Our response to Ofgem's consultation on their Draft Consumer Vulnerability Strategy

In 2018, we advised 41,953 people with electricity arrears (equivalent to 16% of all clients with responsibility for electricity bills) and 22,826 people with gas arrears (12% of all clients with responsibility for gas bills).

In recent years we have seen some welcome progress in terms of how vulnerability and affordability are dealt with in the energy sector. However, there remains much to do and we warmly welcome Ofgem’s commitment to continuing to address these issues, as set out in the draft strategy.

The strategy appears to contain a good level of ambition and it is positive to see the regulator taking a strong stance on these issues. In this response, we set out our position on some of the key questions, including our support for strengthening the Ability to Pay principles.

We highlight where we believe ongoing focus is needed, such as improving the ability of people in arrears to switch, reconsidering the use of Fuel Direct in light of affordability concerns and ensuring people with arrears can get affordable repayment plans set up.

We also talk about our view on Ofgem’s role in wider affordability debates and why we believe it is important for Ofgem to consider the role of social tariffs as part of its assessments regarding the ending of the price cap.

Finally, we highlight the importance of suppliers taking a proactive role in identifying and tackling financial difficulties and set out how we would like to see efforts to improve the Priority Services Register (PSR) used as an opportunity to consider financial vulnerability too.

Download our consultation response to read our full response and recommendations.