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Methodology & Regulatory Rules

How PowerView determines an exception — the exact input fields, trigger conditions, output fields and regulatory reference behind every flag we raise.

INTERNAL TRIAGE ONLY - Sample data - Not Ofgem-approved. This report identifies potential billing exceptions requiring supplier review, not established breaches. Requires independent energy-regulatory review and testing against real billing records.

Scope

Domestic customers, and microbusiness customers where the supplier applies the same backbilling protection. Non-microbusiness I&C accounts are out of scope.

Tested on sample data only. Not yet tested against real billing records, and not yet subject to an independent energy-regulatory review. Both are prerequisites we state openly before any supplier relies on the output.

Rule specifications

Four detection rules run against a supplied billing extract. Two cite a Standard Licence Condition; two do not, and are labelled accordingly.

SLC 21BA

Back-billing - evidenced aged under-billed difference

Regulatory reference

Standard Licence Condition 21BA (back-billing). Ofgem's 12-month back-billing limit sits in SLC 21BA, not SLC 27.

Input fields

  • account_ref - account identifier
  • mpan - supply point number
  • bill_date - date the bill or correction was issued
  • consumption_period_start / consumption_period_end
  • validated_actual_consumption and cumulative_consumption_billed
  • unit_rate and standing_charge
  • standing_charge_days
  • fuel_type, customer_type and VAT rate

PowerView flags

The supplied evidence shows a positive under-billed consumption difference for a consumption period ending more than 12 months before the bill date.

Output

  • Anonymised account identifier
  • MPAN (masked in exported reports)
  • Bill date and evidenced consumption period
  • Validated, billed and under-billed consumption
  • Applicable standing-charge days and VAT treatment
  • Indicative screening estimate, or 'not quantified'
  • SHA-256 evidence hash of the sealed report

Limitations of this rule

  • Carve-outs are not modelled: protection does not apply where the delay is attributable to the customer, to theft of energy, or to conduct outside the supplier's control.
  • A 365-day gap in actual readings is an SLC 21B review trigger only and cannot fire this rule.
SLC 21B

Billing based on meter readings - estimate after an actual read

Regulatory reference

Standard Licence Condition 21B (billing based on meter readings).

Input fields

  • account_ref - account identifier
  • mpan - supply point number
  • reading_date - date of the reading or bill line
  • reading_type - actual or estimated indicator
  • consumption - kWh on the line
  • unit_rate / standing_charge - optional pricing

PowerView flags

A valid actual meter reading exists for the account AND a later bill on the same account is based on an estimated reading.

Output

  • Anonymised account identifier
  • MPAN (masked in exported reports)
  • Date of the actual reading and date of the later estimated bill
  • Days elapsed between the two
  • Estimated consumption billed
  • Not quantified - SLC 21B review flags do not establish financial exposure
  • SHA-256 evidence hash of the sealed report

Limitations of this rule

  • SLC 21B allows an estimated bill where an actual reading could not reasonably be obtained. PowerView cannot see meter-reading attempts, appointment history or industry data flows, so this rule is deliberately over-sensitive and produces triage candidates, not findings.
  • Reading type is derived from the text supplied: anything containing 'est' is treated as estimated. Customer-own-reads and deemed reads are not distinguished.
No SLC citation

Priority Services Register - supplier flag with no DNO link

Regulatory reference

Informational gap analysis only. No licence condition is cited and no licence determination is made.

Input fields

  • account_ref / mpan
  • supplier-held vulnerability flag
  • DNO PSR record where supplied

PowerView flags

The supplier holds a vulnerability flag for the account but no corresponding DNO PSR record is present in the data supplied.

Output

  • Anonymised account identifier
  • MPAN (masked)
  • Vulnerability category held by the supplier
  • Gap description
  • SHA-256 evidence hash of the sealed report

Limitations of this rule

  • A gap in the file supplied is not evidence that a record is missing from the DNO's own register.
No SLC citation

Direct Debit discount expected but not applied

Regulatory reference

Contractual / terms matter. This is NOT back-billing and carries no SLC citation. It was previously grouped under SLC 21BA; that label has been removed.

Input fields

  • payment_method - must indicate Direct Debit
  • dd_discount_expected - true/false
  • dd_discount_applied - true/false
  • monthly_dd_amount - £ (optional, needed to price the exposure)
  • months_without_discount - count (optional)

PowerView flags

The account pays by Direct Debit AND the discount is recorded as expected AND the discount is recorded as not applied.

Output

  • Anonymised account identifier
  • Months billed without the discount
  • Monthly Direct Debit amount
  • Recovery exposure (monthly amount × months), or 'not quantified' where the file carries no amount
  • SHA-256 evidence hash of the sealed report

Limitations of this rule

  • Exposure is not VAT-adjusted; it is the sum of the discount amounts as supplied.
  • Where the file carries no monthly amount or affected month count, the row is reported without a figure rather than estimated.

Calculation behind the indicative screening estimate

Indicative screening estimate = ((validated actual consumption - cumulative consumption already billed) × unit rate + standing charge × applicable days) × (1 + applicable VAT). It is calculated only for an evidenced consumption period ending more than 12 months before the bill date. If dates, consumption difference, tariff or VAT treatment are missing, the value is not quantified.

Known limitations across all rules

  • SLC 21BA carve-outs are not modelled: back-billing protection does not apply where the delay is attributable to the customer (obstructed access, refused appointments), to theft of energy, or to other conduct outside the supplier's control. Flags must be reviewed against those facts.
  • SLC 21B allows an estimated bill where an actual reading could not reasonably be obtained. The engine cannot see meter-reading attempts, appointment history or industry data flows, so estimate-after-actual flags are deliberately over-sensitive and are triage candidates, not findings.
  • The engine cannot determine customer-fault carve-outs, theft, meter-access evidence, change-of-tenancy or change-of-supplier facts. Those facts require supplier review even when the structured billing fields support an SLC 21BA screening flag.
  • Reading type is derived from the text in the file: anything containing 'est' is treated as estimated, everything else as actual. Customer-own-reads and deemed reads are not distinguished.
  • Detection and triage only. It does not replace regulatory judgement.

What PowerView does NOT determine

A flagged record is a potential exception requiring supplier review. PowerView does not determine whether a regulatory breach has occurred, does not make licence determinations, is not Ofgem-approved and does not report anything to any regulator. The supplier confirms, dismisses or escalates each row against its own billing records.

Wider licence context and our independence disclaimer sit in the Ofgem Compliance Statement.