Engage Consulting has deployed ISO9001:2015 accredited Lead Auditors to deliver independent audits of Prepayment (PPM) Levelisation submissions for several leading GB energy suppliers.
As part of Ofgem’s assurance requirements, energy suppliers were mandated to provide 12 months of submission data to the Retail Energy Code Company (RECCo). This dataset, central to the industry’s PPM Levelisation process, required a thorough audit to verify completeness, accuracy and the robustness of supporting processes.
Background
To prevent PPM customer’s bills from increasing following the conclusion of the EPG (Energy Price Guarantee) on 31st March 2024, Ofgem implemented non-volumetric PPM levelisation to apply a discount to PPM standing charges to replicate the support previously provided by the EPG.
RECCo was selected by Ofgem as the reconciliation operator for the non-volumetric Levelisation and tasked with developing the industry processes required to enable the assistance of payments between suppliers.
REC Schedule 31 sets out the detailed code operation for the non-volumetric Levlisation reconciliation mechanism and includes confirmation of the requirement for assurance activity to take place. Following an audit on the first six months of the scheme at the end of 2024, Ofgem contacted eligible domestic energy suppliers in December 2025 confirming the next set of audit requirements for the next 12 months of data submissions (1st October 2024 – 30th September 2025).
What our clients asked us to do
We were asked to undertake audits to assess energy supplier’s adherence to obligations in providing levelisation reconciliation data to RECCo.
The audits needed to be conducted to the ISRS 4400 auditing standard and cover the 12 months of reported data and associated activities for 1st October 2024 – 30th September 2025. The audits needed to follow the Agreed Upon Procedures (AUPs) outlined in Ofgem’s letter to energy suppliers dated 10th December 2025.
Draft and Final Audit Reports
We were required to produce audit reports detailing our findings across four AUPs laid out by Ofgem to industry, covering:.
- Data Completeness;
- Data Accuracy;
- System Processes; and
- Random Sampling.
Reports once drafted were approved by the energy suppliers and could then be submitted to Ofgem with an accompanying template.
Value to the client
Our clients successfully met Ofgem’s audit and submission requirements, supported by independent assurance from Engage Consulting’s ISO 9001:2015 accredited Lead Auditors. We provided confidence in the completeness and accuracy of RECCo submissions, validated key reporting controls, and helped reduce regulatory risk. Beyond compliance, our independent review strengthened reporting and governance arrangements, giving energy suppliers greater confidence in their ongoing PPM Levelisation obligations.