What’s the Proper Procedure for Disconnection of Electricity Supply to Customers?

According to the provisions of the Customer Protection Regulations 2023 (“the CPR”), certain conditions must be met before a customer can be disconnected from electricity supply. A prepaid electricity meter is designed to manage and control the consumption of electricity before the customer uses it. Once the credit is exhausted, the meter automatically triggers a disconnection mechanism by opening a relay of switch built into the meter, which physically interrupts the electrical circuit and stops the flow of electricity into the customer’s premises. As a child of the 70s, I grew up with postpaid electricity meters around me and I can still recall NEPA staff quietly walking into our premises to read their meters. But these are the days of prepaid meters, especially for residential and small power users. Prepaid metered customers are not really concerned about the provisions we are about to review. The only time prepaid metered customers may be disconnected from electricity supply by the Electricity Distribution Company (“DisCo”) is when they engage in revenue threatening protection activities, like meter bypass or tampering.

The following are conditions outlined in the CPR where a DisCo can disconnect electricity supply to a postpaid metered or unmetered customers –

1. DisCos may disconnect supply to a customer’s premises when the customer fails to pay the amount billed by the payment date stated in the DisCo’s bill or breaches other terms and conditions agreed by the DisCo – Section 20(1) of the CPR.
2. The payment date must be clearly stated on the bill – Section 20(2)(a) of the CPR.
3. The payment date must be at least 10 days from the date of the delivery of the bill to the customer. Please note that the payment or due date for the bill is computed from the date the bill is delivered to the customer’s premises and it includes weekends. The date of bill delivery for one premises cannot be used to compute the timeline for another premises. In this regard, DisCo marketers need to maintain an accurate record of the date that bills were delivered per customer.
4. Bills may be delivered physically to the customer’s premises or by some other electronic means, including text messages or mail, as agreed by the customer – Section 20(2)(b) of the CPR. If bills are to be delivered through electronic channels to the customer, it is important for the DisCo to be able to furnish proof that the customer consented to his bills being delivered in the specified electronic format. Simply utilizing the customer’s data as provided in the DisCo’s application for supply form filled out by the customer shall not suffice in this regard. There has to be written proof that indicates that the customer accepted that his bills shall be delivered electronically.  
5. The period between the payment date and the date of scheduled disconnection for non-payment is not less than 2 working days after the payment date – Section 20(2)(c) of the CPR. For example, if the payment date falls on a Friday, the 2 working days after the 10 days is of course the subsequent Tuesday. The non-paying customer can be disconnected from supply by Wednesday.  
6. The DisCo must verify from its records that payment has not been made by the customer –  Section 20(2)(d) of the CPR. Oftentimes, DisCos rely on the customer to furnish them with proof of payment. However, the Regulation clearly states that the burden is on the DisCo to verify from our records whether the customer has paid his bill or not. 
7. Any bill correcting a previous inaccurate bill shall have a payment date which is at least 10 working days from the date of delivery of the corrected bill to the customer – Section 20(2)(b) of the CPR. The customer must be given an opportunity to prepare for any updated or revised bill no matter how minor the revision contained in the revised bill. DisCos cannot rely on their earlier notice to compute the customer’s due date.