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In a Staff Report filed on May 19, 2026 in Dayton Power & Light’s (AES Ohio’s) rate case at the Public Utilities Commission of Ohio (PUCO) states that utility’s billing errors has increased substantially after previously reaching remediation plan milestones.

Specifically, Staff’s report notes that at the conclusion of AES Ohio Billing Group Resolution meetings on January 31, 2026, AES reported to stakeholders that 99.6 percent of customers were being invoiced.

However, as of approximately March 2026, Staff reported that the number of customers not invoiced has increased 56 percent since January 30, 2026, to 3,889 customers.

Excerpts from Staff Report:

Billing Concerns

“On April 1, 2026, Staff amended the PNC. The Amended PNC updated the number of customers who had not received an invoice for over 90 days. The Amended PNC updated the number of PUCO call center cases without a Company response for 10 and 30 days. In addition, Staff added seven new corrective actions, including the following: (1) not collecting or deferring incremental costs of complying with the notice; (2) limiting back-billing of charges to the statutory one-twelfth limit; (3) reviewing already back-billed customers for compliance with the one-twelfth limit; (4) within 30 days, resolve all open customer cases with the PUCO call center related to the ACE billing issues that have been open for 30 days as of the date of the amended PNC; (5) within 60 days, resolve all other open customer complaints with the PUCO that are open as of the date of the amended PNC; (6) within 30 days, submit to Staff a plan for resolving issues for the customers that have not received a bill for more than three months, which should include a resolution of remaining issues within 60 days, and customers not billed within three months should be offered a two-year payment plan. The Amended PNC also proposed a forfeiture of o$2,006,200 for the violations. The Company responded to the amended PNC in a manner similar to its response to the initial PNC, with assurances to invoice customers by increasing the number of employees dedicated to resolving billing concerns and accelerating remaining billing system issues and processes resolutions. Staff and the Company are currently working to resolve the outstanding issues identified in the PNC.”

“The Company’s noncompliance with rules requiring timely responses to the PUCO call center also showed that it lacked the heightened urgency required. The PUCO call center had 184 active investigations regarding the Company on January 13, 2026, increasing to 330 active investigations on March 4, 2026. As part of the commitments to resolve the issues identified in the PNC, the Company has reduced the backlog to 297 active investigations as of March 12, 2026; however, 178 of those investigations are older than 30 days.”

“The ACE transition created thousands of billing issues that the Company has still not resolved. The Company has not met the urgency of concern with an urgency of action. As demonstrated in the chart below, the lack of timely billing was and continues to be a customer service failure.

Staff in the rate case report alleged, “ACE transition created thousands of billing issues that the Company has still not resolved. The Company [DP&L] has not met the urgency of concern with an urgency of action … the lack of timely billing was and continues to be a customer service failure.”

“In a Notice of Probable Non-compliance issued by Staff to AES Ohio, Staff seeks a forfeiture of $2 million related to the billing errors.”

“Interested parties are advised that written 2 objections to any portion of the Staff Report must be filed within 30 days of the date of the filing of this report, after which time the Commission will promptly set this matter for public hearing.”

Background

As background, ACE began transitioning customers to ACE on June 16, 2024. The ACE project was a comprehensive billing, customer information, and data management system. The utility anticipated a complete transition by the end of August 2024. In Case No. 24-08-EL-WVR, the Company requested several temporary waivers of Ohio Administrative Code provisions, including Ohio Adm.Code 4901:1-10, 4901:1-18, and 4901:1- 21. The Commission granted the temporary waivers. The waivers included the suspension of disconnections and late payment fees as well as a short interruption to the Competitive Retail Electric Service (CRES) transactions.”

“The transition period was to conclude at the end of August 2024 but was delayed until September 4, 2024. The Company, however, experienced difficulty with the ACE implementation, which delayed the resumption of ordinary business such as collection and billing activities. The Company continued to experience unresolved customer issues with ACE that impacted customers through April 2025. In July 2025, the Company notified the Commission of the resumption of ordinary billing and collection activities and the ending of the temporary waivers. As the Company was resuming ordinary business activities, the Company filed a Stipulation in Case No. 24-1009-EL-AIR on August 13, 2025. Part of the Stipulation was the convening of a Billing Resolution Group to meet beginning the week of August 18, 2025, to discuss concerns of suppliers and customers regarding customer bills since the implementation of the ACE and the expected timing to resolve those issues. The Billing Resolution Group was to conclude by October 31, 2025, or not until 99 percent of customers had been invoiced in the preceding three months.”

“The Company had 24,629 (16,136 residential and 8,493 commercial) customers in May 2025 that had not received an accurate bill for at least three months. As of January 30, 2026, 2,813 customers of the 24,629 customers had entered into payment arrangements, with nearly half of the customers requesting a 12-month payment term. In addition, 649 of these customers were disconnected. Before the first Billing Group Resolution Meeting, Staff issued data requests to the Company regarding the outstanding billing concerns. As of the July 2025 billing cycle, the Company did not invoice 18,174 accounts, with 3,850 of those accounts not invoiced for more than six months. 10,221 of the 18,174 accounts also had not been invoiced for their CRES charges.”

“The Company had a target of October 31, 2025, to resolve the billing concerns and to have 99 percent of all customers invoiced. The Company reached the 99 percent threshold on November 14, 2025; however, 5,116 customers had not received an invoice for over four months, and, of these, 1,061 customers had not received an invoice for over nine months. 63 percent of these customers were also CRES customers, and 78 percent were residential. The Company concluded the Billing Group Resolution meetings on January 31, 2026, informing stakeholders that 99.6 percent of customers are being invoiced. As of January 31, 2026, 2,176 customers had not received an invoice for over three months, with 650 customers not receiving an invoice for over nine months.”

“In addition, AES Ohio customers during the last year contacted the PUCO call center expressing concerns over billing. These rose to 891 contacts in February 2026. As customers escalated customer inquiries and concerns to the PUCO, AES Ohio did not respond to the PUCO investigators timely. On January 16, 2026, Staff issued a Notice of Probable Non-compliance (PNC) for AES Ohio’s not billing customers accurately monthly and for not responding to Staff investigating customer concerns.”

“On January 30, 2026, the Company responded to the PNC, recognizing the billing concerns and its lack of timely responses to the PUCO. The Company, however, believes that it is materially complying with statutes and rules and that any undercompliance is de minimis. The Company’s proposed action plan was to bill customers who had not yet been billed and to increase staffing levels for the PUCO responses.”

“On March 11, 2026, Staff sent the Company an updated data request regarding progress on reducing the billing backlog. The number of customers not invoiced increased 56 percent since January 30, 2026, to 3,889 customers. Customer calls to the PUCO call center have continued at an elevated rate, and those calls mostly concern customers’ bills. The PUCO call center has experienced an increase in responses to resolve new customer concerns from the Company, but the backlog of responses is not being timely resolved.”

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