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© 2026 Flex Assure Ltd.
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The HOMEflex Code of Conduct for domestic and microbusiness flexibility service providers
Published -- November 2025
In partnership with Scottish and Southern Electricity Networks, funded by the Network Innovation Allowance, with research support conducted by the Centre for Sustainable Energy. Osborne Clarke undertook a legal review.
Whilst this Code of Conduct is based on the best available knowledge at the time of publication, to the fullest extent allowed by law Flex Assure, Scottish and Southern Electricity Networks, Centre for Sustainable Energy, Osborne Clarke, the authors and anyone else involved in the publication of this Code of Conduct hereby disclaim all warranties and conditions with regard to its contents including all implied warranties and conditions of satisfactory quality, fitness for a particular purpose, title and non-infringement except where such disclaimers are held to be legally invalid. In no event shall Flex Assure, Scottish and Southern Electricity Networks, the Centre for Sustainable Energy, Osborne Clarke, the authors and anyone else involved in the publication of this Code of Conduct be liable to any adopter or anyone else for any special, indirect, incidental, punitive or consequential damages or any other damages whatsoever howsoever arising in connection with any of the information disclosed or available from time to time in this Code of Conduct, even if they have been advised of the possibility of such damages.
In partnership with Scottish and Southern Electricity Networks (SSEN) and funded by the Network Innovation Allowance, the HOMEflex project, (standing for Household Of Microbusiness Energy Flexibility), was launched by Flex Assure in 2022 and finished in 2025. The project aimed to develop transparency, inclusivity and respect between Flexibility Service Providers and Customers and developed a Code of Conduct for FSPs. This Code sets out common standards of practice for organisations delivering Energy Flexibility Services to domestic and microbusiness Customers, encouraging good practice and accountability.
Energy Flexibility is changing the amount of electricity used in response to an external signal, leading to multiple benefits. An example of Energy Flexibility for domestic customers is changing the charging pattern of an Electric Vehicle or heating system. For microbusinesses, it may involve periodically adjusting the temperature of fridge/freezer banks. Maximising the monetary or non-monetary benefits of performing Energy Flexibility will involve Customers forming a relationship with a Flexibility Service Provider who specialises in this field.
As the UK transitions to an energy system not reliant on fossil fuels and carbon-intensive electricity generation, changes are needed to create a more responsive, flexible, smart energy system. Energy Flexibility will ensure the UK makes the best use of the clean, renewable energy generation it builds and saves money by avoiding over-build of generation and network. Energy Flexibility Services aims to reflect this value and offers opportunities for domestic and microbusiness Customers to earn revenue while helping the transition to net zero in a cost-effective way that ensures the security of supply.
With the significant growth of Energy Flexibility Services, it is vital that Customers feel confident about the service they will receive and trust Service Providers to communicate and conduct relationships professionally.
While Flex Assure has already developed a Code of Conduct for Industrial and Commercial customers of Flexibility Service Providers, a Code addressing the specific needs and concerns of domestic and microbusiness Customers was also needed. The Code aims to facilitate a positive customer experience and encourage greater participation in Energy Flexibility Services. By bolstering Customer confidence in companies who adhere to the Code and informing Customers of the form that best practice should take, it is hoped that Customers will become increasingly familiar with Energy Flexibility and Service Providers. On the latter, it is important to note that Flexibility Service Providers are not necessarily energy suppliers and may be a company independent of a Customer's energy supplier.
The Domestic and Microbusiness Code of Conduct is an open-source document for anyone to refer to.
The Code addresses issues of particular relevance to the relationship between a Flexibility Service Provider and domestic or microbusiness Customer. The Code does not aim to replicate or conflict with any existing Law, regulation or voluntary standards which are referenced throughout the Code; the Code addresses five main areas, aiming to deliver the following outcomes:
Sales and Marketing -- A relationship between Service Providers and Customers must be initiated honestly and professionally. Accordingly, sales materials must be accurate, and sales representatives must behave with honesty and integrity.
Customer Contracts -- A Service Provider must present the Customer with a Contract that unambiguously states the benefits, expectations, risks, liabilities, and obligations associated with the service being provided.
