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PUC Adopts Modified Rule Language Which Now Says Retail Suppliers Must Obtain Customer "Signature" For ALL Enrollments
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The PUC of Ohio has adopted new rules governing, among other things, retail supplier enrollments, including verification of the customer's identity, with the revised rules, as stated in the adopted rule language notwithstanding PUCO's apparent intent articulated in its narrative order, now requiring that retail suppliers shall obtain a customer's "signature" prior to all enrollments
The new rules require retail electric and gas suppliers to verify a customer's identity at the time of enrollment
In language which was not included in the proposed rules, PUCO has adopted language requiring suppliers to demonstrate compliance with the identity verification requirement by obtaining the customer's "signature" affirming that verification occurred
The proposed rules did not include a requirement that the supplier obtain the customer's "signature" affirming that verification occurred
Specifically, for electricity, PUCO adopted language stating, "CRES providers must verify customer's identity at the time of enrollment. As proof of verification, CRES providers must obtain the customer’s signature acknowledging such verification occurred and must indicate which of the three types of forms of identification acceptable under subsection (D)(1), (D)(2), or (D)(3) of this rule was used for verification."
Such three forms of identity verification are:
(D)(1) "Customer account information," as that term is defined in division (A) of section
4928.103 of the Revised Code [Ed. note: 4928.103 states that "customer account information" means a unique electric distribution utility number or other customer identification number used by the utility to identify a customer and the customer's account record];
(D)(2) A valid form of government-issued identification issued to the customer; or
(D)(3) A sufficient alternative form of identification that allows the CRES provider to establish
the customer's identity accurately
Similar language was adopted for natural gas enrollments
PUCO in an order said that the signature requirement for identity verification would apply to "direct solicitation", with PUCO further stating, "including but not necessarily limited to
door and kiosk customer interaction".
However, as can be seen in the rule language quoted above, nothing in the language itself limits the signature requirement to direct solicitations
Moreover, the rule language is not housed under the section of the rule governing, "mailings, facsimiles, and direct solicitation." Rather, this signature requirement language is located in a broadly applicable part of the rule governing all enrollments (the signature language isn't even, for example, included under the rules applicable only to residential and small commercial customers, but is rather housed in a broader section of the rule)
The proposed rule changes had also served as a forum to address a current requirement which PUCO Staff has interpreted as requiring that the customer must state their account number during a TPV for a telephonic sale (or a sale which must comply with the telephonic sale rules)
For electricity, the current rules provide that the TPV for telesales must include, "If applicable, a verbal request for and the customer's provision of the customer's electric utility
account number."
The current gas rules include similar language, but not the "If applicable" qualifier.
PUCO Staff interprets the existing language under this rule as requiring that the customer must verbally answer by providing (reciting) their account number during the verification. The reading by the verifier of the customer's account number back to the customer for a Yes/No answer does not comply with existing rule, PUCO Staff has said
Other than harmonizing the electric and gas rule (discussed as follows), PUCO did not revise the verbal account number language in response to comments from retail suppliers
However, PUCO did clarify that the request for, and the customer's statement of, the customer's account number is only required "if applicable" (with the term account number updated in the revised rule to be "customer account information" per statute, but which is still essentially an ID number unique to the customer)
PUCO said that if the customer verifies their identity via a valid form
of government-issued ID (which the supplier may now use for enrollment, with the customer account information [number] then obtained from the eligible customer list as further discussed below), then the customer does not need to recite their customer account information on the telesales TPV (the rule newly requires that customer account information shall be included on the ECL)
However, if the customer's identity is established via the provision by the customer of customer account information, then the TPV for telesales must include the customer verbally providing the customer account information
PUCO did modify the gas telesales TPV rule to add language stating that the verbal provision by the customer of customer account information is only required, "if applicable" (previously, only the electric rule included the "if applicable" qualifier)
The adopted rules implement HB 15 of 2025, which provides that customers are not required to provide customer account information to enroll with a retail supplier, to the extent that the customer provides a valid form of government-issued identification or a sufficient alternative form of identification
Under the process established by the rules, customers may enroll without the customer providing to the supplier an account or similar number (now called customer account information) if the customer presents a valid form of government-issued identification or a sufficient alternative form of identification
However, retail suppliers will still need to provide the utility with the customer account information in order to enroll the customer. The rules essentially allow retail suppliers to use a form of ID described above for enrollment and customer identification purposes, with the suppliers then obtaining the customer's account information (number) from the utilities' eligible customer lists. As such, the process is a form of enroll by wallet insofar as the customer does not need to be in possession of their customer account information in order to enroll
While retail suppliers opposed still having to obtain customer account information (either from the customer or the ECL) and having to provide such to the utility for enrollment, PUCO said that HB 15 only provides that customers shall not be required to provide their customer account information for enrollment, but does not provide that suppliers shall not be required to provide customer account information for enrollment
The rules do include language stating that a utility’s tariff may
authorize the use of alternative information (other than customer account information) for enrollment purposes, but no such tariffs exist currently.
PUCO in the final rule does not list the forms of acceptable government-issued IDs, nor does PUCO adopt specifics governing the acceptable sufficient alternative forms of identification
However, PUCO did state that, with respect to sufficient alternative forms of identification, "we would envision a 'sufficient
alternative form of identification' would, at the very least, contain a customer’s name and
address."
Retail Supplier Financial Security
The new rules also implement the financial security requirements of HB 15
In the final rules, utilities are authorized to set "reasonable standards" that require retail suppliers to maintain financial assurances sufficient to protect customers and utilities from default. The rules explicitly exclude brokers and aggregators from these financial assurance requirements
The final rule does not include specific or prescriptive minimums, or limits, for the financial assurance required from retail suppliers
PUCO said that parameters for the financial assurance requirements will be included in utility tariffs, with retail suppliers able to raise any concerns when such tariffs are considered by PUCO
PUCO did state that PUCO, "sees the benefit of transparent collateral amount calculation formulas as well
as delineated frameworks for the timing of reviews and adjustments of collateral amounts," but PUCO did not adopt any prescriptive requirements for the utility tariff filings
While PUCO has adopted final rule language, the rules, under the customary process, remain subject to review by the Joint Committee on Agency Rule Review. An effective date would be established after JCARR review, though PUCO would establish the effective date to be the "earliest date permitted" upon conclusion of the JCARR process
Case 25-729-GE-ORD, 25-0729-GE-ORD
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PUC Clarifies That Customer Must Only Provide Account Number During TPV "If Applicable", Not Required If Customer Identity Verified Though Alternative Means
New Authority For Utilities To Impose Financial Standards On Retail Suppliers
March 4, 2026
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Copyright 2026 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
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