Insights ¦ OFGEM Consumer Vulnerability Strategy

Key Take Aways

1. The strategy underscores a broad, principles-based approach to consumer vulnerability, emphasising individual circumstances and personal characteristics.
2. Focused outcomes aim to ensure consumers in vulnerable situations are identified, supported, and can access tailored services with minimal burden.
3. Data sharing and smarter use of data are central themes, promoting transparency, proactive identification, and timely intervention for vulnerable consumers.
4. The strategy prioritises support for consumers struggling to pay their bills through guidance on billing accuracy, flexible payments, and debt reduction schemes.
5. Improvements in customer service are emphasised, including tailored communication, ease of engagement, and safeguarding against exclusion.
6. The strategy promotes inclusive innovation, encouraging accessible, inclusive, and effective adoption of new technologies and market solutions.
7. Cross-sector collaboration is recognised as vital for addressing common issues faced by vulnerable consumers, highlighting collective industry efforts.
8. Industry participants are expected to embed standards of conduct fostering fair, honest, and transparent treatment, supported by guidance and monitoring mechanisms.
9. The implementation involves annual vulnerability focus sessions with suppliers, reinforced by formal reporting, monitoring, and enforcement actions.
10. The strategy aims to build trust by increasing transparency on work programmes, progress assessment, and learning from good industry practice.
11. A broad, flexible vulnerability definition supports adaptation to changing circumstances, including both permanent and transitory vulnerabilities.
12. Regulatory oversight and industry engagement are designed to promote continuous improvement, accountability, and consumer-centric cultures across the sector.

Key Statistics

• One in three adults (approximately 18 million) in the UK are deaf, hearing impaired, or have tinnitus.
• An estimated 16.1 million people in the UK had a disability in 2022/2023, representing 24% of the population.
• Over 2 million UK residents live with sight loss.
• 47% of disabled working-age adults reported a mental health impairment.
• As of September 2024, 15% of respondents aged 65+ with low household income reported being in debt to their energy supplier.
• As of March 2025, around 7 million adults are behind on at least one household bill, with approximately 1.4 million behind on energy, council tax, or water bills.
• 5.6 million households in the UK are in fuel poverty.
• Nearly 41% of adults found energy bills to be very or somewhat difficult to afford in early 2024.
• 19% of UK adults and 32% of those over 75 lack essential digital skills.
• An average arrears debt of £1,568 for electricity and £1,324 for gas is owed by individuals in arrears without repayment plans as of September 2024.

Key Discussion Points

• The strategy’s broad, principles-based vulnerability definition seeks to cover all aspects of consumer circumstances, ensuring a holistic approach.
• Emphasis on data-driven approaches, advocating smarter data sharing, consumer consent, and infrastructure to support early identification.
• The importance of proactive support schemes, including debt relief, targeted billing improvements, and affordability measures.
• Enhancement of customer service through tailored, accessible communication channels and non-exclusionary engagement practices.
• Inclusive innovation is promoted, with specific focus on technologies and market solutions that are designed inclusively, supporting all vulnerable groups.
• Cross-sector collaboration with government, consumer bodies, and third parties is critical for addressing multifaceted vulnerabilities.
• Industry stakeholders are encouraged to embed standards of conduct that promote fairness, honesty, transparency, and customer-centricity.
• Monitoring mechanisms include annual vulnerability focus sessions, progress reports, and compliance enforcement to ensure continuous improvement.
• Transparency initiatives aim to improve stakeholder understanding of ongoing work, performance metrics, and lessons from best practices.
• The vulnerability definition recognises both transitory and enduring situations, accommodating dynamic personal and market circumstances.
• The strategy aligns with wider policy objectives, including the delivery of government fuel poverty schemes and market reforms for vulnerable consumers.
• The ongoing UK government review of the regulator’s role may influence future strategy themes and the scope of protections.

Document Description
This article presents Ofgem’s refreshed Consumer Vulnerability Strategy, a comprehensive policy framework aimed at improving outcomes for consumers in vulnerable situations within the UK energy sector. It details targeted outcomes, strategic themes on data use, affordability, customer service, inclusive innovation, and cross-sector collaboration. The document outlines the regulatory approach, including industry engagement, transparency measures, monitoring, and enforcement processes to embed fair, inclusive, and proactive support for vulnerable consumers. Designed as a guiding tool for industry and stakeholders, the strategy aims to foster a consumer-centric culture, promote good industry practice, and adapt to evolving personal and market circumstances.