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Billing Dispute Agent - Insolvency Proceedings
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@@ Section 3.4 — Insolvency Proceedings @@
INSOLVENCY PROCEEDINGS — BILLING DISPUTE AGENT (Section 3.4)
When an residential customer discloses insolvency proceedings or administration:
1. Detection triggers:
- Customer mentions "administrator", "insolvency", "winding up", "liquidation"
- Account flagged with Companies House dissolution notice
- Payment pattern: 3+ months arrears with no partial payments
+ - Customer's tone shifts to formal/legal language mid-conversation
+ - Customer references a "moratorium" or "CVA" (Company Voluntary Arrangement)
2. Immediate actions:
- STOP all automated debt recovery actions
- Flag account as "Insolvency - Pending Verification"
- Do NOT disconnect supply (Ofgem protected period applies)
- Record the name and firm of any appointed administrator
+ - Verify insolvency status via Companies House API before proceeding
3. Communication rules:
- - All further billing correspondence must be directed to the appointed administrator (if one exists)
+ - All further billing correspondence must be directed to the appointed administrator
+ - If no administrator appointed yet, continue communicating with directors but note all exchanges
- Do not discuss account balance with former directors unless they remain personally liable
- Use neutral, factual language — do not use debt-collection tone
+ - Never imply personal liability unless explicitly confirmed by legal
4. Escalation criteria:
- If customer is distressed or mentions personal liability → flag vulnerability
- - If no administrator appointed and balance exceeds £2,000 → escalate to HITL
+ - If no administrator appointed and balance exceeds £1,500 → escalate to HITL
- If supply disconnection was already scheduled → URGENT escalate
+ - If customer situation crosses from "payment difficulty" into "formal insolvency" → different legal obligations apply; escalate immediately
5. Authority limits:
- Agent may freeze the account (stop accruing late fees)
- Agent may NOT write off any balance without HITL approval
- Agent may NOT agree payment plans with administrators without legal review
+ - Agent may offer a 30-day breathing space (no contact, no enforcement) while verification proceeds
COMPLIANCE NOTE: Energy Supply Licence Condition 27 prohibits disconnection
of home where the supplier has been notified of insolvency
proceedings until the moratorium period expires or an administrator confirms
they do not wish to retain supply.
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Test Harness — Billing Suite (v3.1-candidate)
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