Technical Due Diligence, Data, Cyber Security, and Installation -- A Service Provider must adhere to best practices to protect electronic data and ensure that any installation of physical Assets is conducted professionally regarding the health, safety, and integrity of the Customer's person and property.
Ethical and Fair Conduct -- A Service Provider must ensure that, as far as practicable, their products and or services are inclusive and that specific regard is taken for Customers in Vulnerable Circumstances.
Complaints and Dispute Mechanism -- A Service Provider must inform the Customer of the process for registering and responding to Complaints and have a Dispute procedure for instances when Complaints cannot be resolved in a mutually satisfactory way. The Service Provider must also comply at all times with the rules of the Independent Dispute Resolution Service.
For the purpose of this Code, the following terms will be interpreted accordingly.
Arbitration -- A means of binding dispute resolution that is an alternative to court action.
Assets -- Devices, technologies, and appliances, including energy smart appliances, which can adjust the immediate or future flow of electricity into or out of itself or another appliance in response to a Load Control Signal or an intervention from the Customer and includes any software or other systems which enable or facilitate the adjustment to be made in response to the signal.
Benefit -- Any benefit including, but not limited to: (a) direct benefits, such as monetary reward or Benefit-in-Kind; and (b) indirect benefits, such as a contribution to carbon emissions reduction.
Benefit-in-Kind -- A non-monetary benefit or reward including, but not limited to: (a) exclusive access to, or discounts on, any goods or services; (b) memberships or subscriptions; (c) insurance and other financial products; and (d) share options.
Code or Domestic & Microbusiness Code of Conduct -- This Code, as updated from time to time and as published on the Flex Assure website.
Complaint -- Any expression of dissatisfaction made to an organisation related to any one or more of its products and/or services or the manner in which it has dealt with any such expression of dissatisfaction, where a response is either provided by or on behalf of that organisation at the point at which contact is made or a response is explicitly or implicitly required or expected to be provided thereafter.
Complaints Process / Handling Procedure -- The procedure that is available to a Customer if it has a Complaint about any action a Service Provider takes.
Contract -- A contract for the provision of Energy Flexibility Services entered into between a Customer and a Service Provider.
Customer -- A person or entity to whom a Service Provider provides, or offers to provide, Energy Flexibility Services, who is either: (a) a Domestic Customer: a Customer supplied with electricity at a domestic premises, or (b) a Micro-business Customer: a business that (i) employs fewer than ten employees (or their full-time equivalent) and has an annual turnover or balance sheet no greater than 2 million euros; (ii) or uses no more than 100,000 kWh of electricity per year; (iii) or uses no more than 293,000 kWh of gas per year.
Customer in Vulnerable Circumstances -- When a Customer's personal circumstances and characteristics combine with aspects of the market to create situations where they are significantly less able than typical Customers to protect or represent their own interests or are significantly more likely to suffer detriment or that detriment is likely to be more significant.
Distribution Systems Operator -- An entity licensed to plan and operate an electricity distribution network.
Dispute -- Has the meaning given to it in clause 6.4.1.
Energy Flexibility Services -- The coordination, aggregation, or optimisation of assets in response to a Load Control signal or an intervention from a Customer.
Face-to-Face Marketing Activity -- Any activities of the Service Provider or any Representative that: (a) take place with the simultaneous physical presence of the Service Provider or any Representative and a Customer, and (b) are directed at or incidental to identifying and communicating with Customers for the purpose of promoting the Energy Flexibility Services to them and includes entering such contracts with such Customers.
Independent Dispute Resolution Service -- The Energy Ombudsman, in accordance with the Energy Ombudsman Terms of Reference and the Energy Ombudsman Scheme Rules (both as published on the Energy Ombudsman website and updated from time to time).
Insolvent -- In respect of a Service Provider, where it becomes bankrupt, goes into liquidation, or has a receiving or administration order made against it, compounds with its creditors, or carries on business under a receiver, trustee, or liquidator for the benefit of its creditors, or if any act is done or event occurs which has a similar effect to any of these acts or events.
