22 July 2025
At the Energy Live Consultancy Conference (ELCC) 2025, Dan Sullivan, Vice President for Mid-Market UK & Europe at SEFE Energy, joined a panel of industry leaders to explore the shifting dynamics of the energy brokerage landscape. The discussion offered valuable insights into the evolving roles of suppliers, third-party intermediaries (TPIs), and end customers amid a rapidly transforming market.
Several key areas were addressed, each of which are increasingly central to industry dialogue:
Broker Code of Conduct – Voluntary vs. Regulatory
The sector continues to debate whether broker conduct should be governed by a voluntary code or formal regulation. Recognising the complexity of the situation. RECCO (Retail Energy Code Company) has published the latest consultation on proposed updates to the Voluntary TPI CoP, with a survey to gather feedback from the industry.
There are multiple factors at play here. On one hand, it is incredibly important to establish consistent standards that ensure ethical practices and protect customer interests - but there is also an operational impact on suppliers and TPIs to consider. Bringing in additional regulation, while potentially offering huge benefits in terms of protections and standardisation, would almost certainly add an extra layer of compliance work to an already busy workforce.
Nevertheless, in general both the TPI community and the Energy Consultants Association are very supportive of an enforceable and regulated Code. The panellists at ELCC also backed the idea of a Kitemark style accreditation scheme, giving customers confidence in trusted brokers. It was noted that regulation will most likely take years to implement and go through the necessary legislative process; panelists urged the industry to take action rather than waiting for Ofgem (responsible for regulation) to reach a decision.
Commission Structures – Upfront vs. Monthly in Arrears
With transparency under the spotlight, Dan commented on a question from the audience in regard to exploring the potential shift from traditional upfront commission models to a “monthly in arrears” approach. Every TPI has a different business model in terms of strategy, sector target, route to market, and more.
For example, the online switching model, allowing consumers to change their energy supplier quickly and easily through online platforms, aims to make switching faster, more reliable, and consumer friendly. In this setup, costs such as data handling and marketing are initial costs for suppliers and TPIs, and therefore require some form of upfront income to be able to sustainably manage exposure and service customers. - With industry-wide transparency now fully implemented and enforceable across the UK, the commission-based payment model is in a much stronger position. It is critical to clearly communicate how and why TPIs are compensated for their services, making this process transparent and easy for customers to understand.
However, introducing a standardised commission structure across the industry could risk undermining market competitiveness, convenience, and the efficient simplicity that consumers currently benefit from - especially depending on their chosen route to market.
Data Sharing on Non-Compliant TPIs
Also discussed at ELCC was the possibility of suppliers collaborating to share intelligence on blacklisted or non-compliant intermediaries. While this raises questions around data governance and legal frameworks, it could be a powerful tool in safeguarding the integrity of the market.
There are risks involved when appropriate due diligence is not performed before entering a new supplier or TPI arrangement – the sharing of data in this way could be a valuable step towards making the due diligence process more straightforward. As it stands, there are a few ways to check if TPIs are accredited with the appropriate organisations, but there is not a single source of truth.
Accredited Broker Listings
SEFE Energy is considering publishing a list of accredited or registered brokers on its website. This initiative would provide customers with a clear reference point to verify broker legitimacy and ensure they are engaging with trusted partners when dealing with SEFE Energy.
At SEFE Energy, we support organisations looking to navigate the complexities of today’s dynamic energy market – and remain committed to fostering transparency, accountability, and collaboration across the value chain. We believe these conversations are essential to shaping a more resilient and customer-centric industry. If you would like to discuss any of this in more detail, or you have questions about your own energy supply, get in touch!