What this consultation actually is
On 25 March 2026, three days before the Iran conflict sent wholesale gas prices sharply higher, Ofgem quietly published a consultation proposing to reduce the benchmark consumption figures it uses to present the headline energy price cap. The consultation closes on 20 April 2026, giving stakeholders less than four weeks to respond.
The figures in question are the Typical Domestic Consumption Values, or TDCVs. They are the assumed annual energy usage of a "medium" household, the benchmark Ofgem uses to translate unit rates (pence per kWh) into the single annual bill figure that politicians quote, the media reports, and fuel poverty metrics are anchored to. The current medium TDCVs of 2,700 kWh of electricity and 11,500 kWh of gas have been in place since the 2023 review.
Ofgem is now proposing to reduce them: electricity from 2,700 to 2,500 kWh, and gas from 11,500 to 9,500 kWh. That is a 17% reduction in the gas benchmark in a single revision. Ofgem acknowledges explicitly in the consultation document that adopting these figures would reduce the communicated annual bill for a medium usage direct debit customer from £1,641 to £1,489, a fall of £152, on the exact same unit rates.
To be unambiguous: the proposed TDCV reduction does not make energy cheaper. It does not reduce what anyone pays per kWh. It changes the hypothetical annual consumption figure used to construct the headline number. As Ofgem states in paragraph 3.17 of the consultation: "we recognise that updating TDCV values in line with our proposals will result in a reduction in communicated typical annual bill amounts. This is caused by a change in our assessment of how much energy customers are using, not a reduction in the price of energy."
What is being changed and by how much
The table below sets out the proposed changes across usage levels. The medium figures determine the headline cap number quoted in government announcements and press coverage.
| Fuel & type | Level | 2023 TDCV | Proposed 2026 | Change |
|---|---|---|---|---|
| Electricity - Standard single-rate meters | ||||
| Electricity | Low | 1,800 kWh | 1,600 kWh | -11% |
| Electricity | Medium | 2,700 kWh | 2,500 kWh | -7% |
| Electricity | High | 4,100 kWh | 3,800 kWh | -7% |
| Gas | ||||
| Gas | Low | 7,500 kWh | 6,000 kWh | -20% |
| Gas | Medium | 11,500 kWh | 9,500 kWh | -17% |
| Gas | High | 17,000 kWh | 14,000 kWh | -18% |
The gas revision is the more significant. A 17% reduction in the medium gas benchmark at Q2 2026 unit rates (5.74p/kWh) reduces the communicated annual gas bill from approximately £766 to approximately £630. Combined with the smaller electricity reduction, the total headline dual-fuel figure moves from £1,641 to £1,489 at identical unit rates.
What changes and what does not is worth stating plainly. The two panels below use the same Q2 2026 confirmed unit rates. The only difference is the consumption benchmark applied to them.
The case Ofgem makes for the change
Ofgem's justification is not manufactured. UK household energy consumption has genuinely been falling for years, and the data backs this up. DESNZ's subnational consumption statistics, the same dataset Ofgem uses to set TDCVs, show mean electricity consumption has fallen by around 18% since 2005, and mean gas consumption by approximately 32% over the same period.
The drivers Ofgem identifies are well-established: improved insulation, modern boiler replacements, higher EPC ratings in newer housing stock, more efficient appliances, and warmer average temperatures due to climate change, which Xoserve's 2024 Seasonal Normal Composite Weather Variables review formally acknowledges as a structural shift in the gas heating baseline.
On that basis, using an 11,500 kWh gas benchmark when median actual consumption is closer to 9,500 kWh does overstate what a typical household pays. If the TDCV genuinely overstates usage, the headline number is misleading in that direction too. Correcting it is a legitimate regulatory function.
The honest version of Ofgem's argument: if the benchmark is wrong, it should be corrected, even if the timing is awkward. Using a consumption figure that is materially above what households actually use creates a systematic upward bias in the headline number, distorting consumer decision-making, fuel poverty statistics, and media coverage. Accuracy serves everyone's interests in the long run.
The admissions buried in the consultation
What makes this consultation unusually revealing is how directly Ofgem acknowledges its own uncertainties. Several paragraphs are worth quoting precisely.
Paragraph 3.8: "Throughout the wholesale price crisis, consumers significantly reduced their energy use in response to affordability pressures... This behaviour change may have continued even as prices have stabilised. This could be either temporary in nature or a more persistent change."
