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The New Change of Occupier (CoO) Process for Energy Contracts
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Kate McCann
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The New Change of Occupier (CoO) Process for Energy Contracts
The Change of Occupier (CoO) process is a vital part of energy contract management — and it’s just been overhauled....
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The Change of Occupier (CoO) process is a vital part of energy contract management — and it’s just been overhauled. Whether a business is moving into a new premises, a landlord is taking back control, or a site becomes vacant, there needs to be a clear, fair and timely way to reflect those changes in energy supply agreements. The newly introduced CoO process, formalised under Retail Energy Code (REC) Change Proposal R0155, aims to do exactly that.
What Is a Change of Occupier (CoO)?
A Change of Occupier, also sometimes referred to as a Change of Tenancy (CoT) refers to a change in the legal entity responsible for a premises. This might be a well-planned shift, such as a property sale or business handover, or something less predictable, like insolvency or early lease termination. Regardless of how or why it happens, the site will still have an energy supply — and a supplier who needs to know who is responsible for it.
In some cases, the supplier may have an active contract in place. In others, the supply may be governed by a deemed contract. Either way, it’s important that the energy supplier is informed of the CoO as early as possible to avoid billing issues and ensure fair treatment of all parties involved.
Why Has the CoO Process Been Updated?
The CoO process has historically been inconsistent and open to interpretation, particularly for non-domestic properties. The revised schedule aims to set expectations around communication, documentation, and timelines — while remaining flexible enough to cater for different scenarios and business types.
The changes have been designed with both consumers and energy suppliers in mind, encouraging early notification, transparency, and fairness in how changes are handled.
Key Features of the New Process
What Happens If There’s No Supplier Switch?
When the existing supplier remains in place, they have 10 working days to review the CoO documentation and either accept it, reject it, or request further evidence. If additional documents are requested, the supplier has a further 10 working days to respond once those have been submitted.
The supplier must clearly communicate the outcome and reasoning, whether the documentation is accepted, incomplete, or mismatched. If the CoO is accepted, the supplier will close the old account and create a new one for the incoming party — which may involve setting up a new contract or moving to a deemed rate.
What If There Is a Supplier Switch?
In a switch scenario, it’s strongly recommended that the CoO documentation is shared with both the gaining and losing suppliers. This ensures billing records are accurate and any objections are managed transparently.
If the new supplier initiates a switch and flags it as a CoO, the current supplier can review the evidence and either accept the change or raise an objection. If the objection proceeds, the losing supplier must explain the reason to the consumer and document any next steps. The gaining supplier can then decide to pause or proceed by escalating the evidence via the Secure Data Exchange Portal (SDEP).
This part of the process has its own performance obligations. Both suppliers are expected to act within 10 working days and to communicate their decisions clearly and securely.
What’s Not Covered?
The updated CoO schedule focuses on occupancy status and supply responsibility. It doesn’t cover energy billing, fraud investigations, or changes to property classification (for example, from non-domestic to domestic use). These fall under separate procedures and regulatory conditions.
Suppliers are encouraged to pause any billing activity or debt recovery while a CoO is under review. They must also consider the consumer’s ability to obtain documentation and the time or cost associated with doing so.
Supporting Documents: What Can Be Accepted?
In addition to leases, surrenders, and sale agreements, other supporting documents may include letters from landlords, banks, or administrators confirming a change; business rates bills showing the new occupier; insurance documents or utility invoices; water supply contracts; or estate agent confirmation letters. While helpful, not all documents independently confirm occupancy, and energy suppliers will assess the risk and reliability of the evidence case-by-case.
What’s the Outcome of the Change?
Overall, the revised CoO process represents a significant step forward in fairness, clarity, and operational consistency across the energy sector. It gives businesses a more structured path to manage occupancy changes, reduces ambiguity for suppliers, and helps prevent disputes before they start. With clearly defined timelines, improved guidance on acceptable evidence, and a focus on fair treatment, this change supports a smoother transition for all involved — ultimately benefiting both consumers and suppliers alike.
If you’d like any guidance ont the new change, feel free to contact one of our expert team, or book a free consultation.