own AI. The regulator, when it asks, sees one answer rather than two.