What to include in a case file – advice for energy suppliers

Guidance last updated July 2019


Detailed case files allow us to make high quality and well-informed decisions. They allow us to be confident on the circumstances surrounding a complaint, which improves acceptance rates and reduces the need for our investigation officers to call to request further information.

Ultimately, it makes our service much more effective. We hope that this guidance provides a point of reference for how to make the most of our service.

Why are detailed case files so important?

If a company does not support its view with the necessary evidence and the customer does, it is likely that we will uphold the customer’s complaint and make an appropriate award.

It is the company’s role to provide evidence to demonstrate this, which we can pass onto the customer by way of explanation. If you have the information but do not provide it in your case file, you cannot rely on it later when making further representations.

What should a company include in a case file?

Every case file should be tailored to the subject matter of the dispute raised, rather than supplying all the information relating to the account/customer.

All case files should aim to convince us that the company’s point of view is reasonable and that it has followed its processes and procedures.

In every case, we would like to see:

  1. a summary of events (within our Case Management System – CMS) that includes an explanation of any unfamiliar terms raised during the dispute and the company’s current position on the dispute (eg any resolution offers);
  2. customer service records (relevant to the time period the dispute spans);
  3. a copy of any correspondence issued by the provider during the course of the complaint; and
  4. a copy of correspondence received from the complainant during the course of the complaint.

For disputes involving billing we would like to see every case detail, plus:

  1. copies of bills (relevant to the disputed period).
  2. a full list of meter readings associated with the customer’s meter (to allow consumption analysis if required).
  3. if possible, a copy of data flows supporting the meter readings received/attempted to be collected.
  4. copy of any correspondence sent in relation to billing of the account (eg meter reading reminder letters, direct debit assessment letters).
  5. if the dispute involves a catch-up bill, a breakdown of how back billing was applied or reason why not deemed applicable.
  6. a customer’s payment history.
  7. confirmation whether a customer’s credit file has been affected in cases where there has been an outstanding unpaid balance.

For complaints which do not specifically include billing, we would like to see every case detail plus:

  1. a copy of the sales call/documentation/welcome pack, if possible (for mis-selling complaints).
  2. a copy of call recordings or confirmation that a call recording is not available (for cases where a customer disputes the information/advice given during a specific customer service call).
  3. copy of any tenancy agreements/land registry documents held (for complaints involving disputed liability).
  4. details of any meter accuracy checks (for complaints about disputed consumption levels).

If the case file is thorough and clearly written, then in most cases we will not need to check details, saving you time and resources.

In addition to the summary, we expect companies to evidence their opinion with appropriate supporting documents.

This is the same expectation we place on complainants. As a minimum, we would expect a company to provide us with a copy of its account notes.

These notes should start from the time the customer states the issue began until the present date.

It is not acceptable for a company to simply select the notes they think may be of relevance, as experience tells us this is rarely the case.

Further information

We find that companies sometimes counter a customer’s argument by stating that they would have followed their usual process. For example, we occasionally receive complaints from customers that say they did not receive notice of price rises.

We have seen companies counter this by saying they would have sent a standard letter, but they do not provide a copy of it.

In instances like the above, we need to see evidence that the company followed the process; we cannot simply take the company’s word for it. In the absence of the addressed letter itself, we would expect to see evidence in the account notes that a letter was posted and to see the standard template that all customers received.

We appreciate that providing detailed case files can be time consuming. However, investing this time at the beginning of the investigation ensures that you receive a high-quality service. In considering a complaint, we seek to complete a thorough investigation that brings closure to the matter for both parties.

Lack of information prevents us achieving this aim and prolongs the dispute. This costs companies time and increases costs.

Furthermore, it can worsen an already strained relationship with a customer if they ask to see the case file and it does not contain all the facts and details.