Decision
OFG1163
Reviewing the Consolidated Segmental Statements Our Decision
Publication date: 1 February 2024
Contact: Andrew Milligan
Team: Retail Financial Monitoring
This document sets out our decision to revise the licence conditions requiring publication
of a Consolidated Segmental Statement (CSS). The effect of these modifications is to
expand the CSS reporting obligation to cover a wider proportion of the domestic and
non-domestic market, providing greater transparency of supplier profitability.
These modifications to the Standard Licence Condition (SLC) 19A of the Gas and
Electricity Supply Licences and SLC 16B of the Electricity Generation Licence will take
effect from 29 March 2024.
Decision Reviewing the Consolidated Segmental Statements Our Decision
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© Crown copyright 2023
The text of this document may be reproduced (excluding logos) under and in accordance
with the terms of the Open Government Licence.
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Any enquiries related to the text of this publication should be sent to Ofgem at:
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Decision Reviewing the Consolidated Segmental Statements Our Decision
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Contents
Reviewing the Consolidated Segmental Statements Our Decision ........ 1
1. Introduction ...................................................................................... 4
Context and related publications ........................................................... 4
Our decision-making process ................................................................ 5
Decision-making stages ................................................................... 5
Implementation .............................................................................. 6
General feedback ............................................................................ 6
2. Decision to modify the CSS licence requirement ................................ 7
What did we consult on? ...................................................................... 7
Summary of stakeholder feedback and our decision ................................. 7
Aims of the CSS ............................................................................. 7
Supplier Thresholds ......................................................................... 8
Generation and ‘Other’ Activities ...................................................... 11
Auditing ....................................................................................... 12
Reporting and Transition Period ....................................................... 13
Next Steps ........................................................................................ 16
Appendices ........................................................................................... 17
Appendix 1 Licence Condition Modifications ....................................... 18
Gas SLC 19A: Financial Information Reporting........................................ 18
Electricity SLC 19A: Financial Information Reporting ............................... 21
Electricity Generation SLC 16B: Financial Information Reporting ............... 24
Appendix 2 Revised CSS Guidelines.................................................... 26
Revised Guidelines for preparing the CSS .............................................. 26
Appendix 3 Templates ........................................................................ 33
CSS template after reconciliation adjustments. ....................................... 33
Template displaying reconciling items to the statutory accounts ................ 34
Decision Reviewing the Consolidated Segmental Statements Our Decision
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1. Introduction
Section summary
This section sets out the context for our decision and informs stakeholders about the
steps we have taken to arrive at our decision.
Context and related publications
1.1. The Consolidated Segmental Statement (CSS) licence condition was introduced in
2009 with the aim of providing a better understanding of the relationship between
the generation and energy supply business of vertically integrated companies by
reporting each business segment’s profitability separately. This was to address
concerns of vertically integrated companies cross-subsidising their supply
business with their generation activities.
1.2. In today’s energy market vertical integration is no longer a significant feature and
in recent years only four suppliers have been obliged to submit a CSS. It therefore
became necessary for us to review the licence conditions to ensure the CSS can
support our work in an evolving energy market.
1.3. On 25 August 2023, we published a policy consultation seeking views on our
proposals to revise Standard Licence Condition (SLC) ‘Financial information
reporting’, which requires publication of a CSS.
1.4. On 30 November 2023, we published a statutory consultation amending our
proposals in light of stakeholder feedback.
1.5. We are now publishing our decision, following the consultation process, to amend
the licence conditions which will expand the CSS reporting obligation to a wider
proportion of the domestic and non-domestic markets. This decision aims to
increase transparency of supplier company profitability which is key in monitoring
whether the market is working well for consumers and is also important in
building consumer confidence. Providing third parties access to this information
also allows them to hold challenge to both suppliers and Ofgem as regulator.
1.6. The CSS will be kept under review to ensure the requirements remain fit for
purpose.
Related Publications
Policy Consultation (2023):
https://www.ofgem.gov.uk/publications/reviewing-consolidated-
segmental-statement-our-initial-proposals
Decision Reviewing the Consolidated Segmental Statements Our Decision
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Statutory Consultation (2023):
https://www.ofgem.gov.uk/publications/reviewing-consolidated-
segmental-statements-our-final-proposals
Links to suppliers’ Consolidated Segmental Statements under previous
SLC 19A condition:
https://www.ofgem.gov.uk/publications/energy-companies-consolidated-
segmental-statements-css
Our decision-making process
1.7. We have engaged with stakeholders throughout our decision-making process. We
issued a policy consultation with our initial proposals in August 2023. We then
issued a statutory consultation on proposed licence changes in November 2023.
1.8. Alongside these formal consultations we have engaged informally with
stakeholders, meeting bilaterally to listen to their feedback.
Decision-making stages
Stage 1
Stage 2
Stage 3
Stage 4
Stage 5
Stage 6
Policy
Consultation
open.
Consultation
closes.
Deadline for
responses to
Policy
Consultation.
Responses
reviewed and
Statutory
Consultation
published.
Statutory
Consultation
closes.
Deadline for
responses.
Responses
reviewed and
published.
Publish
modification
decision.
Revised licence
modification to
take effect (56
days after the
modification
decision).
25/08/2023
22/09/2023
30/11/2023
12/01/2024
01/02/2024
29/03/2024
Our Decision
1.9. Following stakeholder engagement, we have decided to make changes to
Standard Licence Conditions (SLCs) to expand the CSS reporting obligation to
cover a wider proportion of the domestic and non-domestic energy market.
1.10. Accordingly, this decision document is accompanied by Decision Notices to
modify:
SLC 19A of the Gas Supply Licence
SLC 19A of the Electricity Supply Licence
SLC 16B of the Electricity Generation Licence by removal of licence condition
16B
The Guidelines for submitting the CSS
Decision Reviewing the Consolidated Segmental Statements Our Decision
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Implementation
1.11. The revised licence conditions will come into effect on 29 March 2024 (56 days
after the modification decision is published). We expect obliged suppliers to
publish a CSS with their 2023 accounts no more than ten months after their 2023
financial year-end. For example, if a company has a December year-end, we
expect publication by October 2024. If a company has a March year-end, we
expect publication by January 2025.
Next Steps
1.12. Previously CSS data was published within several indicators on our Data Portal
1
however this was paused as the CSS data was no longer representative of the
market. Following this decision to expand the CSS obligation to cover a wider
proportion of the domestic and non-domestic market, we will aim to restore
publication of indicators and scope additional indicators where we see a benefit to
consumers and/or third parties.
1.13. Our decision aims to increase transparency of supplier profitability and ensure
consumers are treated fairly. We will keep our decision under review to ensure
that the CSS meets our objectives and is proportionate in doing so.
