The ICO fined Bluon Energy £105,000 for 194,379 unlawful marketing calls selling solar panel surveys. Its own notice spends ten pages tracing a suspiciously timed account transfer and a reseller's retracted answer to the regulator, then counts neither as aggravating.
Estimated reading time: 7 minutes
In short. On 4 November 2026 the ICO published a Monetary Penalty Notice fining Bluon Energy Ltd (BEL) £105,000 for instigating 194,379 unsolicited calls offering free solar panel surveys to numbers registered with the Telephone Preference Service [[1]]. The 29-page notice behind that fine records a Commissioner's office that spent nearly a year tracing the calls through three telecoms accounts, found a transfer of BEL's own numbers was proposed three weeks after BEL was first named to the investigation, and received information from a reseller that the Commissioner says it "only appeared to retract" after that reseller spoke to BEL [[2]], pages 16 to 17. None of that appears in the notice's own two-item list of what made the case worse, and the notice itself was not published until six days after its own payment deadline had passed [[2]], pages 25, 27 to 29. Three documented mistakes: four stars.
Bluon Energy Ltd, trading as Greentech Solar, Green Line Solar and Solar Diagnostics Checks, offered callers a free survey of their solar panels. Between 1 April 2024 and 30 April 2025 it instigated 194,379 such calls to numbers that had sat on the Telephone Preference Service register for more than 28 days, generating 61 complaints to the ICO and the TPS [[2]], page 19. "Bluon Energy Ltd was fined £105,000 for instigating 194,379 unsolicited live direct marketing calls between April 2024 and April 2025," the ICO's case page states, "to telephone numbers that had been registered with the Telephone Preference Service (TPS) for more than 28 days" [[1]]. BEL was incorporated on 21 April 2023, Companies House number 14820106, registered at Ideas House, Eastwood Close, London, with two directors, Mark Glen Lee and Charlie Lingwood [[2]], page 9.
The chase through three telecoms accounts
The Commissioner did not get a straight answer about who was calling. A third-party information notice (3PIN) went out on 7 June 2024 to establish who held the number behind the complaints; the response on 18 July named one company, a follow-up 3PIN on 30 July named Bluon Energy instead, and an invoice from the reseller to BEL followed [[2]], page 11. A further 3PIN in January 2025 produced yet another name, retracted in February, before the reseller finally confirmed on 15 April 2025 that "the payee records were held in the name of Bluon Energy Ltd" [[2]], page 12. A last 3PIN on 16 April 2025 brought call detail records and a plain statement from the reseller: "it looks like all these numbers are allocated to a Charlie Lingwood, and unfortunately this is all the information we have available to us with respect to end user details" [[2]], page 12. Screening those records against the TPS register is what produced the 194,379 figure. The notice records the finding plainly: "The Commissioner analysed the CDRs and screened the numbers against the TPS, showing that between April 2024 and April 2025, 194,379 calls to TPS-registered numbers were made from an account linked to Charlie Lingwood and paid for by BEL" [[2]], page 12.
Three explanations, and a transfer timed to the day
BEL's first response, in July 2025, was that it did not market at all: customers booked their own appointments, and because callers had supposedly already agreed to be contacted, "BEL did not screen against the TPS on the basis that express permission had been granted for the telephone number to be called before any call was made" [[2]], page 13. Asked to produce evidence that the 61 complainants had actually given that permission, "BEL provided no such evidence" [[2]], page 13.
The second explanation shifted responsibility elsewhere. BEL's legal representative told the Commissioner the telephone numbers "had been incorrectly added to its account by" the reseller, and that a former BEL employee's new company had been meant to take over BEL's handsets and numbers in an account transfer [[2]], page 15. The notice's own timeline undercuts the "incorrectly added" framing: the reseller first identified BEL as the account holder on 2 August 2024, and the transfer "was intended to take place on 22 August 2024, only 20 days after those subscriber details were provided to the Commissioner identifying BEL as the account holder" [[2]], page 17. The transfer never happened. The reseller told the Commissioner it only learned this when Charlie Lingwood later told it so [[2]], page 17, and separately, the Commissioner records that the reseller had "seemingly provided the Commissioner with incorrect information in response to a 3PIN" and "only appeared to retract this position following subsequent correspondence with BEL" [[2]], page 16.
The third explanation concerned the leads themselves. BEL paid a contractor, who it later described as a former employee, £29,581.35 between 16 February and 11 October 2024, then paid his successor company £41,270 for 327 prebooked leads between 26 September and 6 December 2024, a combined £70,851.35 flowing to the same lead source across most of the calling period [[2]], pages 17 to 18. Asked for contracts, due diligence or onboarding checks on either arrangement, BEL said there were none: no written agreement, no instruction to make calls on BEL's behalf, and "BEL did not perform any monitoring on" the contractor "once their services were engaged" [[2]], page 18.
What the notice counts as aggravating, and what it leaves out
Having built that ten-page account, the notice reaches its "Commissioner's decision to issue a monetary penalty" section and lists two aggravating features: that BEL breached regulation 24 by not identifying the calling company, and that "complainants state that calls were aggressive and persistent in nature" [[2]], page 25. "The Commissioner did not find any evidence of any mitigating features in this instance," it adds [[2]], page 25. The suspiciously timed transfer and the reseller's retracted information do not reappear anywhere after page 17.
