An energy supplier has legal routes that a credit-card company simply does not, which is why energy arrears sit near the top of every priority-debt list in the UK. Even so, the supplier can only reach for those routes if it follows the Ofgem Standard Licence Conditions and, for entry to your home, the Rights of Entry (Gas and Electricity Boards) Act 1954, and every step in that process has a limit written into it.
This page covers domestic energy customers in England, Wales, and Scotland. It is general information about how the rules work, not personal financial advice or regulated debt advice.
Quick answer
Energy is a priority debt because your supplier has legal routes credit-card companies do not. It can still only pursue you through a fixed set of steps set out in the Ofgem Standard Licence Conditions and, for entry to your home, the Rights of Entry (Gas and Electricity Boards) Act 1954. Every step has a rule that limits it, and most of those rules are missing from the letters suppliers send. This guide walks you through the map, section by section, so you know exactly which door your supplier is trying to open and what it is not allowed to do while opening it.
Why energy is a priority debt (and what that actually means for your bill)
The label matters because it sets the order you should pay things in. Missing a credit-card payment is bad for your credit file. Missing an energy payment can end with a supplier applying to a magistrate for entry to your home. That is a different weight of consequence, and it is why Ofgem puts stricter rules on energy suppliers than the FCA puts on lenders.
Priority debts sit above non-priority ones on any sensible payment plan. Rent or mortgage, council tax, and energy come first because losing any of the three has consequences that go past your credit score. Credit cards, catalogues, overdrafts, and personal loans wait behind them. If you are behind on both, deal with the priority side first. There is a longer piece on how to hold non-priority creditors off while you do that in the token payments article.
What your supplier can legally do (and the rule that limits each step)
There are five routes a supplier can use against a domestic customer in arrears. Each one comes with a rule that suppliers rarely mention.
| Route | Rule that limits it | What that means for you |
|---|---|---|
| Letters, fees, and a repayment-plan offer | SLC 27A: repayment plan must be based on ability to pay | You can push back on any figure that ignores your Budget Planner numbers. |
| Sell the debt to a debt collector | FCA CONC applies to the buyer; supplier remains bound by SLC | A sale does not delete supplier obligations, and the buyer must follow CONC rules on communication and forbearance. |
| Apply for a warrant of entry | Rights of Entry Act 1954 s.2: 24 hours notice, 28-day expiry | The warrant window is narrow and time-bound. Miss either limit and the entry is unlawful. |
| Switch you to prepayment, physically or by smart-meter mode change | SLC 28 (Debt Trigger, Site Welfare Visit, Do Not Install list) | Every remote switch counts as an involuntary PPM. All the same protections apply. |
| Take you to the county court for a CCJ | Civil Procedure Rules and pre-action protocols | Rare for smaller balances, but real for larger ones. See the CCJ guide. |
The Debt Trigger, defined in the licence
Ofgem SLC (verbatim)
“Debt Trigger means, in relation to a Domestic Customer, the point in time at which: (a) that Domestic Customer has been in Outstanding Charges for a period of at least three months; (b) the value of the Outstanding Charges exceeds the value specified in SLC 28.4; and (c) no repayment arrangement is in place, and no other transition arrangement applies.”
Ofgem, Electricity Supply Standard Consolidated Licence Conditions, SLC 28.21 (definitions). ofgem.gov.uk
Three tests, all needed. If any one is missing, the Debt Trigger is not met and an involuntary prepayment meter route is not open to your supplier. That includes if you have a repayment plan on the account, even a modest one, and even if you are behind on that plan.
What your supplier legally cannot do
The rules on prohibitions are shorter, sharper, and more useful in a live dispute than the ones on process.
In plain English: There is a list of situations where an involuntary PPM is banned outright, a rule that stops the supplier passing warrant costs to a vulnerable customer, and a principle that requires the supplier to assume hardship rather than wait for you to prove it.
Ofgem Involuntary PPM Guidance (verbatim)
“Suppliers must not install an involuntary PPM in premises where: there is a household member reliant on powered medical equipment or a careline; there is a household member with an illness where warmth is essential; there is a household member aged 75 or over without additional support in the household; there is a household member aged 85 or over; there are children aged under 2; or there is a household member with a serious medical condition including cancer, chronic obstructive pulmonary disease, cardiovascular disease, or organ failure.”
Ofgem, Involuntary PPM Decision, Section 3.7, September 2023. ofgem.gov.uk
If anyone in your home fits any of the categories above, put that in writing to your supplier as soon as possible and ask for it to be recorded against the account. Register on the Priority Services Register as well. Both matter if the case ever reaches a magistrate.
Ofgem SLC (verbatim)
“The Licensee must not seek to recover from the Domestic Customer any costs associated with a Warrant of Entry, including court costs, locksmith costs, and installation costs, where the Domestic Customer is in a Vulnerable Situation.”
