PUC Revises Recently Approved Rule Language Which Would Have Required Customer's Signature For All Enrollments (Including Telephone, Large C&I)

April 29, 2026

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Copyright 2026 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

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Granting in part a rehearing request from the Retail Energy Supply Association, the PUC of Ohio has revised recently approved rule language which would have required all enrollments, regardless of enrollment method (including telesales) and regardless of customer type (including large C&Is), to include a signed statement from the customer acknowledging that the retail energy supplier had verified the customer's identity at the time of enrollment

The rule language concerns implementation of a form of enroll-by-wallet, in which a retail supplier may enroll a customer by verifying the customer's identity, using one of the three options below to verify such (electric rule quoted, similar language was adopted for gas):

(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 [retail electric] provider to establish the customer's identity accurately

The process generally allows a retail supplier to use a customer's approved ID as authorization for the supplier to obtain, for the purposes of enrollment, the customer's account number from a utility's eligible customer list, and to then enroll the customer using such account number

Further, under PUCO's prior order, suppliers were ordered to obtain a customer's signature acknowledging that the supplier verified the customer's identity

Specifically, the following rule language had been approved by PUCO: "CRES [retail electric] 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." Similar language was approved for the gas rules

EnergyChoiceMatters.com was first to report that this broad new requirement was ostensibly applicable to all retail energy sales due to where the language was included in the rules. The new language was included in a section of rules not specific to enrollments performed via a certain marketing method (e.g. door to door) or to enrollments of only certain customer types (e.g. small volume).

RESA sought rehearing of the customer signature requirement, both generally, and with respect to sales that typically do not involve a customer signature (i.e. telesales, etc.)

PUCO granted rehearing in part, with PUCO limiting the customer signature requirement for the acknowledgment of the identity verification to, "direct solicitation."

The customer signature requirement for the acknowledgment of the identity verification will not be required for telesales or internet enrollments

However, PUCO stressed that it is appropriate to maintain the customer signature requirement, for the acknowledgment of the identity verification, for direct solicitations, declining a request to eliminate the requirement entirely for such sales

While only direct solicitations will require a customer signature of the acknowledgment of the identity verification, retail suppliers will, for all sales, be required to maintain proof of identity verification

The following language will apply only to direct solicitations: "Where enrollment occurs by direct solicitation, as proof of verification required under subsection (D) of this rule, 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 subsections (D)(1), (D)(2), and (D)(3) of this rule was used for verification." [similar language approved for gas]

PUCO said, "It is wholly reasonable and within the Commission’s discretion for us to establish rules to require CRES [electric] and CRNGS [gas] providers to maintain proof of verification and, specifically for direct solicitation, the type of proof of verification that is acceptable, all of which gives further guidance to and aligns with the existing record keeping and record retention rules in Ohio Adm.Code 4901:1-21-04 and 4901:1-29-04. Otherwise, enforcement of this statutory provision may be rendered unclear and less predictable."

RESA also objected to PUCO's prior order which required retail suppliers to use the utility's most recent customer list when relying on the customer list to enroll the customer (using the customer list for the account number when the customer provides proof of identity via an alternative mechanism such as a government ID). RESA cited the costs of obtaining an updated customer list for every enrollment

PUCO granted rehearing in part, allowing the use of less recent customer lists at certain utilities

Specifically, PUCO ordered that retail suppliers must use for enrollment a customer list updated within the past 12 months, "unless otherwise stated in the applicable utility’s tariff". [emphasis added]

Certain utility tariffs require that suppliers use the most recent customer list, with PUCO ordering that suppliers must follow such tariff provisions at such utilities, rather than the generally permitted 12-month time period

For example, AEP Ohio’s tariff states that, "[t]he [customer] list will be updated monthly and once the list has been updated, a CRES Provider, or other registered party must use the most current Customer Information List to contact customers."

"[T]he Commission expects a CRES provider, in this example, to use the most current eligible-customer list, as stated in AEP Ohio’s tariff," PUCO said

PUCO denied RESA's rehearing request which had sought further guidance from PUCO on alternative forms of IDs acceptable for identity verification for enrollment. As noted in (D)(3) listed above, a "sufficient alternative" form of identification may be used by a retail provider to establish the customer's identity

PUCO in its prior order did not list the forms of acceptable government-issued IDs, nor did PUCO adopt specifics governing the acceptable sufficient alternative forms of identification.

However, PUCO in the prior order 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."

PUCO on rehearing declined to expand on what may be used as an alternative form of ID or to revisit this issue

While PUCO on rehearing has approved revisions to the final rule language, the revised 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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