This browser is not actively supported anymore. For the best passle experience, we strongly recommend you upgrade your browser.
Norton Rose Fulbright logo
  • Global
  • About
    • Our firm
      • Clients
      • Global coverage
      • Vision, culture and people
      • Governance structure
      • Risk management
      • NRF Transform
      • Alumni
    • Diversity, Equity & Inclusion
      • Strategy, goals and priorities
      • Governance and policy
      • Resource groups
    • Responsible business
      • Volunteering
      • Fundraising
      • Sustainable practice
      • Global charitable initiatives
      • Responsible use of AI
  • People
  • Services
    • Services A-Z
    • Key industries
      • Consumer markets
      • Energy, infrastructure and resources
      • Financial institutions
      • Life sciences and healthcare
      • Technology
      • Transport
    • Practices
      • Antitrust and competition
      • Banking and finance
      • Climate change and sustainability
      • Corporate, M&A and securities
      • Cybersecurity and data privacy
      • Employment and labor
      • Energy
      • Environmental, social and governance (ESG)
      • Financial services and regulation
      • Intellectual property
      • Litigation and disputes
      • Projects
      • Real estate
      • Regulation and investigations
      • Restructuring
      • Risk advisory
      • Tax
    • Practices
      • Antitrust and competition
      • Banking and finance
      • Climate change and sustainability
      • Corporate, M&A and securities
      • Cybersecurity and data privacy
      • Employment and labor
      • Energy
      • Environmental, social and governance (ESG)
      • Financial services and regulation
      • Intellectual property
      • Litigation and disputes
      • Projects
      • Real estate
      • Regulation and investigations
      • Restructuring
      • Risk advisory
      • Tax
      • Banking and finance
      • Corporate, M&A and securities
      • Employment and labor
      • Environmental, social and governance (ESG)
      • Intellectual property
      • Projects
      • Regulation and investigations
      • Risk advisory
    • NRF Transform
    • Transform image

      Find out more
  • Insights
    • Publications Podcasts Blogs
    • Webinars and events Videos
    • Professional development Resources and tools
    • colorful light particles
      Trending topics
      • Artificial intelligence
      • Data centers
      • Energy transition
      • International trade and tariffs
    • Trending topics
      • Artificial intelligence
      • Data centers
      • Energy transition
      • International trade and tariffs
  • News
    • Press releases
    • Market recognitions
    • Media information
  • Locations
  • Careers
    • Graduates and students
    • Search current vacancies
  • Careers
    • Graduates and students
    • Search current vacancies
  • Change
  • Global
    • global site
    • North America
      • Canada (English)
      • Canada (Français)
      • United States
    • Latin America
    • Europe
      • Belgium
      • Deutschland (Deutsch)
      • France
      • Germany (English)
      • Greece
      • Italy
      • Luxembourg
      • Poland
      • The Netherlands
      • Turkey
      • United Kingdom
    • Middle East
    • Africa
      • Morocco
    • Asia Pacific
      • Australia
      • China
      • Hong Kong SAR
      • Indonesia
      • Japan
      • Singapore
      • Thailand
    • Regional practices
      • India
      • Israel
      • Korea
      • Marshall Islands
      • Nordic region
      • Pakistan
      • Vietnam
Lake in the forest

Connections

Insights, perspectives and viewpoints from our lawyers on topical issues

All Posts Subscribe
print-logo
4/22/2026 5:10:05 PM | 2 minute read

Ofgem’s “Transformation”: Key takeaways from the DESNZ announcement

Electrical distribution substation at sunrise
19

Get in touch

Avatar
Susanna Rogers
Partner
Avatar
Mark Mills
Counsel
Avatar
Jack Jeffries
Counsel

Get in touch

Avatar
Susanna Rogers
Partner
Avatar
Mark Mills
Counsel
Avatar
Jack Jeffries
Counsel
19

On 22 April 2026, the Department for Energy Security and Net Zero (DESNZ) announced proposals to “transform” Ofgem’s role and powers to strengthen protections for energy consumers. While much of the detail is still to follow, the announcement highlighted three areas where Ofgem’s remit could be materially expanded. Each has clear parallels with developments elsewhere.

Direct enforcement of consumer law

First, DESNZ proposes giving Ofgem stronger powers to enforce consumer law directly. This reflects a broader shift in UK consumer regulation towards quicker, more administrative enforcement tools.

There are obvious links here to the Competition and Markets Authority’s expanded consumer enforcement powers and its increasing activity in this space (see our thoughts on recent developments here).