Interoperability -- The ability of an Asset or system owned by the Customer to operate in conjunction with other products and systems.
Law -- Any applicable statute or proclamation or any delegated or subordinate legislation; any applicable guidance, direction or determination with which the Service Provider and/or Customer is bound to comply to the extent that the same are published and publicly available or the existence or contents of them have been notified to them; and any applicable judgement of a relevant court of law which is binding in England, Wales, Scotland or Northern Ireland.
Load Control -- The sending of a Load Control Signal to an Asset by the Load Controller.
Load Controller -- An entity which carries out Load Control, whether or not the Service Provider.
Load Control Signal -- A digital communication sent via a relevant electronic communications network to an Asset for the purpose of causing or otherwise facilitating an adjustment to the flow of electricity into or out of that Asset, made in response to either: (a) the sending of the signal, or (b) the sending of the signal and one or more additional factors.
Mediation -- A means of dispute resolution involving appointing an independent and impartial third party to help the parties come to a mutually agreeable solution.
Override -- In relation to an Asset, any: (a) modification of a planned flexibility action or current flexibility action; or (b) rejection of a requested action; or (c) cancellation of all actions for a specific interval or indefinitely.
Premises -- A building or a part of a building (including any equipment, systems or facilities used by the building or the part), or any equipment, systems or facilities used by a building or a part of a building.
Representative -- Any delegate, agent, manager, administrator, nominee, attorney, trustee, or custodian.
Resolved Complaint -- A Complaint in respect of which there remains no outstanding action to be taken by the Service Provider and which has been resolved to the satisfaction of the relevant Customer or on whose behalf that Complaint was made.
Switch or Switching -- The process involved when a Customer elects to change its Service Provider.
Service Provider -- Any actor or any representatives of that actor providing Energy Flexibility Services to one or more Customer(s).
Telesales Activity -- Any activities of the Service Provider or any Representative that are: (a) conducted by telephone; and (b) directed at or incidental to identifying and communicating with Customers for the purpose of promoting the Energy Flexibility Services to them and includes entering such contracts with such Customers.
Unsolicited Contact -- Any communication that the Customer did not specifically request.
Website -- The Flex Assure website: www.flexassure.org or such updated reference as notified from time to time.
Working days -- Any day other than a Saturday, a Sunday, Christmas Day, Good Friday, or a day which is a UK bank holiday.
2.1.1 The Service Provider must ensure that their advertising does not infringe existing Laws and regulations including, but not exclusive to, that listed on the Flex Assure Website.
2.1.2 The Service Provider must ensure that any claims made in advertisements and sales promotions by the Service Provider must be legal, honest, and not misleading.
2.1.3 The Service Provider must ensure the Customer can easily access supporting information relating to the claims made in advertisements and sales promotions about revenue, financial payback, or energy savings from participation in Energy Flexibility Services.
2.2.1 The Service Provider must ensure that:
2.2.2 The Service Provider must ensure that it puts in place information, services and/or tools to enable each Customer to easily understand and select the appropriate service from those offered by the Service Provider.
2.3.1 When selling or marketing to Customers, the Service Provider must not (and must ensure that its Representatives do not) mislead or otherwise use inappropriate tactics, including:
2.3.2 Where the Service Provider, or any third parties contracted by it, make Unsolicited Contact with Customers in relation to the sales and marketing of Energy Flexibility Services, these must comply with existing Law and regulations including, but not limited to, what is listed on the Flex Assure Website.
2.3.3 The Service Provider must ensure that all customer-facing employees and Representatives acting on their behalf are given training to ensure that any contact with Customers complies with the Code and the Law. The Service Providers must establish and periodically (and in any event not less than every three years) run an internal compliance-training program (which may be delivered through assigned learning) for customer-facing employees (including, but not limited to sales Representatives), pursuant to which such employees are educated on the Law, regulations and Rules of this Code that apply to their day-to-day job responsibilities.
2.3.4 Pursuant to clause 2.3.3, the Service Provider should maintain a written record showing:
2.3.5 A copy of this Code of Conduct (as updated from time to time) should be provided or made available to employees and sales Representatives acting on behalf of a Service Provider.
