Our response to Ofwat’s consultation on proposed changes to Guaranteed standards scheme in Wales
We welcome the opportunity to submit our views on Ofwat’s consultation on the Guaranteed Standards Scheme (GSS) Wales.
Background
The Guaranteed Standards Scheme (GSS) has been in place for 35 years, without significant changes prior to those made in England in July 2025.
Ahead of this, in July 2024, CCW shared with Defra a set of recommendations to update the GSS. CCW carried out a programme of work which included customer research which included Wales, a call for evidence and a series of workshops with industry stakeholders which led to these recommendations.
In July 2025, following a consultation (pdf), Defra announced the changes that would be implemented in England, and Ofwat published a summary document.
In Wales, Welsh Government decided that customer research was to be carried out specifically with Welsh customers before they consider any changes to the GSS. Ofwat published this customer research in July 2025 (pdf), which then led to the proposals for changes to the GSS as set out in the consultation.
Executive summary
We support the recommendations within this consultation that mirror the changes that have been implemented in England, and our focus when considering alternative options is to ensure that customers in Wales are not disadvantaged in comparison to England.
Within the consultation, option one is presented as mirroring changes that have been implemented in England and option two is an alternative proposal.
We have taken this into account in our response and have responded in more detail on the areas where proposed alternative options are under consideration. These are:
- Supply not restored on time
- Sewer flooding
- Incorrect debt action
- Water quality notices
Detailed response
| GSS Regulation | Current GSS payment | Our proposal – option 1 | Our proposal – option 2 |
|---|---|---|---|
| Supply not restored | Household (HH): £20 for initial period, £10 for each further 24hrs
Non-household (NHH): £50 for initial period, £25 for each further 24hrs |
HH: £50 for initial period, £50 for each further 12hrs, cap of 2 x annual water supply bill
NHH: £100 for initial period, £100 for each further 12 hrs, cap of 2 x annual water supply bill |
HH: £50 for initial period, £50 for each further 12hrs, cap of 2 x average HH water supply bill in Wales
NHH: £100 for initial period, £100 for each further 12hrs, cap of 4 x average HH water |
| Incorrect notice of planned supply interruption | HH: £20
NHH: £50 |
HH: £50
NHH £100 |
HH: £50
NHH £100 |
Option one mirrors what has been implemented in England and is the option we support. If the average bill is used as the basis for the cap, those with a lower than average bill would benefit more, whilst those with higher than the average bills would be disadvantaged.
Option two proposes a cap that is based on the average household bill, as opposed to being based on the individual customer bill. It also proposes a non-household cap which is four times the average household bill rather than two times the customer’s own annual bill. The reasoning for this, stated in Ofwat’s consultation was that it may lead to consequences that may not be welcomed by customers such as some customers reaching the cap before others.
Using the individual customer’s bill as a basis of the cap ensures that GSS payment is fair and proportionate to charges they pay. This is particularly relevant as the GSS is intended to provide payments which recognise service failure rather than to serve as compensation.
This situation would be particularly acute for some non- household customers. Non-households vary massively in size and in the scale of their water bills. As for households, non-households would be at either an advantage or disadvantage based on the proposed option two cap. For larger business users experiencing lengthy interruptions, linking the cap to average household bill levels does not make sense as it could limit payments for loss of service at levels disproportionate to their water bill (high or low).
| GSS Regulation | Current GSS payment | Our proposal – option 1 | Our proposal – option 2 |
|---|---|---|---|
| Internal sewer flooding – HH | Annual sewerage charge (min £150, max £1000) | Annual sewerage charge (min 300, max £2000)
Repeat incidents – minimum is £300+ (£100 x number previous incidents in rolling 12 month period) |
One room affected – £300
Two rooms affected or one room kitchen / only bathroom – £400 Whole floor affected or unliveable – £600 Repeat incidents – amount is £as above + (£100 x number previous incidents in rolling 12 month period) |
| Internal sewer flooding – NHH | Annual sewerage charge (min £150, max £1000) | Annual sewerage charge (min £300, max £2000)
Repeat incidents – minimum is £300+ (£100 x number previous incidents in rolling 12 month period) |
Annual sewerage charge (min £300, max £2000)
Repeat incidents – minimum is £300+ (£100 x number previous incidents in rolling 12 month period) |
| External sewer flooding – HH | 50% of annual sewerage charge (min £75, max £500) | 50% annual sewerage charge (min £150, max £1000)
Repeat incidents – min is £150+ (£50 x number previous incidents in rolling 12 month period) |
£150
Repeat incidents – amount is £150+ (£50 x number previous incidents in rolling 12 month period) |
| External sewer flooding – NHH | 50% of annual sewerage charge (min £75, max £500) | 50% annual sewerage charge (min, max £1000)
Repeat incidents – min is £150+ (£50 x number previous incidents in rolling 12 month period) |
50% annual sewerage charge (min, max £1000)
Repeat incidents – min is £150+ (£50 x number previous incidents in rolling 12 month period) |
Option one mirrors what has been implemented in England which we support. We believe option one is easier to operate in practice and takes account of the amount which each individual customer pays for their sewerage service.
