FEBRUARY 2024
Non-Domestic Market Review
Ofgem publishes the impact assessment recommending statutory regulation of TPIs and tighter Standards of Conduct for non-domestic supply.
FOR GB ENERGY BROKERS & TPIs
Get authorisation-ready before Ofgem starts the clock.
Ofgem will become the regulator of Third Party Intermediaries (TPIs) — energy brokers and consultants who buy on behalf of business customers — in the GB non-domestic energy market under a hybrid authorisation regime confirmed in October 2025. The phase-in window will be twelve to eighteen months once legislation lands. Probari builds your registration evidence, your Standards of Conduct log, your fee transparency record and your complaints process now — so authorisation is a paperwork day, not a project.
FOR COMPLIANCE OFFICERS · COMMERCIAL DIRECTORS · MANAGING DIRECTORS
WHY THIS MATTERS NOW
Authorisation is no longer a question of if.
The October 2025 government response confirmed a hybrid model: Ofgem-led authorisation built on the existing voluntary Code of Practice, with a phase-in window to bring incumbents in. Brokers who have operated under light-touch self-regulation will need to evidence conduct, fee transparency, complaints handling and ongoing supervision in a way most operations have never produced.
The cost of a late start is not the application fee. It is the eight to twelve months of back-filling conduct records, redress scheme membership, fee-disclosure logs and complaints data — while the sales team is still trying to hit number. Probari was built so that work runs in the background of the business, not on top of it.
THE OFGEM TIMELINE
Where the regime is, and where it goes next.
APRIL 2024
Complaints Handling Standards
Ofgem CHS extended to non-domestic complaints. Energy Ombudsman membership and the QDSS — the Qualifying Dispute Settlement Scheme, the redress route customers go to if they cannot resolve a complaint with the broker direct — become the operating standard for brokers handling SME accounts.
JULY 2024
Standards of Conduct expansion
Non-domestic Standards of Conduct broadened to cover micro and small business customers, with explicit requirements on suppliers' use of brokers.
OCTOBER 2024
Broker fee transparency
Suppliers required to disclose broker uplifts on customer bills. Brokers must surface fee structure to customers and to suppliers in an auditable form.
OCTOBER 2025
Hybrid authorisation confirmed
Government response confirms Ofgem will run TPI authorisation, anchored on the voluntary Code of Practice, with a market survey in H1 2026 to inform the formal principles.
2026 — NOW
Build the evidence base
Quiet window. Ofgem is consulting; legislation has not landed. The brokers who use this period to stand up authorisation evidence will pass through the phase-in window without a fire drill.
12–18 MONTHS AFTER LEGISLATION
Phase-in window closes
Operating without authorisation becomes prohibited. Suppliers will only deal with authorised brokers. Acquirers will only buy authorised brokers.
WHAT AUTHORISATION WILL REQUIRE
Seven evidence streams. One platform.
01
UK GDPR & DPA 2018
Lawful basis, data minimisation, retention and SAR readiness across customer-acquisition data flows.
02
OFGEM TPI AUTHORISATION
Registration evidence aligned to the October 2025 hybrid regime for Third Party Intermediary (TPI) authorisation, ready for the formal Ofgem principles when published.
03
STANDARDS OF CONDUCT
Conduct log against the July 2024 non-domestic standards — fair treatment, clear information, complaints, vulnerability.
04
FEE TRANSPARENCY
Auditable fee-disclosure record per contract — what was disclosed, to whom, when, in what form.
05
QDSS REDRESS MEMBERSHIP
Energy Ombudsman membership evidence and the operational records the QDSS (Qualifying Dispute Settlement Scheme) requires from brokers.
06
CHS NON-DOMESTIC
Complaints handling against the Ofgem CHS — one working day flag, eight-week resolution clock, ADR ninety-day cap.
07
UIA CODE OF PRACTICE
Five-day acknowledgement standard and the conduct principles the existing voluntary code requires.
HOW PROBARI DELIVERS
A single tenant, configured for the brokerage regime.
Probari ships the GB Brokerage profile as a self-contained tenant. Every framework above is mapped to controls, every control is tied to evidence, and every evidence item carries an author, a citation and a timestamp. The MeridianTPI Ltd reference deployment is live in the demo environment.
DESIGN
Use case & conduct intake
Onboard each commercial use case — tariff recommendation, supplier matching, customer-acquisition models — through the intake wizard. Risk tier automatically graded; conduct obligations attached at design time.
- Tariff Recommendation Engine reference use case
- Standards of Conduct mapped at intake
- Owner, lawful basis, decision affected captured
ASSESS
AIIA & conduct assessment
Forty-seven-question AI Impact Assessment (AIIA) plus a conduct supplement covering fee disclosure, vulnerability handling and complaints triage. Perplexity Sonar-assisted drafting; full citation chain.
- AIIA template with TPI conduct overlay
- Citation chain to Ofgem source documents
- Sign-off log per use case
ASSURE
Authorisation evidence pack
Controls mapped across the seven brokerage frameworks. Evidence pack exportable as a single bundle for supplier due diligence, Ofgem authorisation, ombudsman queries or acquirer data rooms.
- Seven-framework crosswalk
- Evidence pack export
- Supplier-ready authorisation file
OPERATE
Live conduct & complaints record
Operational signals against the conduct baseline. Complaints flagged within one working day, eight-week resolution clock managed in-platform, drift in customer outcomes triggers reassessment.
- One-day flag, eight-week clock
- UIA five-day acknowledgement standard
- Reassessment queue
WHO IT IS FOR
Three buyers. One product.
FOR COMPLIANCE OFFICERS
Authorisation, ready on day one.
Probari builds authorisation evidence as the business runs, not in a dedicated workstream. When Ofgem asks, the pack is ready.
FOR COMMERCIAL DIRECTORS
Supplier panels, kept open.
Suppliers are already tightening broker due diligence ahead of authorisation. Probari gives you a single bundle to send — fee transparency, conduct log, complaints record, redress evidence.
FOR MANAGING DIRECTORS
Sale-ready, audit-ready.
Brokerage M&A is active. Acquirers will pay a premium for clean conduct evidence and a discount for messy paperwork. Probari produces the data room without a special project.
THE PILOT
Six weeks. One use case. A live evidence pack.
WEEK 01
Tenant stand-up
GB Brokerage tenant configured for your firm. Admin and viewer accounts provisioned. Reference use case loaded as a working template.
WEEKS 02–03
Live use case
One real commercial use case — tariff recommendation, supplier matching or customer-acquisition model — taken through intake, AIIA and control mapping with your team.
WEEKS 04–05
Conduct & complaints overlay
Standards of Conduct log, fee transparency record and complaints process configured and populated against the live business. UIA and CHS clocks operating.
WEEK 06
Authorisation evidence pack
Exportable evidence bundle covering all seven frameworks. Walk-through with the compliance lead, commercial director and (where relevant) the firm's M&A advisor.
Pilot pricing is available on application. The pilot tenant is yours to keep — there is no rebuild between pilot and production.
Book a 30-minute call.
Probari is founded and designed by Ian Curran. If you are a Compliance Officer, Commercial Director or Managing Director at a GB energy brokerage, get in touch — we will book the call within five working days and walk you through the live MeridianTPI reference deployment.
Request a briefingOr write directly to info@probari.uk