Ofwat requires all Retailers in England to offer business customers who are struggling to pay their bills due to the coronavirus pandemic access to a COVID-19 Repayment Scheme. This is a requirement of the Customer Protection Code of Practice, which all Retailers in the Non-household retail market must adhere to.

Although Ofwat has provided some guidance, it has given retailers the autonomy to run their own schemes. We have produced the following guidelines that we expect retailers to follow:

Eligibility:

  • Retailers’ websites should be clear that any customer whose business has been affected by COVID-19 can apply for the repayment scheme, not just those who have had to temporarily close their premises.
  • Retailers should include on their websites an indication of the types of evidence they will ask customers to provide in order to accept them onto the scheme. Retailers should already be aware of any reduction in a customer’s consumption and difficulties in making payments.
  • Retailers should bear in mind that the CP007 decision document (pdf) (the change to the Retail Market Codes which brought in the requirement for a COVID-19 repayment scheme) makes clear that further evidence should be “reasonably requested” i.e. not as a means of dissuading customers from trying to access the scheme.
  • If a retailer is unclear whether a customer qualifies for the scheme or not, then we would expect the retailer to act in the best interests of the customer.
  • Contact details allowing a customer to appeal against a rejected application for the COVID-19 Repayment Scheme should be prominent on the retailers’ website or the schemes Terms & Conditions (T&Cs).

Timing:

  • The closing date for the scheme, which is 31 March 2021, should be clearly visible on retailers’ websites. Retailers should accept applications up to this date but repayment schedules should extend beyond this where appropriate.
  • Retailers should offer customers repayment schemes for a period up to 12 months.
  • Retailers should consider allowing an initial deferral of payments for up to 3 months.

T&Cs:

  • Retailers should have details on the Terms & Conditions of their Repayment Scheme on their websites.
  • The T&Cs should make clear the circumstances in which debt collection will recommence in the event of a customer defaulting. Given the difficult circumstances customers will be facing, we believe that debt collection should not immediately recommence following a single missed payment.
  • At the very least, retailers should publish a summary of the schemes on the website along with contact details for obtaining further information or discussing an application for the scheme.