Recommendation 7: “Bill payment insurance”

Recommendation 7: “Bill payment insurance”

Tracking of the implementation of the recommendation : From the end of 2016, these 4 recommendations have been implemented and the general terms and conditions of the offer were adjusted.

1. “Inform customers who have taken out payment protection insurance that if they are not on a permanent employment contract this service will not be provided if they lose their job. ”

Observation: When a customer takes out payment protection insurance he benefits among other things from payment of his bills if he loses his job. However, this is subject to certain conditions, in particular that of being on a permanent employment contract for at least one year. Claimants in mediation said they were not aware of this condition.


Recommendation: Customers must be on a permanent employment contract if they wish to benefit from payment protection insurance in respect of job loss, but this is not a condition for other cases (disability, etc.). The script issued to customer advisers mentions this criterion in addition to those already indicated. Furthermore, they must tell the customer that if he takes out a contract while on a fixed-term employment contract, he will not benefit from this service if he loses his job.

2. “Modify the wording concerning the subscription for payment protection insurance on the annual adjusting bill of customers on monthly payments. ”

Observation: On the annual adjusting bill there is a line concerning the payment protection insurance offer, which can be construed as payment for the past 10 months and thus as a payment ex post facto. But this line in fact indicates the annual adjustment of the payments already made in the ten direct debits for the “payment protection insurance” subscription. The wording is unclear.


Recommendation: We recommend changing the wording on the annual adjusting bill and state that the ten direct debits have already been made.

3. “Tell the customer that he loses his right to payment protection insurance if he has not paid his subscription within X days of receiving the letter of reminder. ”


Observation: For customers on monthly payments, the direct debits of energy consumption include the subscription for payment protection insurance. If a direct debit is refused by the bank, several refusals can take place before the supplier notifies customers of a change of billing method and sends a letter of reminder. In the meantime, the customer has not received a formal notice and can benefit from the payment protection insurance offer, as he is assumed to have paid the subscription. For the ENGIE Group’s Mediator, as the supplier did not send a reminder specifically concerning this customer service, it cannot claim that the customer has not paid his subscriptions. The fact is that the customer did not receive any reminders to regularize his situation.


Recommendation: The ENGIE Group’s Mediator considers that the customer can only be notified of losing his rights if he has received a reminder, specifying in particular that he risks losing his right to payment protection insurance, X days from receipt of this letter for instance, and that he has not paid after receiving this document within Y days. The process of declaring rights to compensation must be adapted accordingly.

4.“Insert a line itemizing the amount debited for payment protection insurance when the customer is on monthly payments. ”

Observation: The monthly payment plan does not itemize the amount paid for payment protection insurance.


Recommendation: The ENGIE Group’s Mediator recommends that the monthly payment plan specifies that the monthly payments include not just the energy supplies consumed and the standing charge but also the monthly subscription to payment protection insurance. In this way the customer clearly understands that his insurance subscriptions are debited monthly as part of his monthly payments, and that failure to make a monthly payment entails non-payment of the subscription. That does not preclude the debt collection and formal notice process for all that, and does not mean that the insurer can be notified of the loss of cover on the first non-payment of a monthly payment (see observation no. 13).

Addressee: France BtoC


Reason: Billing & consumption



From mid-2016, these recommendations were already partially implemented.