General feedback
1.14. We believe that consultation is at the heart of good policy development. We are
keen to receive your comments about this report. We’d also like to get your
answers to these questions:
1. Do you have any comments about the overall quality of this document?
2. Do you have any comments about its tone and content?
3. Was it easy to read and understand? Or could it have been better written?
4. Are its conclusions balanced?
5. Did it make reasoned recommendations?
6. Any further comments
1.15. Please send any general feedback comments to [email protected].
1
Ofgem Data Portal:
https://www.ofgem.gov.uk/data-portal/overview
Decision Reviewing the Consolidated Segmental Statements Our Decision
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2. Decision to modify the CSS licence requirement
Section summary
We outline our decision to modify the CSS licence requirement, following our
consideration of stakeholder feedback to the 2023 statutory consultation.
What did we consult on?
2.1. This decision paper is following our CSS statutory consultation published in
November 2023 where we set out our final proposals to revise the CSS licence
conditions. Our proposals considered four key changes relating to removing the
requirement to hold a generation licence, lowering the domestic and non-domestic
threshold levels, removing the audit requirement and to request an additional
column reporting on ‘other’ activities separate to the supply or generation
business.
2.2. We received a total of 15 responses to our CSS statutory consultation. We have
considered stakeholder responses and have responded through our decisions as
detailed below.
Summary of stakeholder feedback and our decision
Aims of the CSS
Our November 2023 Statutory consultation proposal
2.3. We proposed to keep the CSS within licence conditions and lower the thresholds
to increase market coverage in both the domestic and non-domestic market. This
aims to increase transparency in the energy supply market and capture
information that is representative and proportionate in terms of the number and
type of suppliers.
Stakeholder Feedback
2.4. Two respondents noted that their financial information is available on Companies
House and there is no further insight to be gained from the CSS for Ofgem,
consumers or third parties.
2.5. One stakeholder mentioned they do not see how the CSS would aid consumer
understanding and suggested a wider campaign of education would be better
placed to increase public confidence in the retail energy market.
Decision Reviewing the Consolidated Segmental Statements Our Decision
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Decision
2.6. We have decided to keep the CSS licence condition in place and expand to cover a
wider share of the domestic and non-domestic markets. This will result in
inclusion of suppliers who previously were not obliged to publish a CSS, making
visible to the public.
2.7. The CSS includes financial information on the supply business separate to any
other activities, which is not always the case for statutory accounts on Companies
House. Further, the CSS is split between fuel type and the domestic and non-
domestic supply business allowing consumers and third parties a view of
profitability for different energy supply market segments.
2.8. The CSS should be provided at a Group level where applicable, and this supports
our aims of providing transparency of supplier profitability, rather than the
licensee level which is provided in Companies House. Many suppliers hold multiple
licences, and a CSS at Group level will allow a view of how the different entities
integrate for oversight of a company’s supply business profitability in its entirety.
2.9. We will continue to publish a list of supplier CSS publications to our website, for
the public and industry’s ease of access, aiming to encourage engagement and
confidence in the energy supply sector.
Supplier Thresholds
Our November 2023 Statutory consultation proposal
2.10. We proposed to remove the requirement for a supplier to hold a generation
licence to be a Relevant Licensee under the CSS licence condition, as vertical
integration is no longer a significant feature of the market.
2.11. We proposed to use a static threshold figure for the domestic and non-domestic
market. We proposed to lower the domestic threshold level to 50,000 or more
meter points in either gas or electricity.
2.12. For the non-domestic market, we changed our proposal to use a static threshold
instead of a threshold based on market share of supply volumes. This allows
suppliers to internally monitor when they fall under the threshold for CSS
submissions. Using a static threshold measure preserves the confidentiality of
supplier pricing unlike using volume of supply to calculate market share. We found
that using volume of supply could capture suppliers with only a few customers
and could show potentially commercially sensitive information. We found 10
meter points, in either gas or electricity, currently provides coverage of around
90% of the suppliers in the non-domestic market and meets our aim of collecting
CSS data which is broadly representative of the market. We noted that thresholds
Decision Reviewing the Consolidated Segmental Statements Our Decision
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may be periodically reviewed if market changes result in the CSS submissions
becoming unrepresentative, and any changes would be made following
consultation.
Stakeholder Feedback
2.13. In response to supplier thresholds, feedback from stakeholders revealed varying
perspectives. Many of the respondents were in favour of the thresholds, with
some noting the move to a static threshold for the non-domestic market is more
straightforward. One respondent agreed this will capture most of the non-
domestic market and will enable transparency.
2.14. Some respondents expressed concerns, emphasising the disproportionate impact
of CSS on small suppliers. One proposed a solution by suggesting a reduction in
the burden through the removal of duplicate information from RFI's.
2.15. On the contrary, another respondent advocated for the absence of any threshold,
suggesting the application of CSS to all suppliers.
2.16. One stakeholder recommended the non-domestic threshold count should exclude
meters which supply to any affiliate business and suggested introducing an
additional test based on the annual volume of supply to prevent capturing small-
scale businesses.
Decision
2.17. In line with proposals in the statutory consultation, we have decided to remove
the requirement for a supplier to hold a generation licence to be a Relevant
Licensee under the CSS licence condition. We have decided to lower the domestic
threshold level to 50,000 or more meter points in either gas or electricity. For the
non-domestic market, we have decided to lower the threshold to 10 or more
meter points in either gas or electricity.
2.18. Following stakeholder feedback, we are clarifying here, and have decided to clarify
in the guidelines, that the non-domestic meter count may exclude meters which
supply to the company itself or any affiliate. Where meters supplying the company
itself or any affiliates are excluded for the purposes of the Relevant Licensee
thresholds and this would result in the Relevant Licensee thresholds not being
met, the company should apply to Ofgem for a direction that the CSS requirement
does not apply and Ofgem will consider whether in the circumstances it is
appropriate to grant such a direction. Such applications should include the number
of meters and details of meters being excluded by emailing [email protected] so
that this information may be verified as appropriate. We have decided to provide
the ability for suppliers to apply for and ability for Ofgem to consider and
Decision Reviewing the Consolidated Segmental Statements Our Decision
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grant/refuse such a direction in the SLCs in support of this. Examples of when
such a direction might be considered are given in the Guidelines. The use of this
process will be kept under review to ensure the requirements remain fit for
purpose.
2.19. We have decided that suppliers will become obliged to submit a CSS if they reach
the threshold in the last month of their financial year.
2.20. We expect suppliers to internally monitor where they sit in relation to the
thresholds and publish a CSS when required. We will internally monitor suppliers
against Relevant Licensee thresholds using data regularly sourced from Xoserve
and Distribution Network Operators (DNOs)., However, we will not be publishing a
list of obliged companies on our website as the responsibility to publish a CSS sits
with the Relevant Licensee.
2.21. Following feedback, we have decided not to include a minimum supply volume
threshold to prevent capturing small-scale businesses. However, we have decided
to introduce the ability for a supplier to request a direction that the CSS condition
does not apply for our consideration of an exemption on a case by case basis, for
example instances as set out in this decision document and in the Guidelines.
2.22. The CSS aims to view profitability across the supply sector, and for this reason we
are requesting CSS publication at the Group level where applicable. This may
include suppliers and affiliates with non-traditional supply businesses, for example
emergency supply. Where a supplier operates solely for non-traditional supply,
and has no affiliate with a traditional supply business, a supplier may apply to
Ofgem for a direction that the CSS requirement does not apply which will be
considered on a case by case basis.
