Around 2,700 Third Party Intermediaries operate in the GB non-domestic energy market. Roughly fifty have signed the Ofgem TPI Code of Practice. That arithmetic — less than two per cent voluntary coverage — is the reason the Government published its consultation on regulating TPIs in October 2025. The consultation is not a discussion of whether to regulate. It is a discussion of how, and how fast.
From voluntary code to statutory licence.
The Retail Energy Code Company — RECCo — administers the TPI Code on behalf of Ofgem. The Code sets seven principles: transparency, clear pricing, fair treatment, dispute resolution, data protection, staff training and compliance. They are sensible. They are also unenforceable against a TPI that has not signed up. The proposal in front of Government is to convert those principles into Standard Licence Conditions, with Ofgem as the statutory regulator and a general authorisation regime that every TPI of any meaningful scale will need to sit inside. The sunrise period being discussed is twelve to eighteen months. That is shorter than most brokers' sales-cycle plans.
What "AI tools come with you" means in practice.
If your brokerage uses an AI quote engine, an AI proposal generator, an AI handler for inbound enquiries, an AI affordability heuristic for SME customers, or an AI-driven CRM that decides which prospect gets called next, that system will need to be evidenced. Not the marketing claim about it. The actual decision logic, the data it uses, the boundaries it respects, the human review it triggers, and the customer outcomes it produces. The same evidence a regulated supplier already has to keep for its in-house AI is the evidence Ofgem will expect from a TPI under licence. The difference is that suppliers have had three years to get ready. Most TPIs have not started.
What you can do in the next ninety days.
Three steps, in order. Map every AI tool you use that touches a customer outcome — quote, contract, complaint, switch, renewal. Write a one-page impact assessment for each: what it decides, what data it uses, what could go wrong, what the human override is. Then check your tools against the seven principles of the existing TPI Code and against your supplier partners' published Codes of Practice; if a tool fails on transparency, fair treatment or data protection today, it will fail under licence tomorrow. The brokers that arrive at the start of the sunrise period with that work already done will be the brokers that suppliers actually want to keep on panel.