Historically, Ofgem has relied heavily on licence conditions to take enforcement action against regulated entities. Stronger consumer law powers could allow it to act more directly in parts of the market where licensing powers are currently limited. Over time, it will be interesting to see whether this leads to a greater shift towards consumer law enforcement, or whether licence‑based enforcement remains the primary tool.

The Law Commission’s recent announcement on a potential consumer class action regime may also be relevant, particularly in shaping the balance between regulatory enforcement and private redress mechanisms.

Banning executive bonuses

The second key proposal is for Ofgem to be able to ban energy company executive bonuses, with a blueprint provided by the recently adopted approach in the water sector under the Water (Special Measures) Act 2025 (W(SM)Act). The suggestion is that individual accountability is the only way to ensure company behaviour is aligned with consumer interests, and appears to follow from other steps taken by Ofgem in relation to fitness of senior staff in the sector.

If the water sector blueprint is followed, a number of key design questions will need to be answered about the regime. The energy sector is significantly more diverse than water, raising issues about which types of breach would trigger a bonus ban, how seriousness would be assessed, and whether the rules would apply uniformly across all regulated entities and activities.

It is also worth noting that the water regime included a degree of retrospective effect, applying from the start of the relevant financial year in which the rules were introduced – that is, April 2024 when the W(SM)Act received Royal Assent in 2025. Whether DESNZ and Ofgem would consider there is a case to push for a similar anti‑avoidance measure in energy will need to be closely watched.

A broader and more flexible remit

Finally, DESNZ points to reforms enabling Ofgem to regulate new areas of the market where needed, with a renewed focus on economic and consumer protection across all energy consumers.

This sits alongside recent developments, including the introduction of statutory regulation for heat networks and the ongoing creation of a regulatory framework for third‑party intermediaries. What remains unclear is how far this flexibility will extend, and how quickly Ofgem could intervene as new business models emerge.

Looking ahead

Together, these proposals signal a regulator with stronger enforcement tools, greater reach, and a clearer consumer‑focused mandate. The impact, however, will ultimately depend on how these powers are framed — particularly in relation to overlap with other regulators, proportionality across a diverse sector, and safeguards against unintended consequences.

Subscribe to our Connections insights Sign-up now

Tags

antitrust and competition

Get in touch

Avatar
Susanna Rogers
Partner
Avatar
Mark Mills
Counsel
Avatar
Jack Jeffries
Counsel

Get in touch

Avatar
Susanna Rogers
Partner
Avatar
Mark Mills
Counsel
Avatar
Jack Jeffries
Counsel
The CMA’s response to heating oil costs
3/13/2026 6:04:57 PM

The CMA’s response to heating oil costs

By Jamie Cooke Ian Giles Caroline Thomas Mark Mills +1 more...

Show less

The government has taken an increasingly tough tone on rising fuel prices following the surge in global oil costs linked to conflict in...
60
60

Latest Insights

The Revised Technology Transfer Block Exemption Regulation: Same framework, sharper edges
4/17/2026 1:02:25 PM

The Revised Technology Transfer Block Exemption Regulation: Same framework, sharper edges

By Alexandra Rogers Mai Muto David Fila
1
25
25
Subsidy Control challenge against the Gambling Commission: What can we learn from this gamble that didn't pay off?
4/17/2026 12:09:15 PM

Subsidy Control challenge against the Gambling Commission: What can we learn from this gamble that didn't pay off?

By Susanna Rogers Mark Mills Jane Kluske James Dempsey +1 more...

Show less

The CMA imposes its first financial penalty for a breach of consumer law under the DMCCA
4/16/2026 3:16:18 PM

The CMA imposes its first financial penalty for a breach of consumer law under the DMCCA

By Caroline Thomas Jamie Cooke Amanda Town Gabrielle Martin +1 more...

Show less

19
19

Explore our site

  • About
  • Careers
  • Diversity, Equity & Inclusion
  • People
  • Services
  • Insights
  • News

Key industries

  • Consumer markets
  • Energy, infrastructure and resources
  • Financial institutions
  • Life sciences and healthcare
  • Technology
  • Transport

Locations

  • Global coverage

Norton Rose Fulbright © 2024. All Rights Reserved.