2.3.6 The Service Provider is responsible for the behaviour of anyone visiting a Customer's Premises on its behalf.
2.4.1 The Service Provider must not operate in an anti-competitive manner and must comply with Law and regulations pertaining to competition and market behaviour, including, but not limited to those listed on the Flex Assure Website.
2.5.1 Where a Customer, to whom the Services Provider or any Representative has provided information in the course of Face-to-Face Marketing Activities or Telesales Activities, enters into a Contract with the Service Provider, the Service Provider must maintain a record of the information which it provided to that Customer concerning that Contract, for a period of six years.
3.1.1 Before the Customer enters into the Contract, the Service Provider must, in writing:
3.2.1 All terms of the Contract must be communicated in writing to the Customer in a clear and concise manner using unambiguous terms. Where a term may have a different meaning within the industry than for non-experts, this should be explained in plain language to the Customer.
3.2.2 The Contract must state and explain:
3.2.3 The terms of the Contract must be in writing and in plain language and include:
3.3.1 Service providers must keep a record of the Contract for a minimum of six years from the later of: (1) the date that a copy of the pre contract marketing material was sent to the Customer; or (2) where a Contract has been entered into, six years after the end of the term of the Contract, including:
4.1.1 The Service Provider must comply with data protection Law and regulations including, but not limited to, those Laws and regulations listed on the Flex Assure Website regarding the collection, processing, storage, and disposal of Customer data. In doing this, the Service Provider must provide:
4.2.1 The Service Provider must take appropriate and proportionate technical and organisational measures to manage cyber risks to their systems to ensure the security of their cyber systems and provide a proper response in the event of a system failure.
4.2.2 The Service Provider must have a valid cybersecurity accreditation including, but not limited to, those listed on the Flex Assure Website.
4.2.3 The Service Provider must comply with domestic flexibility related Law and regulations including, but not exclusive to those listed on the Flex Assure Website.
4.3.1 Where the Service Provider or any of its employees, agents, contractors or sub-contractors installs any Assets on the Customer's Premises, the Service Provider must or must procure that:
4.4.1 The Service Provider must be committed to creating an environment that is safe and secure for its employees, Customers, and third parties and comply with Laws and regulations including, but not limited to those listed on the Flex Assure Website.
4.4.2 The Service Provider should work in a way that minimises harm to the environment or to the communities in which they work.
4.5.1 Any staff or third parties conducting installation and entering a Customer's Premises on behalf of the Service Provider must:
4.5.2 The Service Provider shall be responsible for any non-compliance with the Code by any staff or third parties working on behalf of the Service Provider, and any non-compliance with the Code by staff or third parties working on behalf of or otherwise representing, the Service Provider will be considered non-compliance on the part of the Service Provider.
4.6.1 The Service Provider and any third parties working on behalf of the Service provider must:
4.6.2 The Service Provider must hold the following insurance policies per incident:
5.1.1 The Service Provider must comply with all Law, regulations, and standards relating to equality and accessibility including, but not exclusive to, those listed on the Flex Assure Website.
5.2.1 The Service provider must not enter into a Contract with a Customer whose circumstances are unsuited to the contracted offering.
5.2.2 Prior to entering a Contract with a Customer, the Service Provider must assess if that Customer would be in its reasonable opinion unable to fulfil the terms and obligations set out in the Contract. In doing this, the Service Provider must inquire whether:
5.2.3 If the Service Provider does not reasonably consider the Customer able to participate in or benefit from the Energy Flexibility Service, they must:
5.2.4 The Service Provider must not exclude Customers based on discriminatory, unreasonable, arbitrary, or unfair grounds.
5.3.1 The Service Provider must take reasonable steps, within their particular capacity, to design flexibility products and/or Energy Flexibility Services that are as inclusive as possible. In particular, the Service Provider must have regard to the needs and limitations of Customers in Vulnerable Circumstances.
5.3.2 The Service Provider must ensure that staff who may reasonably be expected to come into direct contact with Customers are sufficiently trained to identify Customers in Vulnerable Circumstances and what the appropriate steps are to take in such an event.
