We warmly welcomed Ofgem’s consultation on refreshing its Consumer Vulnerability Strategy. From the Covid pandemic to the energy crisis to ongoing cost of living challenges, the years since the strategy was last updated in 2019 have been extremely tumultuous for households’ finances and overall wellbeing. More and more people have struggled to make ends meet and found themselves in vulnerable circumstances, including many StepChange debt advice clients.
These challenges are certainly not temporary, so we were pleased to see Ofgem recognise the enduring, significant nature of the affordability and debt problems consumers are facing – and the disproportionate impact faced by vulnerable individuals and households in this context.
While there is evidence of some good practice by energy suppliers, key problems we continue to see at StepChange include energy suppliers failing to identify and take account of consumer vulnerability, suppliers making unaffordable demands for repayment from financially vulnerable households, and the use of aggressive or inappropriate debt recovery methods.
We therefore highlighted the pressing need to increase protections for, and improve the experiences of, customers struggling to keep up with energy bills and consequently interacting with the debt pathway – and that there should be a strong focus on vulnerability in these efforts. We were pleased that Ofgem has signalled a strong focus in this consultation on consumers in vulnerable situations having their needs identified, as well as receiving consistent and compassionate support.
We would also like to see Ofgem go further in its ambition. Ofgem states in its 2024 Consumer Confidence publication that its “goal is that all customers receive not just a good service but one that sets the highest standard for all service sectors”. In that context, we told Ofgem that the proposed vulnerability strategy looks too close to its predecessor, albeit with new commitments to monitor outcomes and a more focused delivery approach.
We suggested in our response how Ofgem could look more closely at its vulnerability definition to better embed considerations of consumer vulnerability in supplier culture and practice. We would also like to see Ofgem consider whether its consumer protection remit and powers are sufficient to achieve the objective set out in Consumer Confidence publication.