Three regulatory moments shape supplier exposure between now and the end of 2026. None of them is unexpected. All of them will produce winners and losers based less on technology choice than on assurance posture.
The Debt Relief Scheme operational review.
The £500m Debt Relief Scheme, launching early 2026, will be reviewed in operation. The questions Ofgem will ask are predictable: how were customers identified, how was eligibility assessed, how were vulnerable cohorts protected, how were decisions evidenced. Suppliers that have AI in any part of that chain — eligibility scoring, prioritisation, contact selection, affordability classification — will be expected to evidence assured AI use. Suppliers that cannot will not lose the right to participate; they will lose the right to be trusted with the next iteration.
The next Consumer Standards review.
Consumer Standards reviews tend to focus on outcomes — fairness, vulnerability protection, complaints handling — and tend to ask, increasingly, what role automated decisions play in those outcomes. The AIIA is the document that answers that question without requiring an audit. Suppliers that have one will be in the conversation. Suppliers that do not will be in remediation.
The MHHS readiness checkpoints.
MHHS readiness reviews are not framed as AI governance reviews, but the data-handling, anomaly-detection and customer-impact questions inside them effectively are. Suppliers that have folded AI assurance into their MHHS programme will pass without comment. Suppliers that have not will be asked, in writing, why the volume of AI-mediated decisions has expanded faster than the governance around them.