Ofgem's TPI Code of Practice: A Practical Compliance Checklist for Brokers

For much of the past decade, energy brokers operated in a regulatory grey area. That era is drawing to a close. Ofgem's reformed approach to Third Party Intermediaries — embedded through supplier licence conditions and an increasingly formal Code of Practice — has set a clear standard of conduct for anyone advising business customers on their energy. This article translates the framework into a practical checklist you can measure your own business against.

1. Transparent Commission Disclosure

The single most important shift is the expectation that commercial customers understand how, and how much, their broker is paid. Disclosure should be clear, given in writing, and provided before a contract is agreed — not buried in small print after the fact.

• Disclose the existence and basis of any commission or uplift before the customer commits
• Provide the figure in writing, in plain language, not as a percentage hidden in jargon
• Never operate dual-charging — taking payment from both supplier and customer — without explicit written consent

2. Honest Sales Conduct

Conduct standards extend across the entire sales process. High-pressure tactics, misleading comparisons and impersonating a supplier or the regulator are all firmly out of bounds. The principle is straightforward: a customer should finish the conversation with an accurate understanding of what they have agreed to and why.

• Represent yourself accurately — never imply you are the supplier or acting on Ofgem's behalf
• Ensure comparisons are like-for-like and based on the customer's genuine consumption
• Keep clear records of what was said, offered and agreed at each stage

3. A Clear Complaints Route

Where an intermediary is involved in a sale, customers must have a clear path to raise concerns and have them addressed. A documented complaints procedure is no longer a nicety — it is an expectation of the suppliers whose products you sell.

4. Records, Vetting and Sub-Broker Oversight

Suppliers are increasingly held accountable for the conduct of the intermediaries they work with, and that accountability cascades down the chain. If you work with sub-brokers or agents, you are expected to apply the same standards to them that suppliers apply to you. Robust record-keeping and credential verification are the foundation of demonstrating compliance.

Your Compliance Checklist

1. Commission is disclosed in writing, in plain language, before the customer commits
2. No dual-charging without explicit written consent
3. Sales conduct is honest, with accurate representation and like-for-like comparisons
4. A documented complaints procedure is in place and shared with customers
5. Records of every sale are retained and retrievable
6. Sub-brokers and agents are vetted and held to the same standards
7. Your processes are reviewed regularly against evolving supplier requirements