The Energy Ombudsman has published its long-awaited  2025 report on the Broker ADR Scheme.

We welcome the publication. not just as a statutory obligation under the QDSS framework, but as a necessary step toward accountability and clarity in a rapidly maturing sector.

This report is overdue. But it does offer insight into the shape and scale of broker-facing disputes, as well as some tentative signs of improved performance from the Ombudsman.

At the same time, it raises familiar and still-unanswered questions about cost, transparency, and operational integrity.

As ever, our stance is straightforward: brokers deserve a regulatory framework that is fair, proportionate, and reflective of the vital role they play in helping UK businesses manage energy risk.

We’re working to ensure they get exactly that.

We’ve heard from many of our members that decisions from the Ombudsman now seem more consistent.

That’s an important shift, especially given the lack of trust that characterised the scheme in its early stages.

It’s encouraging to see that upheld complaint rates have dropped to 54%.

This may suggest two things: either the EO is becoming more rigorous in its assessments, or it is accepting a higher proportion of marginal cases that ultimately do not meet the standard for redress.

Either way, it underlines our longstanding position that too many cases are being escalated unnecessarily, and that the Ombudsman must do more to screen out weak or out-of-scope disputes before they reach full investigation.

The Ombudsman accepted 1,568 broker-related complaints in 2024, of which 58% were upheld. That equates to just over 900 upheld complaints in total.

To put that in context: brokers alone handle more than 300,000 contracts and facilitate over 500,000-meter registrations each year.

Across the scheme’s full 1,800-strong broker base, the true figure is significantly higher.

The resulting complaint rate is approximately 0.3%.

That’s not just low by energy standards — it’s industry-leading when compared to other brokered sectors like insurance, finance, and telecoms.

We’ve said it before: this is not a broken market.

It is a competitive and highly functional one.

And while bad actors do exist, the data shows that the overwhelming majority of brokers act professionally and in their clients’ best interests.

We remain deeply concerned by the EO’s revenue model.

After sustained pressure from the ECA and others, annual registration fees were reduced from £300 to £175. But even at this level, they generate over £318,000 in subscription income.

When combined with case fees, we estimate that the scheme now costs more than £550 per disputed case and over £750 per upheld decision.

Given that typical awards average around £600, this raises an obvious question: how can a redress scheme cost more to run than it pays out?

We believe the current annual registration fee should be reduced to its actual administrative cost, which we calculate at no more than £50, and that a full breakdown of income allocation should be published annually.

At present, the operational costs suggest a scheme being run with overheads disproportionate to its workload.

With just over 1,500 cases and a low churn rate, the programme could be effectively administered by a small, specialist team.

Nearly £1 million in operating costs simply doesn’t add up.

Under Schedule 5 of the ADR Regulations, Ofgem is required to conduct independent biennial reviews of ADR schemes — including the Energy Ombudsman.

Yet the last truly independent review was conducted in 2015 by Lucerna Partners.

Since then, Ofgem has relied on internal assessments, based on self-submitted performance data and internal sampling. This falls short of both the letter and the spirit of the legislation.

The Energy Ombudsman has also never been put out to competitive tender, despite its pivotal role in the redress system.

We believe this lack of market testing undermines standards, stifles innovation, and raises legitimate concerns over impartiality.

That’s one of the key reasons we introduced the Dispute Resolution Ombudsman (DRO) as an alternative — to ensure brokers have, and should always have, a genuine choice in selecting the redress scheme that best fits their business model and values.

For a scheme that brokers and suppliers are compelled to join, transparency and accountability must be above reproach. Ofgem must do more to uphold those principles.

The Ombudsman’s Net Promoter Score (NPS) sits at +33, with a 77.5% satisfaction rating. These are respectable numbers, but they’re based on consumer feedback, not broker feedback.

Let’s be clear: the EO’s contracted customers are the brokers themselves.

As such, we believe NPS should be tracked across both consumers and brokers, with segmented data made public.

Without this, we risk overlooking major issues in scheme delivery and broker experience. something many of our members have raised privately, but which is rarely visible in official reporting.

The EO states in this year’s report that its team is made up of “specialist and experienced colleagues who have undergone comprehensive training.”

Frankly, we’re not convinced.

In recent conversations with two former employees of the scheme, both described a concerning lack of structured training or domain-specific knowledge.

In their view, this continues to hinder the consistency, clarity, and fairness of case outcomes — especially where complex contract arrangements or multi-party relationships are involved.

As it stands, we do not believe the Ombudsman has adequately demonstrated that its staff are trained to the level required to adjudicate in such a specialised market.

This must improve.

This year’s report reflects some positive direction of travel, but we’re under no illusion that the system is fixed.

Too many cases are still accepted that do not meet the bar for redress. Costs remain opaque. And the brokers funding the scheme are still not being heard.

That’s why we’re continuing to raise these concerns directly with the EO, with Ofgem, and with policymakers across Westminster.

We’re also pleased to confirm that we’ve begun working closely with Sarah Edwards MP on a number of reforms designed to improve market fairness and broker recognition.

In particular, the ECA has agreed to:

• Support the creation of a kitemark scheme to identify reputable energy brokers.
• Help develop a new customer-facing website that allows businesses to check their rates and ensure they are not being overcharged.

We’ll keep members informed as this work progresses — and will be actively seeking your input throughout.

We believe in accountability. We believe in high standards. And we believe that reputable brokers deserve recognition, not suspicion.

This report marks a step forward, but not a finish line.

As the only trade body dedicated solely to the UK’s energy brokers and consultants, we’ll continue advocating for fair treatment, evidence-based regulation, and a sector that works — for brokers, and for the businesses they serve.

If you have views, concerns, or insights you’d like us to raise with the Ombudsman, our inbox is always open.

Brokers who are part of the ECA are already leading the way in professional standards.

✔ Access to expert-led training and guidance on regulatory changes
✔ Support with compliance, ADR, and complaints handling solutions
✔ A collective voice to represent brokers’ interests with Ofgem and policymakers
✔ Networking opportunities and industry recognition

If you would like to become a member today and share in tomorrow’s success, please contact enquiries@energyconsultantsassociation.co.uk with the following information:

• Membership tier relevant to your business turnover
• Business address
• Main contact details
• Monthly/Annual payment

Or fill out this form to receive our information pack

If you have any questions, please reach out to Joe Wilson at joe.wilson@energyconsultantsassociation.co.uk or call 07875343161.

If today’s agenda speaks to the challenges you face, or the kind of support you want more of, we’d love to welcome you as a member.

Let’s build the future of this sector together.