2.23. We’ve determined this will not impose significant burden on suppliers as these
thresholds will include companies who will be publishing statutory accounts to
Companies House, as is required by private and public limited companies. The
information requested within the CSS will provide a top-level view of companies’
energy supply profitability with the split between gas and electricity as well as
domestic and non-domestic suppliers improving transparency within the market.
There are reporting requirements currently in place where companies provide
detailed financial information to Ofgem and this should aid with their preparation
of the CSS in its new reduced format.
2.24. We intend for the CSS to be complementary to our other monitoring activities.
While we cannot guarantee that some areas will not overlap, the CSS is distinct in
that it provides actualised financial information which is linked to statutory
accounts and undergoes an audit process whereas, for example, RFI’s include live
Decision Reviewing the Consolidated Segmental Statements Our Decision
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and forecasted data. We aim to limit regulatory reporting and are continually
working to streamline RFI’s where possible.
2.25. We aim for changes to the CSS requirement to be enduring and we aim to capture
information that is broadly representative and proportionate in terms of the
number and type of suppliers. Our decision will achieve this and allow us to collect
data on suppliers as they grow and, at the same time, strike the right balance
between the burden placed upon smaller suppliers and market coverage.
Generation and ‘Other’ Activities
Our November Statutory consultation proposal
2.26. Following feedback to the August Policy Consultation
2
, we proposed to remove the
inclusion of ‘other’ activities within the CSS. In addition, we proposed to remove
the existing requirement to report on generation activities.
Stakeholder Feedback
2.27. All stakeholders who responded on this point agreed with our proposal to remove
generation and ‘other’ activities; asserting that focusing solely on publishing
energy supply activities adequately reflects market changes since the 2021 CSS
review
3
, aligning with the goal of increased transparency. One respondent cited
this as a positive step that avoids costly system changes and addresses concerns
about commercially sensitive information.
2.28. One respondent noted their agreement with the removal of the request for
information on transfer pricing policies and methodologies.
Decision
2.29. Our decision is to remove the requirement to report generation activities in the
CSS template. Therefore, the CSS will only capture the energy supply business of
a supplier. Subsequently, we will not be requesting statements on transfer pricing
policies and methodologies.
2.30. This decision considers feedback received and recognises that the market has
changed significantly. The purpose of the CSS is to ensure transparency in the
2
Ofgem Policy Consultation (2023):
https://www.ofgem.gov.uk/publications/reviewing-consolidated-segmental-statement-our-initial-
proposals
3
Ofgem Statutory Consultation (2021):
https://www.ofgem.gov.uk/publications/final-proposals-and-statutory-consultation-reviewing-
consolidated-segmental-statement
Decision Reviewing the Consolidated Segmental Statements Our Decision
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market, and we believe that information on the energy supply related activities
will provide the transparency required.
Auditing
Our November Statutory consultation proposal
2.31. We proposed to remove the auditing requirement and request the CSS be
reconciled back to statutory accounts which undergo a separate audit process.
We confirmed that we may require an audit in some circumstances, e.g. if we had
reason to think the CSS hadn't been properly prepared.
Stakeholder Feedback
2.32. In response to the proposed removal of the audit requirement and aligning
reporting timelines with statutory accounts, feedback from numerous respondents
indicated overall agreement. However, two respondents sought clarity on defining
triggers for ad-hoc audits and their potential scope.
2.33. A stakeholder called to lower the bar for requesting ad-hoc audits to elevate CSS
preparation standards, while three respondents expressed concerns about
reconciling CSS requirements with statutory accounts. Specifically, they pointed
out discrepancies in EBITDA level information and the domestic/non-domestic
split, suggesting that requirements should reconcile back to the relevant entity
rather than group accounts.
2.34. One respondent highlighted the challenge of implementing consolidation for non-
consolidated financial accounts, requesting a transition period. Another
respondent proposed Ofgem’s removal of the requirement to include fuel-cost
splits, arguing that this adjustment would make CSS more comparable.
2.35. Finally, one respondent advocated for a clear and comprehensive explanation of
how revenues and profits should be reconciled with licensee statutory accounts,
emphasising the need for both numerical and written statements for
transparency.
Decision
2.36. As proposed in our 2023 statutory consultation, we are removing the auditing
requirement and request the CSS to be reconciled back to statutory accounts. We
may require an audit where we consider the CSS may not have been properly
prepared. This could be due to, but not limited to, data quality or where we
consider there may be omissions or errors. We do not believe the costs involved
in an ad-hoc audit should be a deterrent for Ofgem to further investigate whether
the financial information published is accurate and robust.
Decision Reviewing the Consolidated Segmental Statements Our Decision
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2.37. Suppliers should be able to reconcile back to total figures in their statutory
accounts. We require the CSS to be reconciled with any audited accounts for their
business. We also require a clear reconciliation table with explanations to be
provided detailing how items have been reconciled, and this can be at group or
entity level. An example reconciliation table is provided in Appendix 3. We believe
there is adequate time for suppliers to set up reporting processes given that the
publication is required at the latest 10 months after their financial year-end.
2.38. We have decided to remain with the split between fuel costs in the CSS as this is
in line with our aims of transparency on current and future market conditions.
There are many consumers who do not have access to gas, and whose interests
are in the electricity market.
2.39. We require the revenues and profits to be reconciled to audited accounts and
have provided guidance on how this can be done in Appendix 2. We request that a
written statement is also provided in conjunction with a reconciliation table which
should include explanatory notes to support the reconciliation.
Reporting and Transition Period
Our November Statutory consultation proposal
2.40. Following stakeholder responses to our August Policy Consultation, we proposed
to change the publication deadline from four months post year-end to nine
months post year-end to align with statutory accounts. We proposed not to
include a transition period as we proposed to simplify the CSS by removing
generation and ‘other’ activities reporting, and we consider that this provides
sufficient time to prepare the report.
Stakeholder Feedback
2.41. Many respondents supported our proposal to align CSS publication with statutory
accounts. One respondent specifically mentioned they agree with no transition
period.
2.42. One respondent noted that we had not accounted for public companies who must
submit statutory accounts 6 months post their financial year-end.
2.43. One respondent argued the obligation is to publish a CSS, and not to submit to
Ofgem directly as referred to in the statutory consultation.
2.44. While one respondent endorsed the reporting timelines, they suggested licence
conditions should offer flexibility to accommodate extensions granted by
Companies House.
2.45. Another respondent requested clarification on whether a relevant licensee should
report figures for any affiliate that does not hold a supply licence. They also
Decision Reviewing the Consolidated Segmental Statements Our Decision
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requested clarification on whether an affiliate which has a supply licence who does
not reach any threshold is to be included in the CSS.
Decision
2.46. Following stakeholder feedback, and to simplify the approach, our decision is for
the CSS to be published no later than 10 months after the financial year-end. This
was our original deadline as per the statutory consultation. This allows enough
time for the submission to be reconciled with the audited statutory accounts which
is 9 months after the company’s year-end. This will allow suppliers to keep their
auditing processes in place and provide assurance that the CSS submission is
accurate.
