Overview
This is a consultation on draft guidance setting out how companies should apply Licence Condition G (the customer-focused licence condition) when supporting customers affected by sewer flooding. It explains the evidence and issues informing the guidance, presents Ofwat’s proposals, and includes a draft of the guidance text.
- Water and wastewater companies
- Customer service directors and operational leads responsible for sewer flooding response
- Consumer bodies (including CCW)
- Other interested stakeholders
We welcome responses to our consultation by 21 September 2026.
Responding to this consultation
We welcome all responses to our consultation, and particularly answers to the following questions:
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Minimum expectations
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Consultation questions
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- Companies should apply the definitions set out in Table 1 consistently across their operations, communications and reporting to customers and Ofwat.
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- Do you agree with our proposal to introduce these common definitions relating to sewer flooding service and support?
- Are there any further definitions which we should include in our guidance?
- Are there any further considerations, evidence or practical examples you would highlight? For example:
- Do the proposed definitions support consistency and improved customer outcomes across the sector?
- Are there any risks or unintended consequences associated with standardising definitions across the sector?
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- Companies should adopt an end‑to‑end approach to the management of sewer flooding incidents, ensuring that customers are supported, informed and reassured throughout the entire journey from initial contact through to resolution and aftercare.
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- Do you agree with our proposal for introducing a minimum expectation relating to delivering good customer service across the full customer journey?
- Are there any further considerations, evidence or practical examples you would highlight? For example:
- Does the expectation go far enough to deliver good customer outcomes?
- Are there additional elements of the customer journey that should be more explicitly reflected (for example, aftercare or interaction with third parties)?
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- Companies should ensure that communications with customers experiencing sewer flooding are proactive, timely, clear and tailored to the customer’s circumstances and communication preferences.
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- Do you agree with our proposal for introducing a minimum expectation relating to proactive, timely and tailored communication?
- Are there any further considerations, evidence or practical examples you would highlight? For example:
- Are the expectations sufficiently clear on what constitutes effective communication at different stages of the customer journey?
- Are there any specific circumstances (for example, delays or complex incidents) where further clarity would improve consistency of outcomes?
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- Companies should publish their response time policies and attend sewer flooding incidents promptly, with response arrangements reflecting the urgency and potential impact on customers.
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- Do you agree with our proposal for introducing a minimum expectation relating to response times and transparency?
- Are there any further considerations, evidence or practical examples you would highlight? For example:
- Do you consider the proposed benchmarks and prioritisation approach are appropriate and achievable in practice?
- Are there any implementation challenges or unintended consequences associated with the proposed approach?
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- Companies should provide and clearly communicate a minimum clean‑up service following sewer flooding incidents. Companies should ensure that customers understand what clean‑up support will be provided, what is excluded, when clean‑up is expected to begin, and the timescales within which support is expected to be delivered.
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- Do you agree with our proposal to introduce a minimum expectation relating to clean‑up support and transparency?
- Are there any further considerations, evidence or practical examples you would highlight? For example:
- Are the expectations sufficiently clear on timing, scope and communication of clean‑up services?
- Are there additional factors (for example, interaction with insurance or third‑party providers) that should be more explicitly addressed?
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- Companies should proactively identify customers at high risk of harm
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- Do you agree with our proposal to introduce a minimum expectation relating to proactively identifying customers at high risk of harm?
- Are there any further considerations, evidence or practical examples you would highlight? For example:
- Do the framework and minimum factors provide sufficient clarity to support consistent application in practice?
- Are there any practical challenges in implementing this approach, including in relation to data, systems or staff capability?
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- Companies should use a 5-year definition of repeat incidents for the purposes of tracking repeat incidents and determining the level of support provided to customers.
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- Do you agree with our proposal to introduce a minimum expectation relating to the use of a consistent definition of repeat incidents?
- Are there any further considerations, evidence or practical examples you would highlight? For example:
- Do you consider the proposed five‑year timeframe is appropriate and proportionate?
- Are there any practical challenges in applying this definition consistently across systems, performance management and reporting?
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- Companies should provide customers at high risk of harm with an appropriate level of tailored support that is designed to reduce the risk of potential harm
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- Do you agree with our proposal to introduce a minimum expectation relating to providing tailored support to customers at high risk of harm?
- Are there any further considerations, evidence or practical examples you would highlight? For example:
- Do the examples of support provide sufficient clarity on the level and type of support expected?
- Are there additional support measures or approaches that should be reflected to improve customer outcomes?
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- Companies should have governance arrangements that ensure that the customer impacts of sewer flooding incidents are appropriately considered, prioritised and scrutinised.
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- Do you agree with our proposal to introduce a minimum expectation relating to governance, accountability and oversight?
- Are there any further considerations, evidence or practical examples you would highlight? For example:
- Do the expectations strike the right balance between setting clear outcomes and allowing flexibility in governance structures?
- Are there additional governance or escalation practices that would strengthen delivery against this expectation?
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- Companies should ensure learning from customer experiences is embedded with company processes and is applied in order to continuously improve customer outcomes.
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- Do you agree with our proposal to introduce a minimum expectation relating to embedding learning and continuous improvement?
- Are there any further considerations, evidence or practical examples you would highlight? For example:
- Are the expectations sufficiently clear on how customer insight, complaints and case reviews should inform decision‑making?
- Are there additional assurance or monitoring mechanisms that would strengthen continuous improvement in practice?
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We encourage respondents to provide evidence, practical examples and views on the aspects of the draft guidance and proposed minimum expectations most relevant to their role, expertise or experience.
We encourage responses to be submitted via our consultation platform: https://consult.ofwat.gov.uk.
However, you can also respond by email to customerfocus@ofwat.gov.uk or post to:
Consultation response
Ofwat
Centre City Tower
7 Hill Street
Birmingham B5 4UA
If you intend to respond by email, please include the subject line: “Consultation Response – Licence Condition G Sewer Flooding Guidance”.
The closing date for this consultation is 21 September 2026.
If you wish to discuss any aspect of this consultation, please email customerfocus@ofwat.gov.uk.
We intend to publish responses to this consultation on our consultation platform. Subject to the following, by providing a response to this consultation you are deemed to consent to its publication.
If you think that any of the information in your response should not be disclosed (for example, because you consider it to be commercially sensitive), an automatic or generalised confidentiality disclaimer will not, of itself, be regarded as sufficient. You should identify specific information and explain in each case why it should not be disclosed and provide a redacted version of your response, which we will consider when deciding what information to publish. At a minimum, we would expect to publish the name of all organisations that provide a written response, even where there are legitimate reasons why the contents of those written responses remain confidential.
In relation to personal data, you have the right to object to our publication of the personal information that you disclose to us in submitting your response (for example, your name or contact details). If you do not want us to publish specific personal information that would enable you to be identified, our privacy policy explains the basis on which you can object to its processing and provides further information on how we process personal data.
In addition to our ability to disclose information pursuant to the Water Industry Act 1991, information provided in response to this consultation, including personal data, may be published or disclosed in accordance with legislation on access to information – primarily the Freedom of Information Act 2000 (FoIA), the Environmental Information Regulations 2004 (EIR) and applicable data protection laws.
Please be aware that, under the FoIA and the EIR, there are statutory Codes of Practice which deal, among other things, with obligations of confidence. If we receive a request for disclosure of information which you have asked us not to disclose, we will take full account of your explanation, but we cannot give an assurance that we can maintain confidentiality in all circumstances.
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