The Centre for Sustainable Energy (CSE) has submitted its response to Ofgem’s Draft Forward Work Programme for 2026-27.

The Forward Work Programme is a consultation document that Ofgem is legally required to publish. It lays out the energy regulator’s proposed future strategic priorities, key projects and operational plans.

You can download CSE’s response to the draft here (pdf).

CSE supports Ofgem’s four strategic priorities for the year ahead. But in each case we feel that more can be done to strengthen consumer interest. If you want the details, you’ll need to download the full response. But a brief overview is available below.

Strategic Priority 1: Shaping a retail market that works for consumers

We agree with the aim to support the retail market to develop products and services that improve customer outcomes and make it simple for customers to engage with flexibility, and, with consumer energy debt at record levels, the increased focus on systemic issues associated with debt prevention and recovery.

However, we are surprised to see no mention of billing. Nor are there any proposals for further work on low or zero standing charge tariffs, or alternative tariff reforms to support vulnerable customers.

Strategic Priority 2: Enabling infrastructure for net zero at pace

We welcome the underlying aim of ensuring acceleration of investment and projects required to meet the Clean Power 2030 ambition.

However, in respect to this strategic priority we would urge Ofgem to:

• Explore more explicitly the role that DNOs could play in demand reduction and energy efficiency.
• To understand better how grid connections reform impacts upon community and local authority-led schemes energy schemes.
• Given government policy to replace gas central heating with zero and low carbon alternatives, to begin planning for a diminishing (and less affluent) gas customer base across which gas system costs can be socialised.

Strategic Priority 3: Establishing an efficiency, fair and flexible energy system

We welcome Ofgem considering interventions to support consumers to take advantage of the expected increased choice of tariffs and products in the developing energy market.

However, we urge Ofgem to go further and to require suppliers to report on what they are doing to ensure vulnerable customers are being offered the cheapest smart energy tariffs appropriate to their needs and providing data on uptake of these by different groups. Fairness will not simply emerge in this market without purposeful monitoring and action.

We also maintain that suppliers should be required to report on how many of their smart meters are functioning correctly.

Strategic Priority 4: Advancing decarbonisation through low carbon energy and social schemes

The closure of the Energy Company Obligation represents a significant challenge to the energy efficiency industry, with many companies already collapsing. Ofgem needs to urgently and explicitly ensure protection for the many consumers directly affected by failed, or worse unfinished, insulation works installed by contractors who are no longer trading.