Market Insights & Legal Updates
A rapidly expanding market with clear legal momentum.
The hidden commission claims opportunity spans nearly every UK business that purchased energy through intermediary channels, and recent legal decisions have strengthened the likelihood of successful recovery.
Addressable Universe
Our analysis indicates that the opportunity is broad enough to cover essentially the full UK business base. The market is not confined to a narrow niche; it reaches the vast majority of companies that relied on brokers or intermediaries for commercial energy procurement.
Businesses in scope
99.9% of UK businesses
Annual turnover represented
£2.75 trillion
Potential claim pool
Broad energy procurement and broker commission exposure
Why this matters
The scale of the issue means a large number of businesses could be eligible for compensation, especially where commissions were not properly disclosed or where the contract structure was not transparent.
Recent Legal Developments
March 2025 – Court of Appeal decision
The legal position around hidden commission claims strengthened materially, with the court clarifying that mis-disclosed commissions remain actionable where the commercial relationship was not properly transparent.
2024 – Ofgem disclosure rules
Ofgem introduced tighter expectations around commission disclosure, reinforcing the importance of clear broker remuneration and customer transparency.
2025 – Supreme Court precedent
The Expert Tooling decision removed the previous distinction between half-secret and fully-secret commissions, broadening the scope of challengeable conduct.