delete The Alternative Fuel Payment Pass-through Requirement (England and Wales and Scotland) Regulations 2023
These 2023 Regulations require 'relevant intermediaries' (such as heat network operators) in the energy supply chain to pass through government Alternative Fuel Payment (AFP) scheme benefits to end users. They mandate just and reasonable pass-through calculations, detailed notification requirements within 30 days, and allow end users to recover unpaid amounts as civil debt with interest. The regulations apply to England, Wales, and Scotland.
These regulations impose comprehensive bureaucratic compliance requirements on energy intermediaries, forcing them to act as administrators of government energy subsidies. The mandatory notification duties, calculation methodologies for 'just and reasonable' pass-through amounts, and prescribed tariff adjustment mechanisms add significant compliance costs without adding value to the economy. The civil debt recovery and interest provisions create a coercive framework that distorts commercial relationships. While the AFP scheme itself represents government intervention in energy markets, these regulations compound that intervention by codifying exactly how subsidies must flow through supply chains, restricting freedom of contract, and creating a quasi-regulatory relationship between intermediaries and end users. Deletion would restore market freedom to intermediaries and end users to negotiate arrangements freely.