INTERMEDIARIES IN A CHANGINGENERGY LANDSCAPE Contents Executive Summary What makes up an energy bill?Role of suppliers and Third-Party Intermediaries (TPIs) Negative practices within the TPI market Case Study: Pennine Healthcare LimitedCase Study: TEMCO Wire Policy environment ExecutiveSummary Manufacturers face an increasingly challenging environment for doing business. Surgingoperational costs are driven by direct factors such as material costs but ever-increasinglyindirect costs such as energy. The Industrial Strategy has set the stage for the UK For energy-intensive businesses like manufacturers,pursuing opportunities to reduce utility costs is mission-critical. However, the energy market is an intricate andinstantaneous space to navigate – events on the other mis-selling, dispute resolution matters and poor customerservice – exacerbating issues around high energy costs On 23 October 2025, the Department for EnergySecurity and Net Zero announced the government’sintention to appoint Ofgem as the regulator for TPIsin the retail energy market. A turning point in the Therefore, Third-Party Intermediaries (TPIs), like energybrokers, can act as an invaluable conduit betweenenergy suppliers and the end consumer. Acting as anintermediary in a technical and complex field like energy Although the practicalities around the future regulatoryregimen are yet to be outlined, businesses can continue However, some allegedly bad actors within the sector fallshort of this standard. Non-domestic energy users have Energy Procurement Towards the end of 2022, a surge in energy prices saw energy costs fast become the number one issue for UKmanufacturers. This increased the usage of third party intermediaries such as energy brokers as manufacturers As energy costs have become a critical concern for businesses, many organisations seek assistance fromintermediaries. This route allows businesses, particularly SMEs, who may lack energy marketexpertise or internalresource, to secure the most opportune market contracts on offer. Many intermediaries offer a fully-managed service, Therefore, the role of a third-party intermediary is to ensure securing the best possible rates and help clients navigatea complex energy market, thus finding ways to optimise their energy procurement contracts around their usage. What makes up anenergy bill? Energy bills are multifaceted, influenced by complex industry information andnumerous government policies. As the UK are a net importer of energy, it can make Some of the key drivers of UK energy price include: –Geopolitics. –Weather – has a significant impact on our renewable generation but also plays a huge part in demande e.g gas forheating in winter, electricity for cooling in summer.–Supply and demand.–Gas storage levels – our security buffer when supply from continent or via liquefied natural gas (LNG) is low.–Outages – power generation assets having planned or unplanned maintenance. Your business energy bills are made up of two mainelements: –The commodity cost.This is the wholesale costof the electricity and gas you use – set by market –Non-commodity costs,also known as third partyor non-energy costs. Examples of non-commoditycosts include Transmission Network Use of System When discussing surging energy prices, therelationship between commodity and non-commodity The commodity cost has been defined by the couplingof gas and electricity prices, driven by the UK’smarginal pricing system which sets market ratesaccording to the most expensive generator to come Energy Brokers:Intermediaries in a changingenergylandscape This means UK electricity prices have reflected thestrong rise in gas prices since 2021 – influenced byfactors such as the pandemic and the Ukraine war. Thishas been exacerbated by the UK’s relative dependence These costs are set to rise shortly as new transmissioninvestment and nuclear power hit bills which could see energy Make UK has previously argued against the regressivenature of added costs, pushing the government toensure the costs of policy schemes are not borne Moreover, the UK places most of its electricity policylevies – taxes – directly onto electricity bills. This has by manufacturers (e.g. via gas bills).5Instead, thesecosts should be paid for in a progressive way whichaligns with growth and decarbonisation objectives.The Government has stated its intention to consult ona British Industry Competitiveness Scheme (BICS) toaddress the impacts of these policy costs and drivedown costs for manufacturers. Make UK has proposed a For example, government schemes that support energyintensive businesses with their energy costs are fundedwith these taxes – collected from electricity suppliers and Commodity costs: wholesale costs Electricity and natural gas can be bought and sold in large volumes from the wholesale market. Generators andproducers supply electricity or gas to the market and sell these for suppliers or retailers to supply to end user