Ofgem publishes approved R0207 modification text, closing a two-year gap in export supplier MOA charging rules

Ofgem has published the approved modification text for Retail Energy Code change R0207, which settles how Meter Operator Agents (MOAs) charge export suppliers at shared metering points^[1]. The publication closes a procedural loop that began in late 2024 and was interrupted in May 2025 when Ofgem sent the proposal back for further work.

The problem R0207 was raised to fix

Under REC Schedule 14, export suppliers have no choice in which MOA they appoint: they must accept whichever agent the import supplier has selected^[1]. Unlike import suppliers, who can choose their MOA based on competitive rates and service quality, export suppliers are obliged to accept the MOA appointed by the import supplier. This lack of choice can lead to inflated charges and a possible lack of engagement between the import-appointed MOA and the export supplier.

The problem sharpens under MHHS. Under the MHHS design, a MOA accepting 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. Without a code fix, that automatic appointment would leave the charging relationship undefined at scale.

R0207 was raised specifically to resolve the charging question while the broader fix - R0144, which would allow different MOAs to be appointed for import and export metering points - remains on hold due to the MHHS programme.

A proposal sent back, then resubmitted

The modification's path was not straightforward. On 12 March 2025, the Metering Expert Panel voted to reject the Code Manager's recommendation to approve R0207, sending it to the Authority for decision. On 13 March 2025, the Final Change Report was submitted to the Authority, which decided it was unable to form an opinion on R0207 as submitted and sent the proposal back for further work.

The working group reconvened, revised the solution, and resubmitted. Ofgem has now approved the modification^[1].

What the approved text does

The approved modification clarifies the charging obligation between MOAs and export suppliers in scenarios where the MOA has been automatically appointed without a pre-existing bilateral contract. The key parties affected are:

• Export suppliers, who gain a defined basis on which MOA charges can be levied against them
• Meter Operator Agents, who gain clarity on their right to recover costs from export suppliers for services rendered at linked export metering points
• Import suppliers, whose existing contractual arrangements with MOAs are unchanged

The modification does not resolve the underlying competition issue - export suppliers still cannot appoint a different MOA from the one serving the import metering point. That question remains parked until R0144 is taken off hold after MHHS completes.

MHHS timing

The approval lands during an active phase of the MHHS migration. Suppliers that have not qualified by Milestone 14 on 28 October 2026 will be prevented from registering new MPANs until they become compliant. The full migration window closes at Milestone 15 on 7 May 2027, after which the incumbent settlement systems can be turned off.

Having the MOA charging rules settled before the migration window closes matters: as suppliers migrate metering points to MHHS arrangements, the automatic MOA appointment mechanism activates at scale. An unresolved charging gap at that point would have created bilateral disputes across a large number of export metering points simultaneously.

The next question for export suppliers is when R0144 - the modification that would give them genuine MOA choice - returns to the change management queue. That depends on how cleanly the MHHS programme reaches M15 in May 2027.