Ofgem has not written rules specifically for AI chatbots in energy customer service. A supplier's chatbot is held to the same licence conditions as its phone lines and its email team. Ofgem's Ethical AI guidance, which is not binding, adds two expectations worth building to: tell customers when they are dealing with AI, and keep responsibility for it, whoever built it.
The licence conditions are what Ofgem enforces, and a chatbot can break them in ways a contact centre rarely would.
What has Ofgem said about AI?
Ofgem published "Ethical AI use in the energy sector" on 20 May 2025 and a second version on 13 May 2026. It calls it good practice guidance. Its position is that the current regulatory framework is appropriate to govern the use of AI, and that licensees already have to comply with their licence conditions, including treating consumers fairly. The foreword names customer service as one of the areas where AI use has grown.
Three parts of it matter for a chatbot.
Transparency. Appendix 6 sets out what transparency includes. Two items apply directly: making people aware of their interactions with AI systems, with chatbots as the example, in a proportionate way, and disclosing when AI is being used in line with the importance of the interaction.
Accountability. Appendix 3 says that whatever the arrangements for procured services, an organisation cannot outsource responsibility or accountability for safety, security, fairness or sustainability. Buying a chatbot in does not move the risk, and the board holds ultimate oversight.
Human oversight. It recommends human oversight from the earliest stage as a risk control.
So the rules on chatbots are the licence, read through this guidance. Ofcom has taken a similar line in telecoms, covered in what Ofcom says about AI chatbots in telecoms.
Which Ofgem customer service rules apply to a chatbot?
The Standards of Conduct (standard licence condition 0). Suppliers must behave in a fair, honest, transparent, appropriate and professional manner. Their customer service arrangements must make it easy for domestic customers to get in touch, put mistakes right promptly, and be complete, thorough, fit for purpose and transparent. A separate limb covers identifying and treating appropriately customers in vulnerable situations. For domestic suppliers, the Standards also cover anyone acting as their representative.
Ofgem's Standards of Conduct guidance of 5 April 2024 lists, among its non-domestic examples of poor behaviour, a customer who could only contact the supplier by web chat or web form, with nothing saved or sent to them afterwards. Our reading is that a domestic chatbot built the same way carries the same risk under the domestic customer service limb.
The enquiry service rules (standard licence condition 31G). Ofgem's consumer standards decision of 18 October 2023 added these from 14 December 2023. The enquiry service must offer a range of contact methods that meet customers' needs, including those in vulnerable situations, and be available at times that meet those needs. It must prioritise enquiries from vulnerable customers who may need immediate help, and from their representatives. It must be free for customers who are having, or will have, difficulty paying. A further limb, switched on by an Ofgem decision of 10 April 2025, has applied since 1 August 2025: the enquiry service must be available 24 hours a day to customers whose supply is interrupted by a meter fault.
The contact guidance. Suppliers must have regard to Ofgem's contact guidance, updated on 10 April 2025 and in effect from 1 August 2025. It expects methods that suit customers who are digitally excluded (a phone line is its example), with contact details on, or one click from, the homepage. A dedicated freephone number is one way it suggests meeting the free service limb. If service is poor and a supplier is not open, across a range of methods, for a meaningful time outside 09:00 to 17:00 on weekdays, Ofgem may ask it to justify its hours. Its example is two hours a day, or seven hours across the weekend.
A footnote in that guidance belongs on every chatbot project plan. In working out those thresholds, Ofgem left out contact methods it judged would not be covered by customer service representatives, and gave "a completely virtual assistant" as the example. Ofgem says that analysis did not indicate compliance. Our reading is that it would be unwise to count a 24/7 bot as being open out of hours.
How do the complaints rules catch a chatbot?
The Gas and Electricity (Consumer Complaints Handling Standards) Regulations 2008 define a complaint as any expression of dissatisfaction about a supplier's products or services, or about how it handled an earlier one, where a response is given or expected. A customer typing "this is the third bill you've got wrong" into a chat window has made a complaint, whether or not they used the word.
Each complaint must be recorded on receipt with the date and a summary, and so must later contacts about it. When the supplier cannot resolve one, it must write to the customer about their right to go to the redress scheme.
The Energy Ombudsman takes a dispute after eight weeks, or sooner with a deadlock letter, and the customer then has 12 months to escalate. In its June 2026 response on fairer, faster redress, the government decided to cut the eight weeks to six, for Ofgem and the Ombudsman to implement. At the time of writing no start date had been set. A chatbot that treats a complaint as a billing query and closes the chat leaves that clock running on a complaint your records do not hold. More on this in can conversational AI handle complaints.
Where do energy chatbots go wrong?
In our experience the faults are rarely about tone. They are in the routing.
The out-of-hours dead end. A prepayment customer with a meter fault and no power messages at 23:00, and the bot offers a callback tomorrow. The 24/7 limb exists for exactly that customer, and Ofgem says they should not need to know whether the fault is the network's or the supplier's.
Vulnerability nobody named. Ofgem notes that customers will not always say they are vulnerable. Its own suggestions include prioritising contacts linked to Priority Services Register accounts and screening for key words such as "emergency". A carer writing for their mother is a representative the rules say to prioritise, not a data protection problem to deflect.
The free route the bot never mentions. A customer says they cannot afford the next payment. Ofgem expects eligible customers to be told about free contact methods as soon as the supplier knows they are eligible.
What does a compliant energy chatbot look like?
These are the rules we would build to.
- Say it is AI in the first message, and do not give it a human persona. How customers react is in can customers tell they are talking to AI.
- Show the other routes. Phone, including any free number, is one step away in every conversation, and the bot says when the team is back.
- Treat off supply as urgent at any hour. Triage meter faults, send suspected gas emergencies straight to the network operator, and route to whoever covers 24/7.
- Detect complaints by meaning, log them with the date, and hand them over with the conversation attached.
- Route vulnerability and payment difficulty to a person, check the Priority Services Register flag before replying, and sell nothing.
- Send the customer a copy of the conversation, or show it in their account.
- Keep a human owner who reviews transcripts every week and can switch the bot off. What should happen at the edge of what it knows is in what happens when an AI agent does not know the answer.
None of this is unusual for a regulated sector, as we cover in can conversational AI work in a regulated industry.
To see how this looks in a working agent, try our agent.
Sources: Ofgem, "Ethical AI use in the energy sector (version 2)", 13 May 2026, first published 20 May 2025; Ofgem, Standards of Conduct Guidance, 5 April 2024; Ofgem, Consumer standards decision, 18 October 2023; Ofgem, Guidance on expectations for consumers to be able to contact their supplier, 10 April 2025; Ofgem, Consumer Standards: Supplier 24/7 metering support decision, 10 April 2025; The Gas and Electricity (Consumer Complaints Handling Standards) Regulations 2008 (SI 2008/1898); Energy Ombudsman FAQs; DESNZ, "Fairer, faster redress in the energy market" consultation response, 17 June 2026.