2.47. We acknowledge public companies submit their accounts six months after the
company’s year-end. However, we have decided to maintain the CSS publication
deadline as ten months after the company’s year-end for both private and public
limited companies. Suppliers are welcome to publish a CSS earlier than the
deadline if it is reasonably practicable do so.
2.48. We are requesting the CSS template, as well as being published to that company’s
website, is provided to Ofgem in an excel file via email to aid with our data
processing, as per the Guidelines in Appendix 2. We may in future request upload
to a secure portal instead. We have wider powers which support the requirement
to submit information to Ofgem when and in the form requested (e.g. SLC 5.1).
2.49. In cases where there is a Companies House extension, we may consider whether
an extension is appropriate on a case-by-case basis (SLC 19A.3(b) allows Ofgem
to specify another date) rather than an automatic extension in the case of a
Companies House extension.
2.50. Further, we are remaining with our proposal from our 2023 statutory consultation
and not allowing a transition period for the first year.
2.51. Where a supplier reaches the threshold criteria in at least one of the four market
segments; domestic gas, domestic electricity, non-domestic gas or non-domestic
electricity, they will be required to report on supply activities for all segments
where applicable.
2.52. Where a supplier holds multiple supply licences and reach the threshold for one
licensee, they will be required to report on supply activity across all licensees. For
example, for a supplier which reaches the threshold criteria in one commodity (for
example electricity) and has an affiliate company supplying gas which does not
reach the threshold, they will be required to include both company’s supply
activities within the CSS. To add, affiliates without a supply licence are not to be
included as part of the CSS. We have also noted this within the guidelines.
Decision Reviewing the Consolidated Segmental Statements Our Decision
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2.53. To clarify, where a supplier holds multiple supply licences, they should publish a
single CSS for the Group accounts.
Decision Summary
2.54. We summarise our decision for revising the CSS requirements below. The changes
fall into five principal areas.
Supplier Thresholds: We have removed the requirement for a supplier to
hold a generation licence in order to be obliged to publish a CSS. We have
decided to lower the domestic threshold level to 50,000 or more meter
points in either gas or electricity. For the non-domestic market, we have
decided to lower the threshold to 10 or more meter points, with the ability
to exclude those meters which supply to the company itself or any Affiliate.
The company will be obliged to publish a CSS where they reach the
threshold in the final month of their financial year. Companies will be
expected to internally monitor where they reach the threshold/s.
Generation Reporting: We have decided to remove the generation
reporting segment of the CSS.
Audit requirement: We have decided to remove the audit requirement,
however we may require an audit where we consider the CSS may not
have been properly prepared. The CSS should be reconcilable with
statutory accounts. A clear and full explanation of the reconciliation to the
company accounts must be provided, as to how revenues and profits
reconcile to the Relevant Licensee’s audited figures. A numerical table
must also be provided to demonstrate the reconciling items, we have
included a suggested template in the Guidelines.
Reporting: We have decided to extend the reporting timeline of the CSS
publication to ten months after the company’s financial year-end. Where a
supplier holds multiple supply licences and reach the threshold for one
licensee, they will be required to report on supply activity across all
licensees and or affiliates in a Group level CSS, as per the Guidelines.
Transition Period: We have decided to remove the transition period for
the first year of reporting.
Decision Reviewing the Consolidated Segmental Statements Our Decision
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Next Steps
2.55. Previously CSS data was published within several indicators on our Data Portal
4
however this was paused as the CSS data was no longer representative of the
market. Following this decision to expand the CSS obligation to cover a significant
proportion of the domestic and non-domestic market, we will aim to restore
publication of indicators.
2.56. One such indicator is an energy bill breakdown which is a crucial part of our role
in ensuring consumers are informed and have access to information regarding all
the components that make up their bills. Concerns about the costs that make up
consumers bills are ever present and, whilst the Price Cap represents the
breakdown of a notional efficient supplier, we need independent and accessible
information to publish a breakdown of energy bills. The CSS provides a
breakdown of actual supplier costs which better serves customers. We may
develop additional indicators where we see a benefit to consumers and/or third
parties.
2.57. Our decision aims to increase transparency of supplier profitability and ensure
consumers are treated fairly. We will keep our decision under review to ensure
that the CSS meets our objectives and is proportionate in doing so.
4
Ofgem Data Portal:
https://www.ofgem.gov.uk/data-portal/overview
Decision Reviewing the Consolidated Segmental Statements Our Decision
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Appendices
Index
Appendix
Name of appendix
Page no.
1
Standard Licence Condition Modifications
18
2
Revised CSS Guidelines
26
3
Templates
33
Decision Reviewing the Consolidated Segmental Statements Our Decision
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Appendix 1 Licence Condition Modifications
Gas SLC 19A: Financial Information Reporting
19A.1 The Relevant Licensee must prepare and publish on its Website a Consolidated
Segmental Statement in respect of information relating to the revenues, costs and
profits of its activities in the generation and supply of electricity and/or the supply
of gas to any premises taking account of the Guidelines.
19A.2 Where applicable, the Relevant Licensee must prepare and publish the Consolidated
Segmental Statement referred to in paragraph 1 in conjunction with any Affiliates.
19A.3 The Relevant Licensee must, in conjunction with any Affiliates, prepare and publish
a Consolidated Segmental Statement
a. as soon as reasonably practicable and no later than four ten months after
the end of the Relevant Licensee’s financial year; or
b. no later than a date specified by the Authority, which can be no earlier than
four nine months after the end of the Relevant Licensee’s financial year.
19A.4 Subject to complying with this paragraph the Relevant Licensee may, for the
purpose of preparing the statement pursuant to paragraph 3, prepare and compile
the information according to the licensee’s annual accounting procedures. The
Relevant Licensee must include in every such statement an explanation of:
a. how it defines the terms revenues, costs and profits.
b. how the revenues and profits can be reconciled with its UK statutory
accounts.
c. or how, if UK statutory accounts are not prepared or published, how the
revenues and profits can be reconciled with audited figures (prepared under
International Financial Reporting Standards) in accordance with Generally
Accepted Accounting Principles (GAAP)) published in Group accounts; and
d. its transfer pricing methodology and how this relates to the revenues, costs
and profits information published; and
e. where individual business functions are captured in the Consolidated
Segmental Statement, as specified by Appendix 2 of in the Guidelines.
19A.5 The Relevant Licensee must ensure that the information prepared and made public
pursuant to paragraph 19A.3 includes the cost of fuel used to generate electricity
and its share of revenues, costs, profits and volumes of Joint Ventures and
Associates.
19A.6 Subject to complying with Paragraph 19A.5 the Relevant Licensee must ensure
that all the information prepared and made public pursuant to paragraph 19A.3 is
in all material respects consistent with the information prepared pursuant to
paragraph 19A.4 and the information is presented with a clear and full
explanation.
19A.7 The Relevant Licensee must, for the purposes of ensuring the transfer pricing
methodology is appropriate and up to date:
a. keep transfer pricing policies and procedures under review; and
b. ensure that the supporting information that supports the transfer pricing
policies remains appropriate and up to date.
19A.8 The Relevant Licensee must notify the Authority as soon as reasonably practicable
of any material changes to transfer pricing policies.
19A.9
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a. The Authority shall prepare Guidelines in relation to the requirements of this
condition and may modify, in whole or in part, the Guidelines following
consultation with the Relevant Licensees.
b. The Authority shall modify the definition of Consolidated Segmental
Statement as described in Appendices 1 and 2 of the Guidelines in
accordance with section 23 of the Act.
19A.10 Except and to the extent that the Authority otherwise consents, the Relevant
Licensee must include in the Consolidated Segmental Statement a report from an
Appropriate Auditor that gives an audited opinion as to the extent to which the
Relevant Licensee has properly prepared the Consolidated Segmental Statement in
accordance with this licence condition and the Guidelines. Where the Authority
considers that the Relevant Licensee has not properly prepared the Consolidated
Segmental Statement in accordance with this licence condition and the Guidelines
and template, it may require the Relevant Licensee to commission and submit a
report from an Appropriate Auditor or to submit a report from an Appropriate
Auditor which it has already commissioned.
19A.11 The Relevant Licensee may apply to the Authority to request a direction that this
condition 19A does not apply and must provide any information required by the
Authority in support of such application for consideration of whether to grant or
refuse such an application.
19A.12 For the purposes of this condition:
Affiliate
Appropriate Auditors
Associate
means any holding company or subsidiary of a holding
company of the Relevant Licensee, in each case within
the meaning of sections 1159 and 1160 of the
Companies Act 2006.
means
(a) in the case of a licensee which is a company within
the meaning of section 1 of the Companies Act
2006, a person appointed as auditor under Chapter
2 of Part 16 of that Act.
(b) in the case of any other licensee which is required
by the law of a country or territory within the
European Economic Area to appoint an auditor
under provisions analogous to Chapter 2 of Part 16
of the Companies Act 2006, a person so
appointed.
(c) in any other case, a person who is eligible for
appointment as a company auditor under sections
1212 and 1216 of the Companies Act 2006, or in
relation to auditors appointed for financial years
beginning before 6 April 2008, a person who is
eligible for appointment as a company auditor
under sections 25 and 26 of the Companies Act
1989
means an entity, including an unincorporated entity
such as a partnership, over which the Relevant
Licensee has significant influence and that is neither a
subsidiary nor an interest in a joint venture.
Consolidated Segmental
Statement
“Guidelines”
means a statement as described in Appendices 1 and
2 of the Guidelines.
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means the guidance and procedures in place for
preparing the Consolidated Segmental Statements.
Joint Venture
mean a contractual arrangement whereby the
Relevant Licensees and one or more parties undertake
an economic activity that is subject to joint control.
Relevant Licensee
means the holder of a supply licence granted or treated
as granted under section 7A (1) of the Act if
(a) it supplies, or it and any of its Affiliates jointly
supply:
(i) electricity to more than 250,000 50,000 or more
domestic customers based on number of meter
points; or
(ii) gas to more than 250,000 50,000 or more
domestic customers based on number of meter
points; or
(iii) electricity to more than 250,000 10 or more non-
domestic customers based on number of meter
points; or
(iv) gas to more than 250,000 10 or more non-
domestic customers based on number of meter
points, respectively: and
(b) it or any of its Affiliates is a holder of an
electricity generation licence granted or treated as
granted under section 6(1)(a) of the Electricity Act
1989.
Website
means a website controlled and used by the Relevant
Licensee or an Affiliate for the purposes of providing
information and communication.
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Electricity SLC 19A: Financial Information Reporting
19A.1 The Relevant Licensee must prepare and publish on its Website a Consolidated
Segmental Statement in respect of information relating to the revenues, costs and
profits of its activities in the generation and supply of electricity and/or the supply
of gas to any premises taking account of the Guidelines.
19A.2 Where applicable, the Relevant Licensee must prepare and publish the Consolidated
Segmental Statement referred to in paragraph 19A.1 in conjunction with any
Affiliates.
19A.3 The Relevant Licensee must, in conjunction with any Affiliates, prepare and publish
a Consolidated Segmental Statement
a as soon as reasonably practicable and no later than four ten months after
the end of the Relevant Licensee’s financial year; or
b no later than a date specified by the Authority, which can be no earlier than
four nine months after the end of the Relevant Licensee’s financial year.
19A.4 Subject to complying with this paragraph the Relevant Licensee may, for the
purpose of preparing the statement pursuant to paragraph 19A.3, prepare and
compile the information according to the licensee’s annual accounting procedures.
The Relevant Licensee must include in every such statement an explanation of:
a how it defines the terms revenues, costs and profits.
b how the revenues and profits can be reconciled with its UK statutory
accounts.
c or how, if UK statutory accounts are not prepared or published, how the
revenues and profits can be reconciled with audited figures (prepared under
International Financial Reporting Standards) in accordance with Generally
Accepted Accounting Principles (GAAP)) published in Group accounts; and
d its transfer pricing methodology and how this relates to the revenues, costs
and profits information published; and
e where individual business functions are captured in the Consolidated
Segmental Statement, as specified by Appendix 2 of in the Guidelines.
19A.5 The Relevant Licensee must ensure that the information prepared and made public
pursuant to paragraph 19A.3 includes the cost of fuel used to generate electricity
and its share of revenues, costs, profits and volumes of Joint Ventures and
Associates.
19A.6 Subject to complying with Paragraph 19A.5 the Relevant Licensee must ensure that
all the information prepared and made public pursuant to paragraph 19A.3 is in all
material respects consistent with the information prepared pursuant to paragraph
19A.4 and the information is presented with a clear and full explanation.  
19A.7 The Relevant Licensee must, for the purposes of ensuring the transfer pricing
methodology is appropriate and up to date:
a keep transfer pricing policies and procedures under review; and
b ensure that the supporting information that supports the transfer pricing
policies remains appropriate and up to date.
19A.8 The Relevant Licensee must notify the Authority as soon as reasonably practicable
of any material changes to transfer pricing policies.
19A.9 (a) The Authority shall prepare Guidelines in relation to the requirements of this
condition and may modify, in whole or in part, the Guidelines following consultation
with the Relevant Licensees.
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(b) The Authority shall modify the definition of Consolidated Segmental Statement
as described in Appendices 1 and 2 of the Guidelines in accordance with section
11A of the Act.
19A.10 Except and to the extent that the Authority otherwise consents, the Relevant
Licensee must include in the Consolidated Segmental Statement a report from an
Appropriate Auditor that gives an audited opinion as to the extent to which the
Relevant Licensee has properly prepared the Consolidated Segmental Statement in
accordance with this licence condition and the Guidelines. Where the Authority
considers that the Relevant Licensee has not properly prepared the Consolidated
Segmental Statement in accordance with this licence condition and the Guidelines
and template, it may require the Relevant Licensee to commission and submit a
report from an Appropriate Auditor or to submit a report from an Appropriate
Auditor which it has already commissioned.
