Clear Business Water Customer Protection Code of Practice Undertakings

UK Ofwat Publications & Enforcement

Filed March 26th, 2026

Detected March 26th, 2026

Summary

Ofwat has accepted undertakings from Clear Business Water Limited following concerns regarding compliance with back billing provisions in the Customer Protection Code of Practice. The company incorrectly back billed approximately 309 customers, totaling around £350,000, and is now undertaking remedial actions including account credits and refunds.

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What changed

Ofwat has accepted undertakings from Clear Business Water Limited (CBW) under Section 19 of the Water Industry Act 1991. This enforcement action stems from identified concerns that CBW's Terms and Conditions of Supply did not align with the back billing restrictions in the Customer Protection Code of Practice (CPCoP), leading to approximately 309 customers being incorrectly back billed between October 2024 and October 2025, with a total excess of £350,000.

CBW has updated its Terms and Conditions and is conducting a comprehensive review of all back bills issued since market opening to ensure CPCoP compliance. Affected customers will receive account credits or refunds. This review is expected to be completed by May 8, 2026. Ofwat will monitor CBW's compliance with these undertakings and ongoing adherence to the CPCoP.

What to do next

Review and update Terms and Conditions to align with CPCoP back billing provisions.
Conduct a comprehensive review of all issued back bills for compliance.
Issue account credits or refunds to customers who were incorrectly back billed.

Penalties

Account credits or refunds totaling approximately £350,000 for affected customers.

Source document (simplified)

Clear Business Water Customer Protection Code of Practice undertakings

26 March 2026

Case summary

As part of Ofwat’s monitoring of compliance with the Customer Protection Code of Practice (CPCoP) we requested compliance statements from all Retailers in May 2025. Clear Business Water Limited was one of the Retailers randomly selected to provide supplementary compliance evidence.

As part of our review of the compliance statement and supplementary evidence submitted by Clear Business Water Limited we identified concerns in relation to its compliance with the back billing provisions in section 9.3.1 of the CPCoP. These concerns included that Clear Business Water Limited’s Terms and Conditions of Supply did not align with the back billing restrictions in the CPCoP and that customers may have been back billed in excess of the restrictions.

Clear Business Water Limited confirmed that approximately 309 customers had been incorrectly back billed in excess of the timeframes permitted by the CPCoP between October 2024 and October 2025, either due to a change of tenancy or a data error. Clear Business Water Limited also confirmed that the total amount back billed in excess of the permitted during this period is approximately £350,000.

Clear Business Water Limited has reviewed and updated its Terms and Conditions of Supply to ensure that these properly align with section 9.3.1 of the CPCoP. It is also reviewing all back bills that have been issued since market opening to ensure that these are compliant with the CPCoP. Where it is identified that a bill is not compliant, Clear Business Water Limited is applying account credits for all affected customers (or where the customer no longer receives services from CBW, it will make attempts to contact the customer and process a refund in accordance with the CPCoP). This review is due to be completed by 8 May 2026.

Clear Business Water has confirmed its commitment to compliance with the CPCoP and has provided undertakings under section 19 Water Industry Act 1991 in relation to the above compliance issues and remedial action. We will review Clear Business Water’s compliance with these undertakings following completion of the back billing review and will monitor ongoing compliance as part of our annual review of compliance with the CPCoP.