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Sector · Energy & utilities

Energy & utilities: let AI answer the customer line. A person takes the hard calls.

Early Customer Program

Last reviewed: 25 October 2026

Energy customers call about money and continuity: what they will pay, whether they can leave, whether they can pay later, whether the supply stays on. An AI agent will hear all four, and each one is regulated: a price change needs advance notice, switching has deadlines, and a household facing disconnection must be told the alternatives in good time. Audact checks supported AI responses against your published tariffs, contract terms and hand-over rules before they reach the customer, sends disconnection and hardship questions to a person, and records each decision. Voice first. Chat and email next, on the same rules.

What the law requires

A person interacting with an AI system must be told so, unless it is obvious from the circumstances.
Regulation (EU) 2024/1689, Art. 50(1)
What an agent tells a household customer on the supplier's behalf is the supplier's commercial practice, and it must not mislead.
Directive 2005/29/EC, Art. 2(b), 3(1) and 6
Customers get a summary of the key contract terms, direct notice of a price change at least two weeks before it applies (one month for household customers), and the right to leave if they do not accept new terms.
Directive (EU) 2019/944, Art. 10(3) and 10(4)
Within the terms of the contract, a customer can switch supplier within three weeks of the request, and household customers and small businesses pay no switching fee. Where national law allows it, ending a fixed-term, fixed-price contract early can carry a fee, if it was clearly communicated beforehand and stays within the supplier's direct loss.
Directive (EU) 2019/944, Art. 12(1), 12(2) and 12(3)
Before a planned disconnection, household customers are told in good time about the alternatives, such as sources of support, payment plans or debt advice.
Directive (EU) 2019/944, Art. 10(11)
Member States protect vulnerable customers, a concept that can include critical dependence on electrical equipment for health reasons, and must shield vulnerable and energy-poor customers from disconnection.
Directive (EU) 2019/944, Art. 28(1) and Art. 28a, inserted by Directive (EU) 2024/1711
Health information, such as dependence on medical equipment, is special-category data, and a decision with significant effects may not rest on automated processing alone, save for narrow exceptions.
Regulation (EU) 2016/679, Art. 9(1) and Art. 22(1)
Breaching Article 50 carries a ceiling of €15 million or 3% of worldwide annual turnover; for SMEs and start-ups it is the lower of the two.
Regulation (EU) 2024/1689, Art. 99(4) and Art. 99(6); Commission guidelines C(2026)5054, point (152)

What Audact does about it

Tariff, price and outage statements: a supported reply is checked against what you have published before the customer hears it.
In controlled testing
The check covers supported replies and runs within an evaluation window. If it does not answer in time, the original reply is released unchanged and a FAIL_OPEN event records the miss.
In controlled testing
Contract terms, switching and exit fees: checked against the terms you approved.
In controlled testing
Payment arrangements: a supported reply that agrees a plan on the spot is held back, and the request goes to a person.
In controlled testing
Disconnection, hardship and medical-need questions routed to a person while the call runs.
In controlled testing
Vulnerable-customer handling: pace and routing change when a caller shows distress or confusion, and the call goes to a person.
In development
The Article 50 disclosure, spoken at the start of the call.
In controlled testing
A tamper-evident receipt per governed interaction.
Working today
AI chat replies under the same rules.
In controlled testing
AI-written customer emails under the same rules, before they are sent.
In controlled testing

The calls with consequences

Six questions an energy customer line hears every week.

Each one comes with a draft that sounds helpful and a rule that keeps the answer right. The table shows both, and what the customer hears in the end.

  • The customer asks
    “What will I pay per kWh next year?”
    The model drafts
    “Your rate stays at 28 cents for the whole of next year.”
    Your rule
    Tariffs: state only the rate in force, with its date. Future prices come in writing.
    The customer hears
    “Your current rate is on your contract summary. A change is always announced to you in writing before it applies.”
  • The customer asks
    “If I switch to another supplier now, do I pay anything?”
    The model drafts
    “No, leaving is always free.”
    Your rule
    Switching and exit fees: answer only from the customer's contract terms.
    The customer hears
    “Switching itself costs nothing. Whether an early-exit fee applies to your fixed-term contract, our contract team will confirm.”
  • The customer asks
    “I can't pay this month. Can I pay in three parts?”
    The model drafts
    “Sure, I've set up three monthly payments for you.”
    Your rule
    Payment arrangements: explain the options, pass the request to a named team, never agree a plan on the call.
    The customer hears
    “I can't agree a plan on this call, but I've passed your request to our team. They will call you back to work one out.”
  • The customer asks
    “My husband needs his oxygen machine. Are you going to cut us off?”
    The model drafts
    “If the balance isn't paid by Friday, supply may be suspended.”
    Your rule
    Disconnection, medical equipment or hardship: hand over to a person at once and ask nothing further.
    The customer hears
    “I'm putting you through to a colleague now.”
  • The customer asks
    “The power's out. When will it be back?”
    The model drafts
    “It'll be back within the hour.”
    Your rule
    Outages: share only the published status and estimate; never invent a restoration time.
    The customer hears
    “There's a reported fault in your area. The latest estimate is on the outage page; I can't give you a time beyond that.”
  • The customer asks
    “I'm moving on the 1st. Can you move my contract?”
    The model drafts
    “Done, your contract moves with you on the 1st.”
    Your rule
    Moves and contract changes: take the request; the change counts once it is confirmed in writing.
    The customer hears
    “I've noted your move for the 1st and passed it to our team. It's arranged once you have their written confirmation.”

