How UK business energy procurement is structured
Three parties generally sit between a UK business and its energy supply:
- The licensed supplier — the named entity on your bill that holds the Ofgem retail licence (e.g. EDF Energy, British Gas Business, Octopus Energy for Business).
- The third-party intermediary (TPI) — a generic regulatory category covering energy consultants, comparison sites and procurement specialists. We are a TPI.
- You, the customer.
The supplier sets the unit rate for your contract; the TPI's role is to tender across the open market, audit the resulting prices and represent your interests through procurement and the contract life.
How consultants are paid
There are three common structures, all legitimate when disclosed:
- Commission baked into the unit rate. The supplier adds a small uplift (often 0.1–1.0 p/kWh) which is paid back to the consultant. This is the most common SME structure.
- Fixed fee. A flat retainer paid by the customer for a defined service (procurement of N contracts per year, or compliance casework).
- Success fee. A percentage of savings achieved — usually relative to a defined baseline.
The risk in option 1 is opacity: if you don't know what the uplift is, you don't know what you're paying. That is precisely what the new disclosure rules are designed to fix.
The Ofgem 2024 disclosure rules
From 2024, Ofgem licence conditions require any TPI placing a contract with a UK licensed supplier to disclose any commission earned to the customer in writing before contract signature. The disclosure must include the cash amount and, for unit-rate-based commission, the equivalent p/kWh.
This was a significant uplift in transparency, but it remains supplier-enforced rather than directly regulated against the TPI itself. That changes from 2027.
Where the regulator is heading
In October 2025 the UK Government published its consultation response on TPI regulation, confirming Ofgem will become the direct regulator for business energy intermediaries. The expected rollout:
- 2026: Ofgem surveys the TPI population and designs the registration framework.
- 2027: Broker registration opens, subject to parliamentary timing.
- 2028+: Full enforcement — only registered, compliant intermediaries can place contracts.
For customers, this is unambiguously good news: it raises the floor under intermediary conduct and brings the UK into line with the regulated comparable in financial advice.
Four questions to ask any consultant before you sign
- Are you signed up to the TPI Code of Practice? Of an estimated 2,700+ UK business energy intermediaries, only ~52 had signed the voluntary TPI Code as of January 2026 — that's 2%. Ask. (We are signatories.)
- Show me the commission disclosure for every quote. Not just the winning quote — every quote. If they can't show it on every line, they're not really tendering.
- How many suppliers did you tender to? Anything under five for a standard SME tender suggests preferred-supplier bias.
- Are you ADR-registered? If something goes wrong, you need an Alternative Dispute Resolution route. The Energy Ombudsman handles supplier complaints; reputable TPIs are members of an equivalent ADR scheme for intermediary disputes.
If you don't get straight answers to all four, that is itself the answer to your question.