19A.11 The Relevant Licensee may apply to the Authority to request a direction that this
condition 19A does not apply and must provide any information required by the
Authority in support of such application for consideration of whether to grant or
refuse such an application.
19A.12 For the purposes of this condition:
Affiliate means any holding company or subsidiary of a holding company of the
Relevant Licensee, in each case within the meaning of sections 1159 and 1160 of the
Companies Act 2006.
Appropriate Auditorsmeans.
a in the case of a licensee which is a company within the meaning of section
1 of the Companies Act 2006, a person appointed as auditor under
Chapter 2 of Part 16 of that Act.
b in the case of any other licensee which is required by the law of a country
or territory within the European Economic Area to appoint an auditor
under provisions analogous to Chapter 2 of Part 16 of the Companies Act
2006, a person so appointed.
c in any other case, a person who is eligible for appointment as a company
auditor under sections 1212 and 1216 of the Companies Act 2006, or in
relation to auditors appointed for financial years beginning before 6 April
2008, a person who is eligible for appointment as a company auditor
under sections 25 and 26 of the Companies Act 1989.
Associate” means an entity, including an unincorporated entity such as a
partnership, over which the Relevant Licensee has significant influence and that is
neither a subsidiary nor an interest in a joint venture.
Consolidated Segmental Statement” means a statement as described in
Appendices 1 and 2 of the Guidelines.
“Guidelines” means the guidance and procedures in place for preparing the
Consolidated Segmental Statements.
Joint Venture means a contractual arrangement whereby the Relevant
Licensees and one or more parties undertake an economic activity that is subject
to joint control.
Relevant Licensee” means the holder of an electricity supply licence granted or
treated as granted under section 6(1)(d) of the Act if:
it supplies, or it and any of its Affiliates jointly supply:
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(i) electricity to more than 250,000 50,000 or more domestic customers
based on number of meter points; or
(ii) gas to more than 250,000 50,000 or more domestic customers based
on number of meter points; or
(iii) electricity to more than 250,000 10 or more non-domestic customers
based on number of meter points; or
(iv) gas to more than 250,000 10 or more non-domestic customers based
on number of meter points, respectively: and
(v) it or any of its Affiliates is a holder of an electricity generation licence
granted or treated as granted under section 6(1)(a) of the Act.
Website” means a website controlled and used by the Relevant Licensee or an
Affiliate for the purposes of providing information and communication.
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Electricity Generation SLC 16B: Financial Information Reporting
19A.1. The Relevant Licensee must prepare and publish on its Website a Consolidated
Segmental Statement in respect of information relating to the revenues, costs and
profits of its activities in the generation and supply of electricity and the supply of
gas to any premises taking account of the Guidelines.
19A.2. Where applicable, the Relevant Licensee must prepare and publish the Consolidated
Segmental Statement referred to in paragraph 1 in conjunction with any Affiliates.
19A.3. The Relevant Licensee must, in conjunction with any Affiliates, prepare and publish
a Consolidated Segmental Statement
a. as soon as reasonably practicable and no later than four months after the
end of the Relevant Licensee’s financial year; or;
b. no later than a date specified by the Authority, which can be no earlier than
four months after the end of the Relevant Licensee’s financial year.
19A.4. Subject to complying with this paragraph the Relevant Licensee may, for the
purpose of preparing the statement pursuant to paragraph 19A.3, prepare and
compile the information according to the licensee’s annual accounting procedures.
The Relevant Licensee must include in every such statement an explanation of:
a. how it defines the terms revenues, cost and profits;
b. how the revenues and profits can be reconciled with its UK statutory
accounts;
c. or, if UK statutory accounts are not prepared or published, how the revenues
and profits can be reconciled with audited figures (prepared under
International Financial Reporting Standards) published in Group accounts;
d. its transfer pricing methodology and how this relates to the revenues, costs
and profit information published; and
e. where individual business functions are captured in the Consolidated
Segmental Statement, as specified by Appendix 2 of the Guidelines.
19A.5. The Relevant Licensee must ensure that the information prepared and made public
pursuant to paragraph 3 includes the cost of fuel used to generate electricity and
its share of revenues, costs, profits and volumes of Joint Ventures and Associates.
19A.6. Subject to complying with Paragraph 5 the Relevant Licensee must ensure that all
the information prepared and made public pursuant to paragraph 3 is in all material
respects consistent with the information prepared pursuant to paragraph 4 and the
information is presented with a clear and full explanation.  
19A.7. The Relevant Licensee must, for the purposes of ensuring the transfer pricing
methodology is appropriate and up to date:
a. keep transfer pricing policies and procedures under review; and
b. ensure that the supporting information that supports the transfer pricing
policies remains appropriate and up to date.
19A.8. The Relevant Licensee must notify the Authority as soon as reasonably practicable
of any material changes to transfer pricing policies.
19A.9. (a) The Authority shall prepare Guidelines in relation to the requirements of this
condition and may modify, in whole or in part, the Guidelines following consultation
with the Relevant Licensees.
The Authority shall modify the definition of Consolidated Segmental Statement as
described in Appendices 1 and 2 of the Guidelines in accordance with section 11A
of the Act.
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19A.10. Except and to the extent that the Authority otherwise consents, the Relevant
Licensee must include in the Consolidated Segmental Statement a report from an
Appropriate Auditor that gives an audited opinion as to the extent to which the
Relevant Licensee has properly prepared the Consolidated Segmental Statement in
accordance with this licence condition and the Guidelines.
19A.11. For the purposes of this condition:
Affiliate means any holding company or subsidiary of a holding company of the
Relevant Licensee, in each case within the meaning of sections 1159 and 1160 of the
Companies Act 2006.
Appropriate Auditors” means
(a) in the case of a licensee which is a company within the meaning of section 1 of
the Companies Act 2006, a person appointed as auditor under Chapter 2 of Part
16 of that Act;
(b) in the case of any other licensee which is required by the law of a country or
territory within the European Economic Area to appoint an auditor under
provisions analogous to Chapter 2 of Part 16 of the Companies Act 2006, a
person so appointed;
(c) in any other case, a person who is eligible for appointment as a company auditor
under sections 1212 and 1216 of the Companies Act 2006, or in relation to
auditors appointed for financial years beginning before 6 April 2008, a person
who is eligible for appointment as a company auditor under sections 25 and 26 of
the Companies Act 1989.
Associatemeans an entity, including an unincorporated entity such as a partnership,
over which the Relevant Licensee has significant influence and that is neither a
subsidiary nor an interest in a joint venture.
Consolidated Segmental Statement means a statement as described in
Appendices 1 and 2 of the Guidelines.
Joint Venturemeans a contractual arrangement whereby the Relevant Licensees
and one or more parties undertake an economic activity that is subject to joint control.
