Ofgem publishes consumer protection guidance for the SSES load control licence ahead of end-2026 application window

Ofgem has published its consumer protection guidance for the Smart Secure Electricity Systems (SSES) load control licence, setting out the compliance obligations that Flexibility Service Providers (FSPs) will be required to meet once the new licensing regime takes effect^[1]. The guidance is the finalised version of the draft that accompanied Ofgem's December 2025 consultation on implementing the regime, and it arrives as DESNZ prepares to lay the enabling regulations in Autumn 2026.

What the licence covers

The load control licensing regime is designed to regulate entities that control the flow of electricity into or out of domestic Energy Smart Appliances (ESAs) - including EV chargers and heat pumps - in response to digital signals^[1]. The scope also extends to certain ancillary devices used to control load on ESAs and private EVs.

The regime splits licensees into two categories with distinct obligations:

• Load Controllers (LCs) - required to meet cyber security requirements and comply with relevant industry codes; a basic and enhanced tier of requirements scales with aggregate load, with the enhanced tier applying above 300 MW^[1]
• Flexibility Service Providers (FSPs) - required to meet the consumer protection conditions set out in the guidance now published, covering fair treatment, complaints and redress, and protections for vulnerable consumers

Unlicensed load control activity will become a criminal offence once the regime is fully in force, with Ofgem as the enforcing authority.

Consumer protection framework

The guidance sets a baseline standard for FSPs engaging domestic consumers in load control arrangements. The framework is designed to align, where possible, with existing electricity supply licence protections rather than create parallel obligations - an explicit policy choice to limit regulatory divergence and administrative burden on businesses that already hold a supply licence.

Key requirements include:

• Fair treatment and transparent service offerings, enabling consumers to compare products without being unfairly locked into contracts
• Simple and consistent complaints and redress processes
• Additional protections for consumers in vulnerable situations
• Phased implementation, with the first set of requirements representing a minimum standard that will be built on over time^[1]

Consumer protection requirements will be phased in over time, with the initial obligations representing a minimum standard of acceptable protection.

Timeline

DESNZ intends to lay the Load Control Licence Regulations in Autumn 2026, with licence applications opening by the end of 2026. The legal requirement to hold a licence is expected to come into force by the end of 2027, following a 12-month statutory transition period during which unlicensed activity will not be an offence.

Ofgem will manage the full licence application review process for the first 12 months from the application window opening, before governance responsibilities evolve toward industry-led arrangements under the SSES enduring governance framework.

What to watch

The publication of final consumer protection guidance clears one of the remaining pre-application milestones. DESNZ still needs to lay the statutory instrument and finalise the class exemptions order - which will determine which technologies and consumer types fall outside the licensing requirement entirely. Prospective licensees, particularly those operating at the intersection of EV charging and domestic flexibility, should now be assessing their compliance posture against the published guidance ahead of the application window opening later this year^[1].