NERC Customer Protection Regulations 2023
Letter of complaint for a high electricity bill — to your DisCo, with the NERC deadlines
Short answer. The letter is already open below: add your account number and the bills you dispute, and send it to your DisCo's complaints unit. Complain to the DisCo first: To its Customer Complaints Unit — by letter, e-mail, phone, SMS or portal; complaint must be traceable (NERC Customer Protection Regulations 2023, s.43(4)–(5)).
- Meter complaint: DisCo must visit to test the meter (3 working days, s.59): type the date
- Complaint resolved — general rule (no later than 15 days, s.43(7)): type the date
- Bill reconciliation or meter accuracy — within one billing cycle of one month (s.43(7)): type the date
- Maximum period ends — you can refer the complaint to the NERC Forum Office (30 days, s.43(8)–(9)): type the date
Working days: Monday to Friday; public holidays are not deducted. Check your own case.
The Regulations give 15 days, or one billing cycle of one month for bill and meter disputes; the DisCo may extend by no more than 15 days, in writing with reasons (s.43(8)), and after the maximum 30 days you can go to the Forum (s.43(9)). The Forum's own clock starts when it receives your complaint: acknowledgement within 3 working days, decision within 2 months (ss. 49(2), 50(2)). Enter the Forum's decision date to count the 10 working days for an appeal to NERC (s.52(1)).
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Bring numbers, not just anger: the bill, your last 12 bills and a photo of the meter. The 12-month average is your fair payment while they review.
Write down the date the complaints unit received your letter. The Forum will ask when your 30 days started.
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Deadlines
The rules, with the source
| What | Deadline | Source |
|---|---|---|
| Complain to the DisCo first | To its Customer Complaints Unit — by letter, e-mail, phone, SMS or portal; complaint must be traceable | NERC Customer Protection Regulations 2023, s.43(4)–(5) |
| Bill review on your request | DisCo must review; meanwhile you pay the average of your bills for the previous 12 months | s.36(1)–(2) |
| No meter | Bill only on an estimate by a method approved by NERC | s.35 |
| Overcharge found | DisCo tells you in writing within 5 working days and credits the exact amount to your next bill | s.36(7) |
| DisCo resolves the complaint | No later than 15 days; bill reconciliation and meter accuracy — within one billing cycle of one month; extension up to 15 days in writing | s.43(7)–(8) |
| No disconnection while you dispute | Not for non-payment of a billed amount you have complained about, while the complaint is unresolved; compensation in energy credits if wrongly disconnected | ss. 25(1)(c), 26 |
| Meter test | Visit within 3 working days of your report; resolution within 5 working days of the visit | s.59 |
| NERC Forum Office | After the maximum 30 days; acknowledgement in 3 working days, decision within 2 months | ss. 43(9), 49(2), 50(2) |
| Appeal to NERC | Within 10 working days of the Forum's decision | s.52(1) |
The NERC Customer Protection Regulations 2023 (NERC-R-001-2023) replaced the old Customer Complaints Handling Standards and the Meter Reading and Billing Regulations. The Forum Office address must be printed on every DisCo bill.
Step by step
What to do, in order
1
Gather your bills
The disputed bill and your bills for the past 12 months. If you have a meter, photograph today's reading.
2
Work out the average
Add up the last 12 bills and divide by 12. That is what you pay while the review runs.
3
Send the letter to the complaints unit
By e-mail or the DisCo's portal, or by hand against an acknowledgement. Ask for a reference number.
4
Keep paying the average
The DisCo may not cut your supply over the disputed bill while your complaint is open.
5
Wait for the answer
15 days, or one billing month for bill and meter disputes; at most 30 days with a written extension.
6
Go to the NERC Forum
No fix after 30 days? Write to the Forum Office shown on your bill, with this letter and the DisCo's reply.
Questions
Is estimated billing illegal in Nigeria?
Not in itself. Without a meter, the DisCo may bill on an estimate, but only by a method approved by NERC, and NERC has capped estimated bills for unmetered customers on each feeder. If your bill is far above your usual one, ask for a review.
Do I have to pay the full bill while I complain?
No. During the review you pay the average of your previous 12 months' bills. If the review finds the bill correct, you pay the balance or ask for a meter test.
Can the DisCo disconnect me while my complaint is open?
Not for non-payment of the bill you have complained about while the complaint is unresolved. If they do, you are entitled to compensation in energy credits for each day of wrongful disconnection.
Official sources
Other documents
Keep the papers in one place
Letters, receipts and notices in one folder you can share with family or a lawyer. The templates and the editor are free; Layers is free for up to 20 people.
This is a ready document and a deadline calculation, not legal advice.