How do you dispute an electricity or water bill in Peru, and can they cut you off while you do?

Two procedures. Do not mix them

Take the water rule to the electricity company and you lose. Two regulations, two regulators, two appeal bodies:

• Electricity (and natural gas). The Directiva on the administrative complaints procedure for users of public electricity and natural gas services, approved by Resolución de Consejo Directivo OSINERGMIN N.º 269-2014-OS/CD and published on 23 January 2015. There is no TUO of it: what exists is a consolidated text Osinergmin publishes, updated to 25 October 2019. First instance: your empresa distribuidora. Second and final administrative instance: JARU, the Junta de Apelaciones de Reclamos de Usuarios at Osinergmin (art. 12).
• Water and sanitation. The Texto Único Ordenado of the General Regulation on Complaints by Users of Sanitation Services, approved by Resolución de Consejo Directivo N.º 015-2023-SUNASS-CD and published as a special supplement on 4 May 2023. First instance: your empresa prestadora, through the unit it designates. Second instance: TRASS, the Tribunal Administrativo de Solución de Reclamos de los Usuarios de los Servicios de Saneamiento at Sunass (art. 13).

What holds in both

1. It is free. Electricity: art. 5 says these procedures carry no processing fee at any instance. Water: art. 39 makes them free, except for the taking of evidence in the cases the regulation expressly sets out.
2. You do not pay first. The company cannot make the handling of your claim conditional on paying the disputed amount. Electricity: art. 16.1, which covers the interest too. Water: art. 32.2, for claims that directly affect billing.
3. The disputed debt stays off your later bills. Electricity: art. 16.2, until the claim is finally decided in the administrative procedure; the company may show the amount for information, as suspended because it is under claim, but it may take no step at all to collect that debt. Water: art. 32.2, until the claim is decided at final instance.
4. They cannot cut you off over the disputed amount. Electricity: art. 16.3. Water: art. 33.
5. The company’s silence works for you. Both regulations provide for silencio administrativo positivo where the company fails to decide or notify in time: art. 21 for electricity, art. 25 for water.

Electricity and water, side by side

Electricity: the detail

Deadlines to decide (art. 20.1). They run from the day after the claim is received, or from the day after you cure any admissibility defect. Ten días hábiles where you challenge a cut-off and ask for reconnection, and where you challenge only excess electricity consumption on the BT5B tariff option, minimum charges or consumption-linked charges and the prior assessment finds billing errors. Thirty días hábiles for the remaining BT5B excess-consumption cases and for any other subject.

Two remedies, not one (art. 22.1). Reconsideración is decided by the distributor itself within 10 días hábiles and requires you to offer new evidence; it is not a precondition for appealing. The apelación is decided by JARU, which assesses whether the company’s decision fits the regulation in force. Both are filed with the distributor, within a maximum of 15 días hábiles counted from the day after the decision you are challenging was notified (art. 22.2).

Getting money back (art. 14.2). A claim for the refund of amounts already paid on electricity bills has a window of 3 years from the date you paid. In other cases you can claim for as long as the situation that gave rise to it continues.

A rule few people know (art. 16.4). If your claim opposes the installation of a supply point, it cannot be installed — or reinstalled — while the complaint procedure is open.

Water: the detail

Three kinds of claim (art. 2). Operational, for engineering and infrastructure problems in the service. Commercial relating to billing, for problems with a direct bearing on the amount you pay. Commercial not relating to billing. Which kind yours is decides the deadline.

Three stages (art. 12). Investigation, conciliation, decision. Conciliation is mandatory only for commercial claims relating to billing; for operational claims and commercial claims not relating to billing it is optional.

What the utility owes you when it takes the claim. The código de reclamo (art. 11.2) and the latest date — day, month and year — on which it will issue and notify its decision (art. 11.3). The same applies to filing a reconsideración and an apelación. If you claim by phone, the utility must fill in Formato N.º 2 and notify you that it received the claim within 3 días hábiles (art. 11.1.b).

No extensions on billing (art. 24.1). For problems relating to billing, the utility may not extend the deadlines to decide.

Getting money back (art. 34). A refund of overpayments, with interest, is requested in the administrative procedure within one year counted from the day after payment.

If the company will not process your claim: the queja

A queja is not a reclamo. It attacks how the company is behaving inside the procedure, not the merits of what you claimed.

• Water: it may be lodged at any stage of the procedure, which ends with the second-instance decision (art. 42), must be in writing (art. 43), goes to TRASS or to the empresa prestadora (art. 44), and is decided within 15 días hábiles counted from the day after the deadline for the company’s reply expires (art. 46).
• Electricity: the queja is governed by articles 34 to 38 of the Directiva. It is filed at any Osinergmin office nationwide, or through Osinergmin’s website (art. 35.1); it may also be filed with the empresa distribuidora, which forwards it to Osinergmin (art. 35.2). JARU decides it within 15 días hábiles of the expiry of the distributor’s deadline to file its reply, whether or not the distributor replied (art. 38).

Foreigners

Neither regulation requires Peruvian nationality. The water one identifies who may claim by their link to the property and the service: the owner of the property, the holder of the connection, or anyone who proves they are the effective user and suffers harm (art. 11.1.a). The electricity one speaks of the usuario. This follows from the text: neither says a DNI or Peruvian nationality is required.

What this page does not assert

• We give no helpline numbers and no links to online forms at Osinergmin or Sunass: we could not confirm they are current.
• We do not reproduce the full list of cases in article 21 of the electricity directive (silencio administrativo positivo): we confirmed only that the article governs it.
• We did not exhaustively confirm whether the electricity directive was amended between October 2019 and February 2025. The latest amendment we identified is Resolution 014-2025-OS/CD, published 8 February 2025, changing numerals 2.4, 39.2, 39.3, 39.4 and Anexo I — none of the articles this page relies on.
• We do not blend in the consumer route through Indecopi or the libro de reclamaciones. That is a separate track and we did not research it for this page.

What if OSINERGMIN fines the utility and it doesn’t pay?

A complaint resolved in your favor can end in a fine against the electricity company. What happens if that fine goes unpaid is covered in what happens if a company doesn’t pay an OSINERGMIN fine?.

And what’s supposed to happen before your service gets cut?

This guide covers the complaints process; but if what you want to know is what the law requires before a non-payment cutoff (and whether there’s an advance-notice period), we cover that separately in power or water shutoff without notice in Peru.

What if the meter itself is the problem?

If you suspect your electricity or water meter is malfunctioning and that is why your bill jumped, you can request an accuracy test. Read what to do about a faulty meter to see who pays for the test and what error margin is acceptable.