Illustrative scenario with fictional rules; no customer deployment implied. A check applies only where the governed workflow routes the response through it.

Your rules

What Audact checks before a reply reaches the customer.

You set the rules, and Audact checks the reply against them in the response path, not only in a prompt. A prompt is a request, and a request can be argued with.

The tariff, the contract change and the payment plan stay where they are today: in your systems, with your team. Audact checks what the agent says; it does not change a contract or agree a plan.

  • Tariffs and prices: the rate in force, with its date, and no forecast.
  • Contract terms: notice periods, fixed terms, exit fees and the right to leave after a price change, in your approved wording.
  • Switching: what the contract and the law give the customer, stated as it is.
  • Payment arrangements: options explained and requests passed on; no plan agreed by the agent.
  • Disconnection, hardship and medical need: an immediate hand-over to a person.
  • Outages: the published status and estimate, nothing more.
  • Words your rules exclude, such as threats, pressure to pay or deadlines the agent has no authority to set.

Where it pays off first

Four places an energy agent earns its keep.

  • Inbound customer lines: bills explained, tariff and contract questions, moving home. Answered within your published terms.
  • Outage peaks: when the lines light up after a fault, the agent gives the published status and takes the details, so your team's time goes to the calls that need a person.
  • After hours: the line keeps answering, and a disconnection, hardship or medical question goes to the person on duty or becomes a call-back first thing.
  • Call-backs the customer asked for: about a bill, a move or a payment plan, under the same rules as an inbound call.

What goes to a person

Where the agent stops and your team takes over.

A hand-over is a rule like any other: the reply is held back, the reason is recorded, and the customer hears the next step you approved.

  • Any question about disconnection, a prepayment meter or a cut-off date.
  • Payment difficulty, arrears or a request for a payment plan.
  • Medical equipment, illness, age or another vulnerability the caller mentions.
  • A bereavement, and the account that goes with it.
  • A complaint, or a dispute about a bill or a meter reading.
  • A customer who asks for a person.

The record

A record of each decision, not a transcript.

Every check that answers in time leaves a receipt: whether the reply was allowed, modified or blocked, with the input and the output stored as hashes rather than words.

The receipt is tamper-evident. It shows that the record is intact: a later change or reordering is detectable by recomputation against a retained commitment. It carries an HMAC-SHA256 code under a symmetric key held by Audact, so whoever can check it can also produce it: an authentication code, not a signature. It does not establish who issued it, and whether the underlying event is true. Three of its values can be recomputed without a key: the input hash, the output hash and the hash of the preceding evidence event.

Whether a payment plan was agreed or a contract moved is established by the system that did it, not by the receipt. You can recompute a sample receipt in your own browser.

The law, in short

Article 50 already applies. Energy has its own consumer layer on top.

Article 50 of the AI Act has applied since 2 August 2026: a customer must be told they are speaking to an AI system, unless that is obvious. It is a transparency duty, not a ban.

For electricity, Directive (EU) 2019/944 adds the sector layer: contract information, notice of price changes, switching, alternatives to disconnection and protection for vulnerable customers. Gas customers have comparable rules under Directive (EU) 2024/1788, and water supply is governed nationally. These are directives, so the operative text is the national law, with the regulator's rules on top. General information, not legal advice.

Questions

Can the agent quote a tariff?
It can state the tariff in force, with its date, in the wording you approved. A supported reply with a forecast, or a promise that a rate will hold, is held back before it is spoken: price changes follow the notice rules in your contract terms.
Can the agent agree a payment arrangement?
Not under the rules on this page. It explains the options you approved and passes the request to a named team, and a supported reply that agrees a plan on the spot is held back. The decision stays with a person, so it does not rest on automated processing alone (Article 22 GDPR).
What happens when a caller mentions medical equipment or says they cannot pay?
The call goes to a person. A rule sends disconnection, hardship and medical-need questions to your team while the call runs. Health details are special-category data under Article 9 GDPR, so the agent's job is to reach a person quickly, not to take a history. Recognising distress from how someone speaks is in development.
Is a customer-service agent a high-risk AI system?
Annex III, point 2 of the AI Act makes AI used as a safety component in the supply of water, gas, heating or electricity high-risk. An agent that answers customers and hands calls to a person is not designed as a safety component of the supply. Classification follows the intended purpose of your deployment, so confirm it with counsel.
How do we start?
With one workflow: one customer line, one rule set, one team to hand over to. A utility can come in through an agency or answering service, or directly with an enterprise pilot. Netherlands and Flanders (BE): intake open. Germany and Austria: intake is a conversation and not a start date.

How a governed call runs

From the caller's question to the recorded decision in six steps, including the moment a request goes to a person.

See Governed Voice AI

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