Energy Licensing Compliance Guide
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Natural Gas Agent, Aggregator, and Broker Registration

Learn about registration requirements for natural gas supply intermediaries.

Click on a state to read about detailed license requirements in that state.
31 States Have Limited or No Natural Gas Choice Programs
10 States Have Natural Gas Choice Programs but no License Requirement for Agents
9 States (and D.C.) Require Natural Gas Agent Licensure

About Registration

Businesses that act as intermediaries between natural gas supply companies and commercial or residential customers are often required to register with the public utilities commission. These intermediaries can fill a variety of roles within the energy supply industry.

Natural gas agents and brokers facilitate the purchase of a supply of natural gas by working on behalf of a specific supplier or independently, while natural gas aggregators negotiate natural gas supply deals on behalf of a group of people or a community. Some states also require registration for energy consulting firms that advise on energy usage.

The services issued by these intermediaries as agents, aggregators, and brokers varies slightly, but none of these intermediary roles actually take ownership of a supply of natural gas. Once an entity takes ownership of a supply of natural gas they are typically required to be registered as a natural gas supplier.

Initial Registration

Before starting the registration process, it is important to make sure that your business entity is in good standing and, if providing service outside of your home state, has a certificate of authority to do business in each of the jurisdictions you plan to serve. Filing tax registrations with the department of revenue is another important step, especially for businesses with employees in multiple states.

Application requirements vary by state, but it is common for applicants to be asked for the following:

  • Business entity information
  • Articles of incorporation/formation
  • A list of officers and owners of the business
  • Financial statements
  • Proof of relevant experience for principals of the business
  • Disciplinary and criminal history for key personnel
  • Customer service contact information
  • Proposed service area and related information
  • Marketing material information

Gathering all of the documents and submissions required for registration can be a challenge, but keeping a detailed track of your progress will help when it comes time to submit your application. Minimizing application errors is important because missing a single requirement can add weeks to the approval process.

Maintaining Compliance

After registrations are approved by the public utility commission, there are ongoing requirements to meet to maintain the registration’s active status. Filing on time can save you from headaches down the road because missing periodic filing deadlines can jeopardize your company’s authority to provide service in a jurisdiction.

In most states agent, aggregator, and broker registrations need to be renewed periodically. The most common renewal periods are annual or biennial, but District of Columbia registrations expire every five years.

Along with renewing registrations, many states require natural gas supply intermediaries to file periodic reports relating to bond requirements, distribution numbers, or financial information. These reporting requirements also vary in frequency but are usually required on an annual or quarterly basis.

Keeping up with each state’s requirements, tracking renewals, and submitting the applications on time are critical to avoiding penalties. Dedicated compliance services and software can help you keep track of varying jurisdiction requirements and relevant updates to state laws.

Explore Registration Requirements by State

Click on a link below to view registration information in your state.

Aggregator - Agents acting as brokers on behalf of a group or groups of customers.

Broker - An agent acting as a middleman between energy suppliers and customers. Brokers can be affiliated with a single energy supplier or may have several supplier affiliations.

Competitive Energy States - States that allow consumers to choose the supplier of their energy source.

Energy Supplier - Narrowly defined, a supplier is a company that owns rights to a supply of energy or owns means of producing energy and then sells that energy to customers. The broad definition of energy supplier also includes aggregators, brokers, and marketers.

Franchise Agreement - A contract between municipal governments and utility companies that sets a franchise fee and conditions for the use of public rights of way.

Power Marketer - Act as intermediary between utilities and customers. Marketers do not own any assets related to power generation, they simply find price discrepancies between utility companies and offer savings to customers.

ACCES: American Coalition of Competitive Energy Suppliers
Consumer outreach organization that educates the public on energy choice.

FERC: Federal Energy Regulatory Commission
Independent agency charged with oversight of electric, oil, natural gas, and hydropower transmissions.

RESA: Retail Energy Supply Association
National association of energy suppliers that encourages competition in energy markets.

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