On 23 April, MOSL submitted its response to the Independent Commission’s Call for Evidence.
The Commission, Chaired by Sir Jon Cunliffe, was established in October 2024 to review the regulatory framework and water sector reform in England and Wales.
MOSL has engaged with the Commission Secretariat since the end of last year, with Kathryn Newell, Head of the Secretariat, presenting at our CEO Forum on 12 December.
In our response, we noted that as the market operator for the business retail market (BRM), MOSL seeks to use evidence and insight to support its participants. We sought to provide factual and evidence-based answers where we felt we could add value and were acting within our remit.
In doing so, we drew not only on the expertise within MOSL but leveraged the collective experience of our Board - whose membership consists of directors operating in the market, as well as independent directors with experience across the public sector, infrastructure, financial and technology industries.
Our response consisted of a cover letter to the Commission and answers to over 30 of the Call for Evidence questions.
Key points on the BRM, as noted in our cover letter:
- We do not believe that limiting the market to large customers (those using over >50 ML/year) will improve outcomes for the sector
- There is no evidence to suggest smaller customers will be better served in the household market
- Data from the Central Market Agency (CMA) shows switching for small customers in Scotland started slowly (comparable to England). The market started to flourish in 2014/15 (seven years after market opening)
- Rather than considering proposals to reduce the size of the market, we believe Government should focus on:
- Improving the profitability of the market by increasing the retailer margins for those who serve smaller customers, allowing these customers to benefit from competition
- Exploring how the BRM can support better outcomes for the efficient use of water, as outlined in our wider regulatory recommendations
- Raising awareness of the market to support greater engagement from all customers, in particular, smaller customers (amongst whom awareness is lower) in order to generate further competition and support the market’s ‘investability’.
We also set out a number of recommendations for regulatory and legislative change to drive broader efficiencies, more strategic and long-term planning and to support economic growth. These are set out in our letter and within the answers to the Call for Evidence.
If you have any questions on our response, please email
