Ofgem has completed a Market Compliance Review of how energy suppliers support customers in vulnerable situations, publishing its findings on 22 November 2022. The review assessed suppliers against their Supply Licence obligations and divided all of them into three groups by the severity of the weaknesses found1.
The assessment drew on material suppliers provided in response to Ofgem's request for information dated 4 July 2022, including market monitoring data on priority services registration and customers who are self-disconnecting or self-rationing1. Ofgem said all suppliers had issues to address and that it has started compliance engagement with every supplier, asking them to take action on the weaknesses identified. It said suppliers are implementing improvement plans based on the assessment and feedback already given1.
| Group | Suppliers named | Ofgem's description |
|---|---|---|
| First group | British Gas, Bulb, EDF, E.ON, Ovo, Scottish Power, Utility Warehouse | Most required processes, procedures and training in place, with some areas for improvement |
| Second group | E (Gas & Electricity), Ecotricity, Green Energy UK, Octopus, Shell | Moderate weaknesses; processes generally in place but in some cases not adequately documented, with insufficient controls and governance |
| Third group | Good Energy, Outfox, SO Energy, TruEnergy, Utilita | Severe concerns; no consistent and structured approach demonstrated to identifying and supporting customers in vulnerable situations |
Ofgem said the third group put consumers at serious risk of poor and potentially serious outcomes, with a clear need for rapid and significant improvement1. Areas for improvement identified across suppliers included clearer policies to identify customers in a vulnerable situation, appropriate training for customer-facing staff, quality assurance controls over third-party representatives, and demonstrating that using prepayment meters, including smart meters switched to that mode, is appropriate for customers1.
Ofgem also wrote to suppliers about the remote switching of smart meters to prepayment mode. It said:
"We have written to suppliers on remote switching of smart meters to prepayment mode with our expectation that they review their obligations and processes on smart prepayment meter practices as a matter of urgency"
The licence obligations Ofgem assessed include proactively identifying and recording customers in a vulnerable situation on a Priority Services Register, providing free gas safety checks to eligible customers, ensuring prepayment meters including smart prepayment meters are used only when safe and reasonably practicable, supporting customers who have self-disconnected or self-rationed, and communicating in accessible formats1.
Why it matters for households
The review concerns the practical support a household can expect when it is in a vulnerable situation, which sits alongside the prepayment meter and vulnerable customer protections that apply to suppliers. For a household on a smart prepayment meter, the letter on remote switching is significant because a meter can be changed to prepayment mode without a visit, so the processes a supplier follows determine what happens in the home. The findings also cover the Priority Services Register and what suppliers must do for vulnerable customers, including free gas safety checks and accessible communications. Ofgem's role in setting and enforcing these obligations is set out in its remit as the energy regulator, and the underlying duties sit within the smart meter rules and supplier obligations.
What happens next
Suppliers are required to deliver on their improvement plans to demonstrate they fully support customers in vulnerable situations in line with their licence obligations1. Ofgem said that where it has serious ongoing concerns with suppliers, it will consider what further action may be necessary in line with its Enforcement Guidelines1. No further dates or deadlines have been reported.