What Ofgem’s TPI Code of Practice Actually Means for Your Broker

Ofgem’s TPI Code of Practice Exists to Protect Business Energy Customers. Most Business Owners Have Never Heard of It.

The TPI Code of Practice is Ofgem’s framework for regulating the conduct of energy brokers, consultants, and comparison services operating in the UK non-domestic energy market. It sets out what brokers must do, what they must disclose, and what standards of conduct apply when they arrange energy contracts on behalf of business customers.

Understanding it doesn’t require reading the full regulatory document. But knowing the five things it requires of your broker — and knowing how to test whether your broker is actually compliant — is commercially valuable. A broker who isn’t meeting the code’s standards is one whose recommendations you should treat with considerably more scepticism.

What the TPI Code of Practice Is and Why It Exists

The non-domestic energy market has historically had a significant information asymmetry problem. Suppliers have full visibility of the commission structures they offer brokers. Brokers have full visibility of the quotes they obtain. Business customers — the buyers of the energy — have been largely in the dark on both dimensions.

This asymmetry created conditions for conduct that was technically legal but not in customers’ interests: brokers recommending higher-commission suppliers over lower-commission ones, concealing the existence or amount of commission, presenting single-supplier quotes as “the best available,” and recommending longer contract terms than the client needed in order to maximise commission income.

Ofgem’s TPI Code of Practice, developed through consultation with industry and consumer groups and operationalised through the TPI Working Group, is designed to address these problems. Brokers who commit to the code accept obligations that are enforceable and represent a minimum standard of professional conduct.

The Five Core Requirements

1. Commission disclosure on request

The Code requires that brokers disclose the existence of commission when arranging a contract, and provide the specific amount or rate upon the customer’s request. The disclosure must be clear and intelligible — not buried in terms and conditions, not described in ambiguous language, not deflected with phrases like “we’re paid by the supplier.”

In practice, many brokers meet the technical letter of this requirement — they will disclose if directly and persistently asked — while doing nothing to proactively inform customers that commission exists. The spirit of the requirement is proactive disclosure at the point of recommendation. The letter requires disclosure on request. There is a meaningful gap between these two positions.

What this means for you: You have the explicit right to ask your broker how much commission they receive on any contract they recommend. The answer should be a specific figure (in £ or in p/kWh) for the specific contract being recommended. If the broker cannot or will not provide this, they are not meeting the code’s disclosure standard.

2. Acting in the customer’s best interest

The Code requires that brokers make recommendations based on what is most suitable for the customer — taking into account the customer’s consumption profile, risk tolerance, budget requirements, and contract preferences — rather than recommendations that maximise the broker’s income.

This requirement is the most significant in principle and the most difficult to enforce in practice, because it requires an assessment of intent and outcome rather than a simple procedural check. A broker who recommends a 36-month contract to every client regardless of market conditions may be systematically meeting this standard — if 36 months genuinely was in each client’s interest — or may be maximising commission on every renewal. The difference is not visible from the contract itself.

What this means for you: Ask your broker why they are recommending the specific contract structure (length, supplier, fixed or flexible) they propose. The answer should reference your specific situation — your consumption profile, the current market conditions, your business’s operational context — not be a generic statement about “market conditions” that could apply to any customer.

3. Maintaining an adequate supplier panel

The Code requires brokers to access a sufficient range of suppliers to conduct a genuinely competitive market comparison. A broker operating from a panel of 3–4 suppliers cannot credibly claim to have compared the market on your behalf.

There is no specific numerical requirement for panel size in the code — “sufficient” is a judgement based on the market available. In the UK non-domestic market, which has 20–30 active mainstream suppliers plus several specialist operators, a genuinely competitive panel should include at least 10–15 active suppliers for any given customer profile.

What this means for you: Ask your broker how many suppliers they approached for your contract and which ones returned quotes. Request the comparison showing all quotes received. A broker who presents a single quote, or who won’t show you the comparison, is not demonstrating adequate market access.

4. Transparent contract terms

The Code requires that the contract terms presented to the customer are clearly explained — including the contract length, unit rates, standing charges, notification periods, auto-renewal provisions, and early termination terms. Hidden or inadequately explained contract terms that subsequently cause detriment to the customer are a breach of this requirement.

The most practically significant element here is auto-renewal: the Code requires that customers are made aware of the notification window, the deadline by which they must act to avoid the contract rolling over automatically. A broker who fails to flag the notification deadline, or who allows the deadline to pass without alerting the client, is not meeting the transparent terms requirement.

What this means for you: When your broker presents a contract recommendation, ask them specifically: “When is the notification deadline? What happens if I miss it?” The answer should include the specific date and the consequence (auto-renewal at the supplier’s discretion). If your broker has managed your contract for more than one term and you’ve never been told the notification deadline, that’s a gap in the service you’re receiving.

5. Handling complaints appropriately

The Code requires brokers to have a clear complaints process and to handle complaints from business customers in a timely and fair manner. Where complaints cannot be resolved directly, the code provides escalation routes, including the Dispute Resolution Ombudsman (formerly the Energy Ombudsman) for micro-businesses and formal regulatory complaint routes for larger customers.

What this means for you: If you have a complaint about your broker’s conduct — a recommendation that resulted in a materially worse outcome than competitive procurement would have delivered, undisclosed commission, or inadequate market access — you can raise a formal complaint with the broker and escalate to the DRO if the complaint isn’t resolved.

Ofgem TPI Registration: What It Does and Doesn’t Mean

Brokers who commit to the TPI Code of Practice are listed on Ofgem’s TPI register, which is publicly searchable. Registration means the broker has committed to the code’s standards — not that they are continuously monitored for compliance.

Ofgem TPI registration is a necessary but not sufficient indicator of broker quality. A registered broker has made a commitment to the code. Whether they’re living up to it in their day-to-day practice requires the questions and scrutiny described above.

Telnergy is an Ofgem registered TPI (ADR Ref E3561). We support the code because raising professional standards across the broker market benefits businesses and the industry alike.

The Practical Test

Four questions that test TPI Code compliance in practice. Ask them of any broker you use or consider using:

1. “What commission will you receive on this contract — specifically, in pence per kWh or as a total £ amount?” Required by the code. Evasion = non-compliance signal.
2. “How many suppliers did you approach for this contract?” Adequate panel access requirement. Expect 10–15+.
3. “Why is this specific contract structure — length, supplier, terms — the right one for my business?” Client-specific best interest requirement. Generic answers = inadequate reasoning.
4. “When is the notification deadline on this contract, and what happens if I miss it?” Transparent terms requirement. If they can’t answer immediately, raise it as a concern.

A broker who answers all four questions clearly and without hesitation demonstrates code compliance in the most direct way possible. A broker who deflects, provides vague answers, or treats the questions as unreasonable is telling you something important.

Telnergy and the TPI Code

We disclose commission on every contract we recommend. We access 21+ suppliers for every comparison. We provide a client-specific market assessment with every recommendation. We track notification deadlines and flag them proactively. And we have a clear complaints process.

We tell you this not as a credential recitation, but because it sets the standard that every broker should be meeting — and most of the businesses we speak to have never experienced it from their previous adviser.

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Telnergy Limited · Independent commercial energy consultancy since 2002 · Ofgem registered TPI · ADR Ref E3561 · CRN 04576876 · Christchurch, Dorset