Relevant Licensee” means the holder of an electricity generation licence granted or
treated as granted under section 6(1)(a) of the Act if it supplies or any of its Affiliates
supply, either jointly or severally:
i. electricity to more than 250,000 domestic customers; or
ii. gas to more than 250,000 domestic customers; or
iii. electricity to more than 250,000 non-domestic
customers; or
iv. gas to more than 250,000 non-domestic customers.
Website” means a website controlled and used by the Relevant Licensee or an
Affiliate for the purposes of providing information and communication.
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Appendix 2 Revised CSS Guidelines
Revised Guidelines for preparing the CSS
Licence Condition
1.1. These Guidelines relate to Standard Licence Condition (SLC) 19A of the Gas and
Electricity Supply Licences, ‘Financial information reporting’. There is currently
one requirement under these conditions, which is the Consolidated Segmental
Statement (CSS) and this will be referred to as the CSS licence requirement for
the purposes of the Guidelines.
1.2. The Guidelines have been prepared by the Office of Gas and Electricity Markets,
('Ofgem'), pursuant to SLC 19A.
1.3. These Guidelines are accompanied by a spreadsheet with Templates (see
Appendix). The Guidelines and Templates will be published on the Ofgem
website.
Scope and Application of the Licence Conditions
1.4. The requirement to submit a CSS only applies to those companies that are
‘Relevant Licensees’ as defined in the CSS licence requirement. Where
information required under the CSS licence requirement is held by an Affiliate,
the Relevant Licensee is required to obtain and publish the information.
1.5. Where a supplier holds multiple supply licences and reach the threshold for one
licensee, they will be required to report on supply activity across all licensees. For
example, for a supplier which reaches the threshold criteria in one commodity
(for example electricity) and has an affiliate company supplying gas which does
not reach the threshold, they will be required to include both company’s supply
activities within the CSS. To add, affiliates without a supply licence are not to be
included as part of the CSS.
1.6. To clarify, where a supplier holds multiple supply licences, they should publish a
single CSS for the Group accounts. Further, where an affiliate does not hold a
supply licence they will not be included in the CSS.
1.7. SLC 19A provides for the ability for suppliers to apply for and ability for Ofgem to
consider and grant/refuse a direction that the CSS requirement does not apply on
a case by case basis. Examples of when such a direction might be considered
include, but are not limited to:
a. Where a supplier operates solely for non-traditional supply, and has no
affiliate with a traditional supply business;
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b. Where the exclusion of meters supplying the company itself or affiliates
would mean that the Relevant Licensee thresholds would not be met (see
para 1.9 below).
Minimum Threshold for Suppliers
1.8. To be obliged under the CSS, the following thresholds apply in determining who is
a Relevant Licensee (as set out in the CSS licence requirement):
domestic: suppliers must have at least 50,000 domestic gas customers
(measured in meter points, MPANs and MPRNs) in the final month of the
Relevant Licensee’s financial year; or
domestic: suppliers must have at least 50,000 domestic electricity
customers (measured in meter points, MPANs and MPRNs) in the final
month of the Relevant Licensee’s financial year; or
non-domestic: suppliers must have at least 10 non-domestic gas
customers (measured in meter points, MPANs and MPRNs) in the final
month of the Relevant Licensee’s financial year. The number of meters
may exclude any of which that supply to the company itself or any
affiliates.
non-domestic: suppliers must have at least 10 non-domestic electricity
customers (measured in meter points, MPANs and MPRNs) in the final
month of the Relevant Licensee’s financial year. The number of meters
may exclude any of which that supply to the company itself or any
affiliates.
1.9. Where meters supplying the company itself or any affiliates are to be excluded for
the purposes of the Relevant Licensee thresholds and this results in the Relevant
Licensee thresholds not being met, the company should apply to Ofgem for a
direction that the CSS requirement does not apply and Ofgem will consider
whether in the circumstances it is appropriate to grant such a direction. Such
applications should include the number of meters and details of meters being
excluded by emailing [email protected]ov.uk so that this information may be verified
as appropriate.
Financial Year
1.10. As per the CSS licence requirement, the financial year should be interpreted as
the Relevant Licensee’s current financial reporting year. For the avoidance of
doubt, this may differ between companies.
Publication and Submissions
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Publication
1.11. The majority of suppliers are registered companies, and they are obliged by law
to submit their financial statements to Companies House on a yearly basis. This
financial information is in the public domain as all companies’ accounts are open
and accessible. Where a supplier has a specific concern, they should notify us in
advance of publication, and we will advise whether we consider it can be
redacted.
1.12. Where a supplier holds multiple supply licences, they should publish a single CSS
for the Group accounts.
1.13. The Template should be fully completed at the Group level where applicable,
including the Relevant Licensee and any Affiliates, with all information.
1.14. In cases where there is a Companies House extension, we may consider whether
an extension is appropriate on a case-by-case basis (SLC 19A.3(b) allows Ofgem
to specify another date) rather than an automatic extension in the case of a
Companies House extension.
Submissions
1.15. The completed templates (see Templates for Submitting the CSS below) should
be submitted in a spreadsheet. Other explanations, analysis and commentary
should be submitted in a searchable pdf format, and not an image. The completed
template, other explanations, analysis, and commentary should be sent to the
following email address: css@ofgem.gov.uk
Interpreting the Financial Information
1.16. Under the CSS licence requirement, a clear and full explanation of how the
Relevant Licensee defines the terms ‘revenues, costs and profits’ should be set
out, to enable understanding of what the information published pursuant to the
conditions does and does not represent.
1.17. The Relevant Licensee should describe the methodology or methodologies used to
allocate marketing, shared and corporate costs across the supply elements. The
licensee should also describe how, for example, individual costs such as Feed- in-
Tariff costs (classified in the income statement as ‘Other Direct costs’) and
Renewable Obligation costs (classified as ‘Environmental and Social Obligation
costs’), are allocated across the supply business. For the avoidance of doubt,
PPAs will come under ‘Direct Costs’. Where issues pertaining to the data are
unexpected or unusually complex these issues should be set out in full.
Decision Reviewing the Consolidated Segmental Statements Our Decision
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1.18. We would only expect the ‘revenues, costs and profits’ to reflect company
activities relating to that year of operations.
1.19. Examples of financial items we would not expect to be included are, but are not
limited to, mark to market adjustments; profit or losses on disposal; restructuring
costs that have been identified as such in the Group’s annual report; and
impairment charges.
1.20. Where the Relevant Licensee has included any such items for the purpose of
reconciliation, or otherwise, a clear and full explanation of the reconciliation to
the company accounts of the Relevant Licensee(s) must be provided, as to how
revenues and profits reconcile to the Relevant Licensee’s audited figures. The
Relevant Licensee must also provide a numerical table to demonstrate the
reconciling items, we have included a suggested template below.
1.21. Revenue and costs for the financial year should be stated on the accruals basis,
following Generally Accepted Accounting Practice (GAAP). In order to comply with
GAAP, the Relevant Licensee is required to follow the same accounting standards
applied in preparing their statutory accounts. If a Licensee applies a version of
International Financial Reporting Standards (IFRS) in its statutory accounts, then
it should apply the same version of IFRS for preparation of the CSS.
