Guide for energy brokers

UK Energy Broker (TPI) Regulation: The 2026 Guide

Last reviewed: June 2026. Plain-English summary, not legal advice.

Energy broking in the UK is moving from light-touch rules to direct regulation. Some of it is already mandatory. The rest is coming through Ofgem over the next two years. This is what a third-party intermediary (TPI) needs to know, and what to do now so the change is a non-event for you.

At a glance

  • Already mandatory: commission disclosure on non-domestic contracts (since Oct 2024) and redress-scheme membership for small-business deals.
  • Confirmed: Ofgem will become the dedicated TPI regulator (government response, Oct 2025).
  • Coming: mandatory registration with Ofgem plus a "fit and proper person" test.
  • Timeline: Ofgem market survey in 2026, registration expected ~2027, full enforcement from 2028.

What is a TPI?

A third-party intermediary is any business that helps a customer arrange or manage energy supply without being the supplier itself. Energy brokers, energy consultants and comparison services are all TPIs. The incoming regulation is aimed squarely at TPIs that arrange contracts for businesses.

Is energy broking regulated right now?

There is no single broker licence yet, but two sets of rules already bite, and suppliers enforce both because their own licence depends on it.

1. Commission disclosure (since October 2024)

Non-domestic suppliers must show the broker uplift as a principal term of the contract, in pence per kWh. You must give the client a written commission statement: the total commission in pounds, and the p/kWh uplift shown separately from the supplier's own rate. Burying margin in a blended unit rate is no longer allowed.

2. Redress scheme membership

To place small-business contracts, you must belong to a qualifying redress scheme — in practice the Energy Ombudsman. Suppliers cannot work with you on those contracts otherwise. The Energy Ombudsman's scope now covers "small business" (broadly, fewer than 50 staff, turnover under £6.5m, or under 200,000 kWh electricity / 500,000 kWh gas a year), wider than the old microbusiness definition.

3. The voluntary TPI Code of Practice

There is also a voluntary Code of Practice administered by RECCo. Uptake has been low — around 52 of 2,700-plus brokers have signed. Signing is not required, but it is a credibility signal while statutory rules are still being built, and it costs you nothing if you already disclose properly.

What's changing: Ofgem becomes the regulator

In October 2025 the government published its response on regulating TPIs and confirmed Ofgem as the dedicated regulator, to be legislated when parliamentary time allows. The model is a "hybrid" authorisation: a general authorisation regime combined with formal registration. In plain terms:

  • Every TPI arranging energy contracts will have to register with Ofgem.
  • You will need to meet a "fit and proper person" test to operate.
  • Ofgem will gain enforcement powers — the ability to fine, suspend or ban non-compliant intermediaries.
  • Expect stronger requirements around complaints handling and redress.

The timeline

Dec 2022Suppliers restricted to working with brokers in a qualifying redress scheme (small-business deals).
Oct 2024Commission disclosure becomes mandatory on non-domestic contracts.
Oct 2025Government confirms Ofgem as the dedicated TPI regulator.
H1 2026Ofgem surveys the TPI market to size the sector and map consumer harm.
2026Ofgem designs the framework and publishes conduct principles.
~2027Broker registration expected to open (subject to parliamentary time).
2028+Full enforcement — only registered, compliant brokers can operate.

Once registration opens there will be a 12–18 month "sunrise period" before it becomes mandatory, so existing brokers get time to register before they can no longer trade without authorisation.

How to get ahead of it (checklist)

  • Show your commission in pounds and pence per kWh on every quote and contract, separate from the supplier rate.
  • Make sure you are a member of the Energy Ombudsman redress scheme, and keep the evidence to hand.
  • Get your contract paperwork and commission statements into a state you would be happy to show a regulator.
  • Consider signing the voluntary TPI Code of Practice as an early credibility signal.
  • Tighten complaints handling: a clear process, logged, with a route to the Ombudsman.
  • Read the government response and Ofgem updates directly rather than waiting for the trade-press summary.

None of this hurts a broker who already adds real value. If a client can see you take a fee and still thinks you are worth it, regulation changes very little for you. The brokers who built a model on the client never asking are the ones with work to do.

Frequently asked questions

Is energy broking regulated in the UK?

Partly, and increasingly so. There is no single broker licence yet, but since October 2024 non-domestic suppliers must show broker commission as a principal contract term, and brokers arranging small-business contracts must belong to a qualifying redress scheme such as the Energy Ombudsman. In October 2025 the government confirmed Ofgem will become the dedicated regulator for third-party intermediaries, with registration expected to open around 2027.

Do energy brokers need to register with Ofgem?

Not yet, but they will. The government has confirmed a hybrid authorisation model where every TPI arranging energy contracts must register with Ofgem and meet a "fit and proper person" test. Registration is expected to open around 2027, followed by a 12 to 18 month sunrise period before it becomes mandatory.

When does TPI regulation come into force?

Ofgem began surveying the TPI market in the first half of 2026 and is designing the framework through 2026. Registration is expected to open around 2027 (subject to parliamentary time), with full enforcement from 2028 onwards. The commission-disclosure and redress-scheme rules are already in force now.

Do energy brokers have to disclose their commission?

Yes. Since October 2024, non-domestic energy suppliers must show the broker uplift as a principal term of the contract, expressed in pence per kWh. Brokers must also provide a written commission statement showing the total commission in pounds and the uplift separately from the supplier rate.

Do energy brokers need to join a redress scheme?

Yes, for small-business contracts. Suppliers can only place small-business contracts through brokers that belong to a qualifying redress scheme, in practice the Energy Ombudsman. Without it, suppliers will not work with you.

What is a TPI in energy?

A TPI (third-party intermediary) is any business that helps a customer arrange or manage their energy supply without being the supplier — energy brokers, consultants and comparison services all count. The incoming regulation applies to TPIs that arrange contracts.

Sources

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