This is Ofgem acknowledging it cannot determine whether the consumption reduction is structural or price-driven. If it is primarily price-driven, people using less gas because it cost 400% more than it did in 2020, then as prices stabilise, consumption may rebound and the proposed TDCV would understate typical usage.
Paragraph 3.14: "Based on these factors and given that the next TDCV review will rely on consumption data from only 2025 and 2026, any rebound in demand is unlikely to materialise clearly enough within this limited window to prevent the proposed TDCVs being set materially too low."
This is the most striking admission in the document. Ofgem is explicitly stating that its own methodology creates a structural problem: by the time any consumption rebound appears in the data, it will already have adopted lower TDCVs that cannot be quickly corrected. The regulator knows this and is proceeding anyway.
Paragraph 3.15: "Recent geopolitical events have introduced renewed uncertainty into energy markets, potentially reinforcing more cautious consumption behaviour."
This is the Iran conflict, in regulatory language. Higher prices suppress consumption further, which makes 2025 and 2026 data look even lower, which supports the case for lower TDCVs. The feedback loop between high prices, reduced consumption, and a lower benchmark is visible in the document itself.
The timing question
The consultation was published on 25 March 2026. The Iran conflict that has driven Q3 2026 cap forecasts to around £1,929 began on 28 February 2026. The Q3 observation window closes on 17 May 2026. The consultation closes on 20 April 2026.
These dates matter because they frame the political effect of any adopted change. If the proposed TDCVs are implemented before the Q3 cap is announced on 27 May, then the headline number Ofgem publishes for July will be calculated against 9,500 kWh of gas rather than 11,500 kWh. A Q3 cap that might otherwise be reported as "rising to £1,929", a headline increase of £288, would instead be reported as rising to approximately £1,590 under the new TDCVs. The percentage increase would appear smaller. The absolute number would appear lower.
Ofgem almost certainly began preparing this consultation well before the Iran conflict escalated. The consumption trend has been running for years and the previous review was in 2023. But the political effect is real regardless of intent: reducing the benchmark at the moment when wholesale prices are rising rapidly means the headline cap figure will be materially lower than it otherwise would have been, on a like-for-like basis.
The £152 effect in context: under proposed TDCVs, a Q3 forecast of around £1,929 on old figures would become roughly £1,590 on new figures, at the same unit rates. A rise from £1,641 to £1,590 could be presented as a fall. The public's actual bill, driven by unit rates applied to real consumption, would be materially different from both numbers.
What actually changes for households
The TDCV change has no effect on what you pay. Your bill is calculated from your actual meter readings multiplied by your actual unit rates, plus daily standing charges. TDCVs do not appear anywhere in that calculation.
What TDCVs affect is three things: the headline number Ofgem quotes in cap announcements; the figures that suppliers, price comparison websites and the media use to illustrate "typical" bill levels; and the methodological inputs to fuel poverty calculations and government support thresholds. That last point matters more than it might appear. The Warm Home Discount eligibility framework and fuel poverty line definitions are calibrated against the TDCV-based typical bill. If the benchmark shifts permanently lower, the floor at which these measures kick in also shifts, potentially excluding some households that would have previously qualified.
If you use more than 9,500 kWh of gas per year, and many households in older or less-insulated properties do, the new TDCV will understate your actual costs relative to the headline, because the benchmark no longer reflects your usage pattern.
The broader question
Ofgem's own consultation notes that TDCVs serve two distinct purposes now in tension. The first is to give consumers an accurate benchmark for how much energy a typical household uses. The second is to provide a common reference point for communicating the impact of price changes across industry, government and media.
If real consumption has permanently fallen to 9,500 kWh of gas, then using 11,500 kWh overstates what a typical household pays. Correcting it serves the first purpose. But if the benchmark is also the number that government and media use to evaluate whether intervention is needed, reducing it at precisely the moment prices are rising serves the second purpose in a politically convenient direction. The consultation does not appear to invite views on whether these two functions should be kept separate.
The question worth putting to Ofgem: if the TDCV is being reduced because actual consumption has fallen, partly in response to high prices, what happens when prices fall and consumption recovers? Will the benchmark be revised upward at the same pace it is being revised downward? The consultation is silent on this asymmetry. The response deadline is 20 April 2026. Responses go to the Retail Price Protection team at priceprotectionpolicy@ofgem.gov.uk.