5.3.3 The Service Provider must take all reasonable steps, within their particular capacity, to ensure that information is capable of being provided in accessible formats, for a wide range of potential Customers. This may include, but is not limited to:
5.3.4 The Service Provider must take reasonable steps, within their particular capacity, to ensure Customers are not incentivised to engage in behaviours that are detrimental to their health and well-being in order to maximise financial rewards.
5.4.1 In circumstances where physical Assets are placed or installed on or in a Customer's Premises, but said physical Assets are not owned outright by the Customer, the Customer should not be liable for any unintentional damage or fair wear and tear to the Assets.
5.4.2 The Service Provider must communicate to the Customer in writing in plain language who to contact in the case of damage, theft, or breakage of the Asset.
5.4.3 Any financial risk and liability posed to the Customer must be limited where possible and must be communicated to the Customer by the Service Provider in plain language.
5.5.1 The Contract should clearly provide the steps that must be taken by the Customer if the Customer is no longer able to participate in the Energy Flexibility Service being provided by the Service Provider.
5.5.2 If the Customer is no longer able to participate in the Energy Flexibility Service being provided by the Service Provider and this requires the reclamation of Assets, this must be conducted professionally, at a time convenient for the Customer and ensure that any other Assets in the Customer's Premises unrelated to that owned by the Service provider still function adequately.
5.6.1 In situations where the Service Provider acts as a Load Controller to the Customer's Assets, the Customer must have the absolute right to Override any automatic Load Control being undertaken by the Service Provider.
5.6.2 The Service Provider must make the Customer aware of:
5.6.3 The Service Provider must not impose any unreasonable or disproportionate losses to revenue based on Customer Override.
5.7.1 The Service Provider must make the Customer aware of the Assets and/or loads within the remit of the Contract.
5.7.2 The Service Provider must make the Customer aware of the options for and implications of signing any or all of the Assets and/or loads up to an Energy Flexibility Service with another Service Provider.
6.1.1 The Service Provider must have a procedure for receiving and processing Customer Complaints in a reasonable and timely fashion, including a procedure for resolving urgent Complaints as set out in 6.2.1.
6.1.2 The Service Provider must inform the Customer in writing about their Complaints Handling Procedure prior to entry of the Contract and either:
6.1.3 The Service Provider must ensure that as a minimum, the following information is available in the Complaints Handling Procedure:
6.2.1 A Complaint would be considered an Urgent Complaint if any of the following applies:
6.3.1 The Service Provider must co-operate fully with the Customer throughout the Complaints Process.
6.3.2 The Service Provider must, within a reasonable timeframe of the Complaint being filed, having regard to the nature of the Complaint, take all reasonable steps to:
6.4.1 For instances when Complaints cannot be resolved between the Service Provider and Customer (a "Dispute") within 8 weeks of receipt of the Complaint, the Service Provider must, where the Customer requests that a referral is made to the Independent Dispute Resolution Service, allow the Independent Dispute Resolution Service to review the Dispute.
6.4.2 If the Customer does not agree with the actions taken or resolution proposed under clause 6.3.2 by the Service Provider, the Service Provider must provide details in writing of the next steps to resolve the Dispute by reference to the provisions set out in the Contract, including but not limited to:
6.4.3 A Customer is not required to participate in independent Mediation or Arbitration unless mutually agreed and may choose to deal with the Dispute in other ways, including by taking legal action.
6.4.4 If the Customer and Service Provider mutually agree to refer the Dispute through independent Mediation or Arbitration:
6.5.1 A Customer may nominate a representative to deal with their Complaint by notifying the Service Provider in writing of their chosen representative's name and contact details.
6.5.2 Service Providers shall deal with the representative as if they are the Customer. All communications usually addressed to the Customer relating to the Complaint will be addressed to the representative directly using the contact details they provided, ensuring the Customer received a copy of all correspondence.
6.6.1 Service Providers must provide Customers with clear written instructions, no later than the time of entry of the relevant Contract on what to do in the event that the organisation with which the Customer will enter the Contract becomes Insolvent.
6.7.1 For a minimum of six years after the Complaint is raised, the Service Provider must keep a written record of the following information: