Guide / Make the agreement work
Know which energy protections and complaints routes apply to your school
Independent-school status does not determine your energy-consumer protections. Establish the actual customer, relevant fuel and eligibility evidence, then record the route to use if supply or adviser service goes wrong.
Establish the customer and the relevant protection
A small school, a large boarding estate and a multi-school company can have different energy-consumer classifications. Do not infer eligibility from pupil numbers, charity registration or a single campus description. Identify the actual contracting customer and ask the supplier to confirm the classification used, its evidence and the rights that follow.
This guide separates general commercial-contract checks from eligibility for particular complaints and redress arrangements. Ofgem's non-domestic Standards of Conduct apply to suppliers' treatment of non-domestic customers generally. Additional protections and access to an external scheme depend on the relevant rules; they are not universal promises made by this programme.
Check the microbusiness test using evidence
For the Great Britain redress framework, a non-domestic customer can meet the microbusiness criteria through the employee and financial test or through the relevant energy-consumption test. Record the period, customer and source data used. If the structure or consumption makes eligibility unclear, obtain confirmation rather than selecting a category because it appears helpful.
The financial limit is now expressed in pounds. Older material can still refer to euros: the 2024 amendment changed the relevant limit to £2 million from 19 December 2024. Use current legal and scheme wording when checking an actual dispute.
| Route to microbusiness criteria | Test to check |
|---|---|
| People and finances | Fewer than 10 employees or their full-time equivalent, and either annual turnover or annual balance sheet total not exceeding £2 million. |
| Electricity consumption | Annual electricity consumption not more than 100,000 kWh. |
| Gas consumption | Annual gas consumption not more than 293,000 kWh. |
The small-business category is wider, but not unlimited
The 2024 Order extended the redress framework to qualifying small-business consumers from 19 December 2024. It defines a small-business consumer as a non-domestic consumer who is not already a relevant consumer and meets one of the following routes. The controlling wording is fewer than 50 employees, not a general band running from 11 to 50.
When eligibility relies on consumption and the same regulated provider supplies both fuels, the Order requires gas and electricity consumption to be treated separately for the complaint concerned. Do not assume that qualifying for electricity automatically establishes the same position for gas.
| Route to small-business criteria | Test to check |
|---|---|
| People and finances | Fewer than 50 employees or their full-time equivalent, and either annual turnover not exceeding £6.5 million or balance sheet total not exceeding £5 million. |
| Electricity consumption | Annual electricity consumption not more than 200,000 kWh. |
| Gas consumption | Annual gas consumption not more than 500,000 kWh. |
A school example explains why fuel matters
Consider a fictional customer with 70 employees, annual electricity use of 150,000 kWh and gas use of 700,000 kWh. On those invented facts, the electricity consumption is within the small-business limit; the gas consumption is above it, and the employee test is not met. This illustrates a possible difference between fuels. It is not an eligibility determination for a real school.
Keep annual-use evidence, the employment and financial evidence where relevant, customer details and the supplier's written response. For a group, check the actual customer and aggregation question rather than applying a single-site assumption. The scheme assesses eligibility under its own terms and the applicable rules.
Use the supplier process first and preserve the record
Raise a clear complaint with the supplier, identifying the account, disputed item, supporting documents and outcome sought. Obtain a reference, keep the chronology and distinguish a billing dispute from a network or continuity problem. Follow suitable advice on payment and urgent safety or supply concerns; making a complaint does not by itself remove the school's obligations.
The Energy Ombudsman says eligible supplier disputes can be referred after deadlock or after eight weeks without resolution, subject to its rules. Check its current acceptance requirements and any referral time limit. Larger customers outside scheme eligibility need another appropriate route, which may include negotiation, the contractual dispute process and professional advice.
Check adviser recourse before appointment
Ask the TPI for its complaints procedure and current scheme details before committing. For micro and small-business customers, Ofgem guidance addresses qualifying dispute-settlement arrangements. Check that the scheme covers the provider and the proposed service, and that the customer and complaint are eligible. Do not treat a logo or membership number as proof that every issue can be referred.
Keep the engagement letter, authority, disclosure of fees, recommendation, supply terms and relevant communications. A dispute about the adviser may differ from one about the supplier. Notify the appropriate organisations, explain each party's role and seek advice where there may be material loss or a binding-contract dispute.
Keep Great Britain and Northern Ireland distinct
Ofgem and the Great Britain redress framework should not be presented as the Northern Ireland route. The Utility Regulator advises Northern Irish customers to approach the supplier first and then the Consumer Council for Northern Ireland if the matter remains unresolved or the response is unsatisfactory. Its TPI guidance also identifies separate advice on broker concerns.
Retain a one-page protections record for each relevant customer and fuel: evidence, classification confirmed, complaints contacts, external route and key dates. Recheck it when the customer, supplier, service or school structure changes. That makes escalation practical while preserving the distinction between an anticipated protection and a confirmed entitlement.