Ofgem, Electricity Supply Standard Consolidated Licence Conditions, SLC 28.11. ofgem.gov.uk
Ofgem SLC (verbatim, Precautionary Principle)
“In any case of doubt about whether a Domestic Customer is in a Vulnerable Situation, the Licensee must proceed on the basis that the Domestic Customer is in a Vulnerable Situation.”
Ofgem, Electricity Supply Standard Consolidated Licence Conditions, SLC 28.22. ofgem.gov.uk
The Precautionary Principle flips the burden. If your circumstances are unclear to the supplier, the rule says to assume you are vulnerable, not the other way round. That is worth quoting back to any letter that treats hardship as something you have to prove up front.
Winter disconnection is separately restricted. Under Standard Licence Condition 27, suppliers must not disconnect a domestic customer of pension age between 1 October and 31 March. For everyone else, disconnection remains the last resort after the process above has been followed and the supplier can show it took vulnerability into account.
The warrant of entry route explained (what most guides get wrong)
A warrant of entry is not a bailiff visit. It is a separate route granted by a magistrate under a 1954 statute, and it has its own time limits. The bailiff powers guide covers what enforcement agents can do under CCJ enforcement, which is a different route entirely.
Statute (verbatim, 24-hour notice)
“It shall be the duty of the person by whom the application is made to satisfy the justice of the peace that at least twenty-four hours’ notice of the intended entry has been given to the occupier.”
Rights of Entry (Gas and Electricity Boards) Act 1954, s.2(2)(a). legislation.gov.uk
Statute (verbatim, 28-day window)
“A warrant granted under this section shall continue in force until the purpose for which the entry is required has been satisfied, or until the expiration of twenty-eight days from the date on which it was granted, whichever first occurs.”
Rights of Entry (Gas and Electricity Boards) Act 1954, s.2(4). legislation.gov.uk
In plain English: If you were not given at least 24 hours written notice, the magistrate should not have granted the warrant. If the visit falls outside the 28-day window, the warrant is spent. In both cases the entry is not lawful under the warrant, and any charges that flow from it are open to challenge.
Prepayment meters after the 2023 rules (and what they mean for you)
Ofgem paused involuntary prepayment meter installations after the 2023 press coverage and only restarted them once every major supplier signed up to the new rules. That is why suppliers now speak about “consent”, “Site Welfare Visits”, and “eligibility”. Those words come from Ofgem’s decision document, not from marketing copy.
Ofgem SLC (verbatim, consent)
“Consent means express, freely given, informed and unambiguous consent to the installation of a Prepayment Meter, given by the Domestic Customer without pressure, undue inducement, or coercion.”
Ofgem, Electricity Supply Standard Consolidated Licence Conditions, SLC 28.21 (definitions). ofgem.gov.uk
A smart meter switched remotely into prepayment mode counts as an involuntary PPM. That is important. If it was not accompanied by a physical Site Welfare Visit and a real consent conversation, it did not meet the rule.
Ofgem SLC (verbatim, Site Welfare Visit)
“Site Welfare Visit means a physical, in-person visit to the premises for the purpose of establishing the circumstances of the Domestic Customer and any other person residing in the premises, and confirming eligibility for the installation of an involuntary Prepayment Meter.”
Ofgem, Electricity Supply Standard Consolidated Licence Conditions, SLC 28.21 (definitions), read with SLC 28.7(d). ofgem.gov.uk
All the Do Not Install categories from the section above apply here. If a supplier switched or installed a PPM without a Site Welfare Visit, or ignored a category on the DNI list, that is a rulebook breach worth raising in a formal complaint. Ofgem’s public guidance for consumers confirms the same rules from the household side.
What to do this week if you have a letter
Six steps, in order. None of them requires paying anything to a debt firm.
- Open the Budget Planner and get a realistic monthly figure for what you can put toward energy. You need this number for step 2, and you need it before any phone call.
- Write to the supplier and ask for a repayment plan on ability-to-pay basis under SLC 27A. Attach the Budget Planner output. Ask them to record the request against your account.
- If you or anyone in your home fits a Do Not Install category, put that in writing in the same letter and register on the Priority Services Register with the supplier and your network operator.
- Keep every letter and every reply. If the supplier ever applies for a warrant of entry, this paper trail is the evidence that goes in front of the magistrate.
- If you are already receiving formal debt letters or court paperwork, do not ignore them. There is a separate piece on what happens if you do ignore them and why replying in the right form matters.
- If you are asked to complete an income and expenditure form, use realistic figures based on the Budget Planner rather than the supplier’s template. There is a longer piece on this in the income and expenditure article.
When the Energy Ombudsman is the right escalation
The Energy Ombudsman is a free service and legally binding on the supplier if you accept the decision. It is the route to use once the supplier has had time to fix the problem and either has not, or has said it will not.
