The UK’s energy system is transforming rapidly as we generate more renewable energy. But without the right infrastructure and safeguards, we risk creating a two-tier system. One where affluent, tech-savvy households benefit from lower bills, while other households in more vulnerable circumstances are left behind paying more.

Two new government consultations – on completing the smart meter rollout by 2030 and on consumer-led flexibility – offer a chance to get this right. CSE has responded to both, because they’re fundamentally linked. You can’t have a fair, flexible energy system without smart meters in every home that wants one.

Smart meters track energy use in real time, while flexibility rewards customers for using power when renewable energy is plentiful. Both are essential for a smart and green energy system that cuts bills.

Smart meters are essential infrastructure

The government’s consultation on the Smart Metering Policy Framework post-2025 sets out its ambition for all households to have a working smart meter by 2030. It’s a good goal.

Smart meters are not gadgets: they are foundational infrastructure. Without them, the UK cannot deliver a smart, flexible, low-carbon energy system. And without equal access, poorer or digitally excluded households risk being left behind.

At CSE, through our advice line, home visits and research, we see daily how smart meters help people. They reduce inaccurate bills, increase customer understanding as to why their bills are high, and enable access to smarter tariffs and energy services that can cut energy bills.

This is why we support a no-nonsense approach to the smart meter rollout that would require energy suppliers to submit yearly smart meter deployment plans shaped around their customer base. It would signal that the government means business, and that the (currently stalled) rollout of smart meters will be completed on time.

The final stage will be the hardest though – reaching rural homes, flats, private renters, and those resistant to installation. Suppliers’ deployment plans should specifically address these groups with targeted actions.

To get there, the government should ensure vulnerable groups and renters are included – including mandatory smart meter installation in new rental properties. Supplier obligations need tightening so faulty meters and in-home displays are repaired faster, with clear consumer protections. And the rollout timetable should be accelerated and the proposed ‘gap year’ in 2026 (during which there will be no targets) ruled out.

Additionally, in-home displays (which for many households are the most effective way to engage with their energy use) have barely advanced in their design or functionality since their introduction. The government and Ofgem should update minimum functionality requirements for in-home displays and explore traffic-light signals for time-of-use tariffs, peak demand alerts, and carbon intensity indicators.

Consumer-led flexibility: making smart energy work for all

The second consultation addresses consumer-led flexibility: how to get customers using energy when renewable generation is plentiful. Participation requires more than access to technology like batteries, smart meters and solar panels. Household energy demand, financial situation, lifestyle, and digital confidence all shape whether people can engage effectively.

Without a joined-up approach, only the well-off and tech-savvy will benefit.

Our research shows that barriers go beyond technology. Vulnerable households may lack the time, digital skills, or financial security to explore smart tariffs or new technologies. Trust is also a major factor, particularly regarding smart meters and suppliers. And flexibility carries risks.

In our CrowdFlex winter trial (which tested the public’s willingness to move their energy demand), one in five survey respondents said they used less electricity than they needed in order to take part, such as sitting in the cold or dark, with vulnerable households more likely to take these risks.

Meanwhile, the market is growing fast. Our Smart and Fair market monitoring tracks over 170 smart energy offers yet disparities in access are widening and consumers face confusing information and inconsistent terminology.

The government’s proposal for a consumer engagement framework – run by an independent body to set standards and provide advice – reflects much of what we’ve called for through our Smart and Fair programme since 2019. Our key finding: fair outcomes won’t emerge naturally from the market. Government intervention is essential. Four core functions are critical and must work together.

1. Coordination means providing impartial, plain-English insight into the flexibility market, highlighting gaps in provision.
2. Standards must embed fairness, ensuring providers deliver positive outcomes, not just avoid harm.
3. Advice needs to be independent, local and tailored. Personalised guidance increases confidence and uptake of smart energy options.
4. Communications must be clear, motivating and targeted, reflecting diverse motivations – from cost savings to environmental impact.

Monitoring and data collection underpin all this. Without visibility of who benefits, providers may engage only wealthier consumers, leaving vulnerable households behind.

Acting now to avoid exclusion

The government’s proposed timeline of 2028 for a consumer engagement framework is too late. The flexibility market is already growing, and delay risks mis-selling or consumer confusion. We need action now, building on Smart and Fair, the HomeFlex code of conduct, and insights from projects such as CrowdFlex and Smart Energy Action Plans (SMEAPS).

Smart, fair and trusted energy

If designed well, consumer-led flexibility can lower bills, support net-zero targets, and create a cleaner, more resilient grid. Achieving this requires:

• Better monitoring of who benefits.
• Clear standards prioritising fairness.
• Independent, tailored advice that people trust.
• Joined-up communications reflecting real motivations and barriers.

People want to engage with flexibility, but they need confidence it will work for them. By linking the rollout of smart meters with a strong, consumer-led flexibility framework, we can create an energy system that is smarter, fairer and inclusive – delivering real benefits to everyone, not just early adopters.