1.22. Likewise, if a Licensee applies FRS101 (reduced disclosure under IFRS) or
FRS102, it should apply the same standard in preparing the CSS.
1.23. The explanation of accounting terms can be based on the accounting standards
used in the company accounts and needs to clarify where the figures differ due to
the scope of the CSS being limited to operations during the year.
Hedging
1.24. The hedging policy of the Relevant Licensee should be described.
1.25. The description should include an explanation of the hedging applied to default
and active choice tariffs.
1.26. The description should also include an explanation as to who bears the volume
risk whether that is the Relevant Licensee, an Affiliate, and the Trading
Counterparty or a third party to a financial instrument.
Treatment of Joint Ventures and Associates
1.27. Under the licence requirement, the Licensee must work with other companies in
its group to provide the CSS, which will help give further transparency on overall
revenues, costs, profits and volumes of energy supply.
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1.28. The Relevant Licensee should account for Joint Ventures and Associates (which
hold supply licence relating to the supply of gas or electricity in the UK) as
follows:
the share of revenues of Joint Ventures and Associates to be included
within revenue, and
the share of the profit before tax of Joint Ventures and Associates to be
included within EBITDA (Earnings before Interest, Tax and Depreciation)
and EBIT (Earnings before Interest and Tax).
1.29. For each of the items, the Relevant Licensee’s share of the income and expenses
of a Joint Venture or Associate should be combined line by line with similar items
in the Relevant Licensee’s CSS or reported as separate line items in the Relevant
Licensee’s CSS.
Auditing
1.30. The CSS must be reconciled to the figures in the audited statutory accounts. A
table for the reconciliation must be provided, a suggested template has been
provided. It follows that the same GAAP accounting standards applied in the
statutory accounts should be applied in the CSS in order to facilitate
reconciliation.
1.31. The Relevant Licensee is not obliged to submit a report from an Appropriate
Auditor. However, Ofgem reserves the right to ask for the submission of a report
from an Appropriate Auditor where it considers that the Relevant Licensee has not
prepared the CSS in accordance with the licence conditions, Guidelines and
Template.
1.32. Where an audit is required, the Relevant Licensee should engage an Appropriate
Auditor, as stated in the CSS licence requirement, to review whether the figures
in the CSS can be reconciled with the figures in the statutory accounts and that
costs are fairly allocated on a basis that, the Auditor is satisfied, is fair to
customers in the various business segments. Alternatively, the Relevant Licensee
may send us a copy of an audit report from an Appropriate Auditor if they have
previously prepared one in relation to the CSS submission in question. The
Appropriate Auditor will be engaged by the Relevant Licensee only and will report
to the Relevant Licensee only; the Appropriate Auditor will have no contract with
Ofgem.
Template for submitting the CSS
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1.33. The CSS Template is to be filled in annually by the Relevant Licensee. This CSS
Template will be in an Excel format or in another format directed by us and
contains the following:
fuel types separate figures for electricity and gas and domestic and non-
domestic customers
separation of ‘revenues, costs and profits’ by domestic and non-domestic
customers
General Presentation
1.34. All financial figures should be stated in millions of pounds sterling (GBP £m) and
rounded to no more than one decimal place. The grey shadings denote
summations that can be calculated by using other information within the
statement.
1.35. WACOE should be reported to the nearest pence in £/MWh and WACOG reported
to one decimal place in p/kWh. Volumes for electricity to one decimal place in
TWh and for gas to one decimal place in MThms
1.36. All revenues, costs and depreciation should be entered as positive values with
only EBITDA (Earnings before Interest, Tax and Depreciation)’ and EBIT (Earnings
before Interest and Tax) displaying negative values in the event of a loss.
Revenue and Cost line items for Supply
1.37. ’Revenue from sale of electricity and gas’ means electricity and gas sales for the
respective retail supply segments. Revenue for domestic supply should be less
dual fuel discounts where applicable; that is these discounts should be deducted
from revenue, with the discount split evenly between electricity and gas. Social
tariff costs should also be deducted from domestic supply revenue directly.
1.38. ‘Other Revenue’ not covered above means revenue from other activities in the
licensee company that is revenue that is not defined in paragraph A2.37. This is
to be included in the ‘Other Revenue’ row of the income statement below the
‘Revenue’ row. The description of ‘other revenue’ should continue to be provided
in a footnote.
1.39. ‘Direct fuel costs’ for supply should include aggregate electricity and gas costs.
For the supply businesses, WACOE/G should cover the wholesale energy cost,
losses, the energy element of Reconciliation by Difference (RBD) costs, Power
Purchase Agreements (PPAs), balancing and shaping costs incurred by supply
licences.
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1.40. ‘Other direct costs’ for supply should include network costs, Balancing Services
use of System charges (BSUOS), environmental costs (including Renewable
Obligation Certificates (ROCs), Carbon Emissions Reduction Targets (CERTs) and
the Community Energy Savings Programme (CESP) and the transport element of
RBD costs.
1.41. ‘Indirect costs’ should be defined as Relevant licensees’ own internal operating
costs including sales and marketing costs, bad debt, central services, customer
service, costs to serve Priority Services Register (PSR) customers and all
metering costs. With Indirect Costs the licensee should also highlight R&D and
Innovation costs incurred during the period.
1.42. Volumes should be supplier volumes at the meter point (ie net of losses).
1.43. WACO E/G means the “Direct fuel costs” line divided by the “Volume” line, shown
as £/MWh or p/th.
1.44. Meter Points should be the average number of electricity and gas, domestic and
non-domestic meter points (MPANs and MPRNs) during the reporting year. This
should be calculated by adding monthly closed meter points and dividing by 12.
1.45. The supply aggregation column (aggregation of domestic and non-domestic
electricity and gas supply businesses) sums the horizontal supply figures and
thereby helps facilitate reconciliation to group accounts.
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Appendix 3 Templates
CSS template after reconciliation adjustments.
Results after adjustments
Unit
Electricity supply
Gas supply
Aggregate
supply
business
Domestic
Non-
domestic
Domestic
Non-
domestic
20XX
20XX
20XX
20XX
20XX
Total revenue
£M
Revenue from sale of
electricity and gas
£M
Other revenues
£M
Total operating
costs
£M
Direct fuel costs
£M
Direct costs:
Transportation costs
£M
Environmental and social
obligations costs
£M
Other direct costs
Indirect costs
£M
EBITDA
£M
Depreciation and
amortisation
£M
EBIT
£M
Volume
TWh,
m therms
WACO E/G
£/MWh,
p/th
Meter Points
000s
Decision Reviewing the Consolidated Segmental Statements Our Decision
34
Template displaying reconciling items to the statutory accounts
Adjustments for Reconciling items
#
Item
Unit
Electricity supply
Gas supply
Aggregate
supply
business
Adjust
in
CSS?
Domestic
Non-
domestic
Domestic
Non-
domestic
#1
£M
#2
£M
#3
£M
#4
£M
#5
£M
#6
£M
#7
£M
#8
£M
#9
£M
#10
£M