The notice separately states: "The Commissioner does not consider that BEL deliberately set out to contravene PECR in this instance" [[2]], page 22, finding negligence instead. That conclusion is not tested against the transfer timed to within three weeks of BEL's exposure, the unevidenced "incorrectly added" claim, or the reseller's own retracted answer to a formal regulatory notice. The Commissioner does record, elsewhere, that the 194,379 calls were found to be BEL's "on the balance of probabilities" [[2]], page 19, so the fact-finding was not in doubt; it is the aggravating-factors and deliberateness sections that do not return to it.
Published after its own deadline had passed
The notice is dated 29 September 2026 and signed by Andy Curry, Head of Investigations [[2]], page 29. Full payment was due "by BACS transfer or cheque by 30 October 2026 at the latest," with a 20% discount to £84,000 available only "if the Commissioner receives full payment... by 29 October 2026" [[2]], pages 27 to 28. The ICO did not publish the case or the notice to the public until 4 November 2026 [[1]], six days after the standard deadline and seven after the discount window had already closed. The notice states its purpose is to "act as a general encouragement towards compliance with the law, or at least as a deterrent against non-compliance, on the part of all persons running businesses currently engaging in these practices" [[2]], page 26, a purpose aimed at businesses operating right now, none of which could see the notice, the fine or the discount it carried until after BEL's own clock on both had already run out.
Credit where due
The investigation itself was not a shortcut. Four rounds of third-party information notices over nearly a year, each time following up on an incomplete or shifting answer, produced the paper trail that let the Commissioner establish, on the balance of probabilities, that BEL's own account paid for all 194,379 calls [[2]], pages 11 to 12, 19. The Commissioner did not accept BEL's unevidenced "incorrectly added" account at face value, and did not let a proposed transfer that never completed close off the question of who was responsible. The investigation produced exactly the evidence the aggravating-factors and deliberateness sections would have needed to engage with. The gap is that, having done the work, the notice does not use it there.
The claims, tested
| The notice's own words | What the same notice's own fact-finding shows | Verdict |
|---|---|---|
| "The Commissioner did not find any evidence of any mitigating features in this instance," with two aggravating factors listed: an unidentified caller and aggressive, persistent calls [[2]], page 25 | The same notice records a reseller giving the regulator information it "only appeared to retract" and a transfer of BEL's numbers proposed 20 days after BEL was named to the investigation [[2]], pages 16 to 17 | Two narrow factors are counted as aggravating; conduct the notice's own fact-finding describes as evasive is not weighed either way |
| "The Commissioner does not consider that BEL deliberately set out to contravene PECR in this instance" [[2]], page 22 | BEL's account held the number used for all 194,379 calls, paid £70,851.35 to two successive contractors across most of the calling period, and a transfer of its numbers was proposed within three weeks of being named to the regulator [[2]], pages 12, 17 to 18 | The "not deliberate" finding is stated without returning to the notice's own strongest evidence of calculated evasion |
| A penalty should act as "a general encouragement towards compliance... on the part of all persons running businesses currently engaging in these practices" [[2]], page 26 | The notice, dated 29 September 2026 with a 30 October payment deadline, was not published to the public until 4 November 2026 [[1]][[2]], pages 27, 29 | Businesses the notice says it is meant to deter could not see it, or the 20% early-payment discount, until after BEL's own deadlines had already closed |
The mistakes, counted
Evasive conduct documented, then left out of the aggravating factors (1). Ten pages of the notice's own background section trace a reseller's retracted answer to a 3PIN and an account transfer proposed three weeks after BEL was named, and neither appears when the notice lists what made the case worse [[2]], pages 16 to 17, 25.
"Not deliberate" stated without testing it against that evidence (2). The finding that BEL did not deliberately set out to contravene PECR is not weighed against the suspiciously timed transfer or the reseller's retraction documented earlier in the same notice [[2]], page 22.
Published after its own deadlines had passed (3). The notice's standard and discounted payment deadlines, 30 and 29 October 2026, had both already elapsed by the time the ICO made the case public on 4 November 2026, cutting against the stated deterrent purpose for businesses currently operating [[1]][[2]], pages 27 to 28.
Verdict
Four stars, three documented mistakes. The underlying investigation was genuinely persistent: four rounds of third-party notices across nearly a year reconstructed who was behind 194,379 unlawful calls after BEL offered no evidence and a reseller gave the regulator information it had to walk back. The notice's own fact-finding is not the problem. The problem is that the sections meant to weigh seriousness and intent do not draw on it, and that the public could not check any of this until BEL's own payment clock had already run out.
The star score counts three documented mistakes. First, the notice's own ten-page account of a reseller's retracted answer to a regulatory notice and a suspiciously timed account transfer does not appear in its two-item list of aggravating factors. Second, the finding that BEL did not act deliberately is not tested against that same evidence. Third, the notice was not published to the public until six days after its own standard payment deadline, and seven days after its discounted one, had already passed. Three falls in the 1 to 3 band: four stars; the bands are on the ratings page. This piece makes no finding about the conduct of any named individual beyond what the ICO's own published notice already states; the reseller and contractors referred to here are not named because the notice itself redacts them. All sources below were fetched directly on 7 November 2026 and returned HTTP 200; the Monetary Penalty Notice was checked with a full-text extraction of all 29 pages.
Sources
- Bluon Energy Ltd, ICO enforcement action page, published 4 November 2026
- Monetary Penalty Notice: Bluon Energy Ltd, Information Commissioner's Office, dated 29 September 2026, published 4 November 2026