Ofgem approves REC R0207, settling export supplier MOA charging rules ahead of MHHS migration

Ofgem has approved Retail Energy Code (REC) modification R0207: Import/Export MOA Charging Clarification, closing a long-running dispute over how Meter Operator Agents (MOAs) charge export suppliers for metering services^[1]. The decision lands as the Market-wide Half-Hourly Settlement (MHHS) migration is already underway, with roughly 80% of meters targeted for acceptance into the new settlement arrangements by October 2026.

The problem R0207 was raised to fix

Under REC Schedule 14 (Metering Operations), export suppliers have no say in which MOA is appointed to their metering points. Historically, export suppliers have faced challenges due to the lack of flexibility in appointing MOAs: unlike import suppliers, who can choose their MOA based on competitive rates and service quality, export suppliers are obligated to accept the MOA appointed by the import supplier. This lack of choice may lead to inflated charges and a possible lack of engagement between the import-appointed MOA and the export supplier, ultimately disadvantaging export suppliers.

The issue was compounded by a contractual gap. Because an export supplier has no choice in which MOA it appoints, it must in practice hold contracts with every MOA in the market in order to match whichever import MOA is in place. The proposer considered that this reduces competition for export suppliers and may lead to unfair or inflated charging from export MOAs.

A long road to approval

R0207 has had a turbulent passage. On 12 March 2025, the Metering Expert Panel voted to reject the Code Manager's recommendation to approve the change, sending it to the Authority for decision. On 13 March 2025, the Final Change Report was submitted to Ofgem, which decided it was unable to form an opinion on the proposal as submitted and sent it back for further work.

The working group that followed found the original solution - obligating MOAs to treat all suppliers equally - unviable on several grounds:

• Unintended consequences in a competitive market
• Enforcement challenges for the REC Performance Assurance Board and Code Manager
• Legal ambiguity over whether the text would apply to all services, not just export

A revised proposal was developed and has now received Ofgem's approval^[1].

MHHS changes the underlying architecture

The timing matters because MHHS is restructuring how agent appointments work across the board. Under the MHHS design, a MOA accepting an appointment for an import metering point is automatically appointed for any linked export metering point - completed automatically, regardless of whether a contract exists between the MOA and the export supplier. That automatic linkage is precisely the scenario R0207's charging clarification needed to address: if no bilateral contract governs the relationship, the code must be explicit about how charges flow.

Both BSC Modification 459 and REC Change Proposal R0144 - the broader proposals to allow different Metering Equipment Managers to be appointed to import and export metering points - were placed on hold due to the MHHS programme, which is why R0207 was raised to resolve the charging issue specifically.

MHHS migration began in September 2025 and is scheduled to complete in May 2027, with Elexon targeting approximately 80% of meters accepted into the new arrangements by October 2026.

What to watch

The approval of R0207 removes one code ambiguity ahead of the peak MHHS migration window running from now through May 2027. The larger question - whether R0144 and BSC Mod 459 will be revived once MHHS is fully live - remains open. Parties with export metering obligations should confirm their contractual arrangements with MOAs align with the clarified REC text now in force.