Water Plus Limited: Investigation
Decision to close the investigation into Water Plus Limited (Water Plus) and its compliance with Standard Licence Conditions (the “SLCs”) A2(1), A4(1), B1, B2(2), and B6(1) of its water services and sewerage services licences.
Investigation
In November 2025, the Commission wrote to Water Plus outlining its decision to undertake an investigation of a potential licence breach. After careful review of the information provided by Water Plus, the Commission concluded that Water Plus had been in trivial breach of SLC A4(1), B1, B2(2), and B6(1). The Commission did not identify any evidence that would suggest that Water Plus had been in breach of SLC A2(1).
SLC A4(1) requires that licensed providers shall comply with the Market Code that is in force at any time. Section 5.9.1A.4 of the Market Code requires that each transfer read will always be taken by the physical reading of the meter by the incoming licensed provider, except where the conditions defined in Section 2.8 of CSD0202 apply, when a transfer read may be substituted by an estimated transfer read. Based on the Commission’s review of the initial Terms & Conditions (T&Cs) published by Water Plus, it appeared that Water Plus required its customers to provide meter reads as part of the transfer process, and submitted estimated transfer reads to the CMA in cases where customers did not provide a read prior to a transfer. Water Plus provided evidence that it did not require transfer reads from incoming customers but instead attempts to obtain a transfer read from a qualified meter reader for all relevant incoming meters regardless of the wording in its initial T&Cs. However, Water Plus outlined that it had incorrectly provided to the CMA the transfer reads relating to 5 customers. Water Plus has reminded its staff of the relevant market arrangements and amended its T&Cs to clarify that it does not require its customers to provide transfer reads in Scotland.
SLC B1 requires licensed providers to offer terms and conditions for the provision of default services at the default standards and at a price not exceeding the default maximum tariffs, including the provision of Default Standards payments to customers. Based on the Commission’s review of the initial Default Service Standards for 2025 – 2026 published by Water Plus, it appeared that Water Plus provided outdated compensatory payments to customers. Water Plus acknowledged that it had provided outdated Default Standards payments to c.82 customers in 2023-24, 2024-25, and part of 2025-26 resulting in a marginal detriment per compensation paid of c.£1, £2 and £3 respectively. Water Plus agreed to strengthen its tariff setting procedure and compensate all affected customers with an additional £24 Default Standards payment.
SLC B2(2) requires licences providers to allow all customers on a fixed term contract to terminate their contract ahead of the fixed term. Based on the Commission’s review of the initial T&Cs published by Water Plus, it appeared that Water Plus disallowed the early termination of fixed term contracts and / or requested customers to provide a prior written notice in excess of the allowed provisions. Water Plus asserted that it did not reject early termination requests on the basis of requiring more than 20 business days’ notice. Water Plus did however identify c.23 customers that had been incorrectly blocked between July 2024 and July 2025 from transferring to another licensed provider by terminating their contractual arrangements ahead of term. Water Plus revised its internal processes and agreed to provide scaling compensation to affected customers of £25 (up to £100 retail margin), £50 (up to £250 retail margin), £100 (up to £500 retail margin), and 20% of the retail margin (above £500 retail margin). This includes waiving any early termination fee should those affected customers seek a subsequent transfer within one month of being contacted by Water Plus. Where Water Plus cannot contact any affected customers that have already transferred to a different licensed provider, Water Plus agreed to donate to charity the equivalent value of the compensation.
SLC B6(1) requires licensed providers to comply with the Code of Practice (CoP). Section 1.2.1 of the CoP provides that customers shall be entitled to cancel or terminate a newly agreed contract, at no cost, without giving any reason, by notifying the incoming licensed provider within a cooling off period of 10 business days from the date of agreeing the new contract. Based on the Commission’s review of the initial T&Cs published by Water Plus, it appeared that Water Plus provided a shorter cooling off period. Water Plus acknowledged that its T&Cs only provided a seven-day cooling off period and that this was inconsistent with the requirements of the CoP. Despite providing a shorter cooling off period, the Commission notes that Water Plus has not applied any early termination charges to customers who cancelled their contractual arrangements within or outwith what would have otherwise been the correct cooling off period as required by the CoP. The Commission also notes that in most cases, the relevant communications issued to customers outlining the seven-day cooling off period were typically issued with a certain delay following agreement of the contractual arrangements, this means that in practice most customers would have likely benefited from a cooling off period as that stipulated by the CoP. Water Plus amended its T&Cs and all customer communications to ensure alignment with the CoP.
Decision
The Commission considers the relevant breaches are trivial, affected a small number of customers over a limited timeframe, and appear to have been caused by administrative errors and delays in updating policies or procedures rather than seeking a systemic circumvention of the current market arrangements or an unfair competitive advantage.
The Commission notes the openness and cooperation of Water Plus throughout this investigation. Water Plus has responded to all communications promptly and provided detailed information to allow the Commission to assess the specific circumstances of the case. Water Plus has been open to learn from this investigation and ensure that similar issues of non-compliance do not reoccur.
The Commission is satisfied that Water Plus has appropriately prioritised the issues identified as part of this investigation and put the necessary level of resources in place to quickly address those issues, including the overall proposed redress to those affected customers above and beyond the detriment incurred.
Consistent with its Policy for Licence Contraventions and Policy for Monitoring, Enforcement and Penalties, the Commission made a decision to accept a redress plan proposed by Water Plus and not to undertake enforcement action.