Energy Ombudsman (verbatim)
“You can bring your complaint to us once your energy supplier has had eight weeks to resolve it, or once they have issued a ‘deadlock letter’, whichever is sooner. You then have up to 12 months from the date of the deadlock letter or the end of the eight-week period to refer your complaint to us.”
Energy Ombudsman, Our process. energyombudsman.org
Put another way, the door opens at eight weeks or a deadlock letter, and it stays open for 12 months. Awards are typically modest in cash terms (£50 to £100 for procedural failings is common) but include practical remedies: reversing a switch, removing warrant costs, correcting a bill, apologising, and reporting the failure back to Ofgem. Suppliers must comply within 28 days of you accepting the decision.
The bigger picture: Ofgem’s 2025-2026 Debt Relief Scheme
Household energy debt has grown sharply since 2022. Ofgem’s own debt-strategy update puts it plainly.
Ofgem (verbatim)
“Total customer debt and arrears stood at £4.43 billion at the end of June 2025. Our Debt Relief Scheme is designed to help reduce the stock of debt on customer accounts. Phase 1 will target support at up to 200,000 households in receipt of means-tested benefits, with an ambition to reduce debt stock by up to £500 million.”
Ofgem, Debt strategy update: supporting the reduction of energy debt. ofgem.gov.uk
You are not the only customer having this conversation with a supplier, and the regulator knows it. That is useful context when a letter frames your account as unusual or difficult. It is neither.
FAQs on energy arrears in the UK
Can my energy supplier disconnect me in winter?
For domestic customers of pension-age households, the supplier must not disconnect between 1 October and 31 March under Standard Licence Condition 27. For everyone else, disconnection remains a last resort after warnings, offers of a repayment plan on ability-to-pay basis, and consideration of vulnerability. If you or anyone in your home relies on medical equipment, has a serious health condition, or has children under two, register on the Priority Services Register with your supplier and network operator. The supplier must factor that in before doing anything.
What is the "Debt Trigger" and does it apply to me?
The Debt Trigger is Ofgem’s defined moment at which an involuntary PPM route becomes available. Under Standard Licence Condition 28.21, it means at least three months of outstanding balance, an amount above the SLC 28.4 minimum threshold, and no active repayment plan or transition to a new tariff. If any one of those three tests is missing, the Debt Trigger is not met and involuntary PPM is off the table.
If a magistrate grants a warrant, can the supplier just turn up any day?
No. Under the Rights of Entry (Gas and Electricity Boards) Act 1954, a warrant is valid for 28 days from the date it is issued (section 2(4)). The supplier or its agent must also give at least 24 hours written notice of the intended entry (section 2(2)(a)). If the visit falls outside the 28-day window, or if you were not given 24 hours notice, the entry is not lawful under the warrant.
My smart meter was switched to prepay without my say-so. Is that allowed?
Only in narrow circumstances. Under Ofgem’s Involuntary PPM rules, a remote smart-meter switch counts as an involuntary PPM. Standard Licence Condition 28.21 defines valid consent as unmistakable and free of undue pressure. If the switch happened without a physical Site Welfare Visit, or if you fall in any Do Not Install category (medical equipment, dependants under two, older residents without support, and other listed conditions), the switch is likely to have broken Ofgem rules. That is a complaint to your supplier, and if unresolved after eight weeks or a deadlock letter, an escalation to the Energy Ombudsman.
I have a small child or a health condition. Can they still fit a prepayment meter?
Not if you fall in a Do Not Install category. Under Ofgem’s Involuntary PPM Guidance 3.7 read with SLC 28.10, involuntary PPM must not be installed where anyone in the household relies on powered medical equipment, uses a careline system, has an illness that makes warmth essential, is aged 75 or over without support, has children under two, or has serious conditions including cancer, chronic obstructive pulmonary disease, cardiovascular disease, and organ failure. Put your situation in writing to the supplier and ask them to record it against your account before any warrant hearing.
My supplier added warrant fees to my bill. Can I get them removed?
If you are in a vulnerable situation, Standard Licence Condition 28.11 says warrant-related costs must not be passed on to you. That covers court fees, locksmith fees, and installation charges tied to the warrant of entry. Write to the supplier citing SLC 28.11 and ask for the charges to be removed. If they refuse, escalate to the Energy Ombudsman after eight weeks or a deadlock letter.
When can I take my supplier to the Energy Ombudsman?
Once the supplier has had eight weeks to resolve the complaint, or once they issue a deadlock letter, whichever is sooner. You then have 12 months to bring the case to the Energy Ombudsman. The service is free. If the Ombudsman upholds the complaint, the supplier is legally bound by the decision if you accept it, and typical awards for procedural failings run from £50 to £100, plus practical remedies like removing charges or reversing a switch. Suppliers must comply within 28 days of acceptance.