Option two proposes a grading system that is dependent on the severity of the incident for internal sewer flooding, and a set payment for external sewer flooding. Option two was based on Ofwat’s customer research (pdf) where customers felt payment should depend on the severity of the incident however was possibly mistook for compensation.
Our review of this standard considered the potential advantages of a grading system and how it could make GSS proportionate to the severity of an incident. We concluded that option 2 raised some considerable issues in terms of how this would be administered, the resources that would be needed to assess every incident on a case-by-case basis, and the potential for customers having to delay clean up for impact to be assessed.
The fact that GSS is intended as a payment for service failure, rather than compensation, is also relevant here, and we believe a good reason for maintaining a link between the level of payment made and the individual customer’s sewerage bill level. It should also be noted that GSS does not prevent companies from compensating customers based on the severity/damage caused as an addition to the GSS payment.
| GSS regulation | Our proposal – option 1 and 2 |
|---|---|
| Wrongly issued court summons | £40 |
| Wrongly issued court summons that result in a judgment against the customer | £100 |
| incorrect payment defaults registered with a credit reference agency | £100 |
Ofwat’s proposal mirrors the original recommendation made by CCW.
In England, this standard is structured around the actions that have been taken by the company before any Credit reference agency reporting, third party recovery or court action is taken. Failure to follow these actions results in a £150 GSS payment.
We believe that the proposal set out above by Ofwat is the most practical way for this standard to be structured. The standard would require guidance from Ofwat to set out when this standard is and is not payable including defining what the term ‘wrongly issued’ would include.
| GSS regulation | Our proposal – option 1 | Our proposal – option 2 |
|---|---|---|
| Boil water notice | If notice is in place for longer than 48 hours:
HH: £40, plus £20 per day for each additional day. Cap of annual water supply bill NHH: £60, plus £40 per day for each additional day. Cap of annual water supply bill |
If notice is in place for longer than 48 hours:
HH: £40, plus £20 per day for each additional day. Cap of average HH water supply bill in Wales NHH: £60, plus £40 per day for each additional day. Cap of 2 x average HH water supply bill in Wales |
| Do not drink notice | If notice is in place for longer than 48 hours:
HH: £40, plus £20 per day for each additional day. Cap of annual water supply bill NHH: £60, plus £40 per day for each additional day. Cap of annual water supply bill |
If notice is in place for longer than 48 hours:
HH: £50, plus £25 per day for each additional day. Cap of average HH water supply bill in Wales NHH: £65, plus £45 per day for each additional day. Cap of 2 x average HH water supply bill in Wales |
| Do not use notice | If notice is in place for longer than 48 hours:
HH: £40, plus £20 per day for each additional day. Cap of annual water supply bill NHH: £60, plus £40 per day for each additional day. Cap of annual water supply bill |
If notice is in place for longer than 48 hours:
HH: £60, plus £30 per day for each additional day. Cap of average HH water supply bill in Wales NHH: £70, plus £50 per day for each additional day. Cap of 2 x average HH water supply bill in Wales |
Option one mirrors what has been implemented in England. Option two sets out payment by notice type depending on the inconvenience caused.
The research carried out by Ofwat (pdf) highlighted that customers in Wales wanted the payments to be linked to the severity of the restriction applied. The ‘do not use’ notice was compared to the ‘supply not restored on time’ standard as they both leave the customer with no water. Customers also raised the addition of potential health risks and felt this should be reflected in the payments.
Given the findings of Ofwat’s research we support the payment structure set out in option two. However, in line with other measures, we believe that the caps applied to the payment amounts should be linked to the individual customer’s water bill level rather than that of the average household. The latter approach would be particularly impactful for larger businesses, which could see their payments limited severely relative to their bill size.