  • Amsterdam
  • ●
  • Athens
  • ●
  • Austin
  • ●
  • Bangkok
  • ●
  • Beijing
  • ●
  • Brisbane
  • ●
  • Brussels
  • ●
  • Calgary
  • ●
  • Canberra
  • ●
  • Casablanca
  • ●
  • Chicago
  • ●
  • Dallas
  • ●
  • Denver
  • ●
  • Dubai
  • ●
  • Düsseldorf
  • ●
  • Frankfurt
  • ●
  • Hamburg
  • ●
  • Hong Kong SAR
  • ●
  • Houston
  • ●
  • Istanbul
  • ●
  • Jakarta*
  • ●
  • London
  • ●
  • Los Angeles
  • ●
  • Luxembourg
  • ●
  • Melbourne
  • ●
  • Mexico City
  • ●
  • Milan
  • ●
  • Minneapolis
  • ●
  • Montréal
  • ●
  • Munich
  • ●
  • Newcastle
  • ●
  • New York
  • ●
  • Ottawa
  • ●
  • Paris
  • ●
  • Perth
  • ●
  • Piraeus
  • ●
  • Québec
  • ●
  • Riyadh*
  • ●
  • San Antonio
  • ●
  • San Francisco
  • ●
  • São Paulo
  • ●
  • Shanghai
  • ●
  • Singapore
  • ●
  • St. Louis
  • ●
  • Sydney
  • ●
  • Tokyo
  • ●
  • Toronto
  • ●
  • Vancouver
  • ●
  • Warsaw
  • ●
  • Washington DC *associate office
  • Legal notices and disclaimers
  • Impressum
  • Standard terms
  • Blog network terms and conditions
  • Cookies policy
  • Privacy notice
  • Website access conditions
  • Fraud alerts
  • Modern Slavery Statements
  • Health plan machine readable files
  • Anti-Facilitation of Tax Evasion Statement
  • Suppliers
  • History
  • Remote access
  • Sitemap
Offices and locations

Norton Rose Fulbright © 2024. All Rights Reserved.

  • Amsterdam
  • ●
  • Athens
  • ●
  • Austin
  • ●
  • Bangkok
  • ●
  • Beijing
  • ●
  • Brisbane
  • ●
  • Brussels
  • ●
  • Calgary
  • ●
  • Canberra
  • ●
  • Casablanca
  • ●
  • Chicago
  • ●
  • Dallas
  • ●
  • Denver
  • ●
  • Dubai
  • ●
  • Düsseldorf
  • ●
  • Frankfurt
  • ●
  • Hamburg
  • ●
  • Hong Kong SAR
  • ●
  • Houston
  • ●
  • Istanbul
  • ●
  • Jakarta*
  • ●
  • London
  • ●
  • Los Angeles
  • ●
  • Luxembourg
  • ●
  • Melbourne
  • ●
  • Mexico City
  • ●
  • Milan
  • ●
  • Minneapolis
  • ●
  • Montréal
  • ●
  • Munich
  • ●
  • Newcastle
  • ●
  • New York
  • ●
  • Ottawa
  • ●
  • Paris
  • ●
  • Perth
  • ●
  • Piraeus
  • ●
  • Québec
  • ●
  • Riyadh*
  • ●
  • San Antonio
  • ●
  • San Francisco
  • ●
  • São Paulo
  • ●
  • Shanghai
  • ●
  • Singapore
  • ●
  • St. Louis
  • ●
  • Sydney
  • ●
  • Tokyo
  • ●
  • Toronto
  • ●
  • Vancouver
  • ●
  • Warsaw
  • ●
  • Washington DC *associate office
Policies and disclaimers
  • Legal notices and disclaimers
  • Impressum
  • Standard terms
  • Blog network terms and conditions
  • Cookies policy
  • Privacy notice
  • Website access conditions
  • Fraud alerts
  • Modern Slavery Statements
  • Health plan machine readable files
  • Anti-Facilitation of Tax Evasion Statement
  • Suppliers
  • History
  • Remote access
  • Sitemap
Visit our global site, or select a location
North America
  • Canada (English)
  • Canada (Français)
  • United States
Latin America
Europe
  • Belgium
  • Deutschland (Deutsch)
  • France
  • Germany (English)
  • Greece
  • Italy
  • Luxembourg
  • Poland
  • The Netherlands
  • Turkey
  • United Kingdom
Middle East
Africa
  • Morocco
Asia Pacific
  • Australia
  • China
  • Hong Kong SAR
  • Indonesia
  • Japan
  • Singapore
  • Thailand
Regional practices
  • India
  • Israel
  • Korea
  • Marshall Islands
  • Nordic region
  • Pakistan
  • Vietnam