Consumer Scotland has published its response to Ofgem's statutory consultation on consumer standards, saying it broadly agreed with the regulator's priorities for improving service standards in the retail market1. The response was published on 28 August 20231.
The consultation proposes additions to the licence code and draft contact ease guidance. Among the proposed requirements is that suppliers' enquiry services be open 24 hours a day for domestic customers who have lost gas or power because of supplier issues1. Consumer Scotland noted that the draft wording of the condition covers electricity interruptions but does not include "gas", and asked whether this was intentional, saying consumer protection would be enhanced by an explicit reference to gas, for example in the case of a gas meter fault1. It also said it would expect the 24 hour service to be provided free of charge to domestic customers in vulnerable circumstances1.
Consumer Scotland's evidence base shows overall satisfaction with energy supplier customer service is low. The Spring 2023 wave of its Energy Affordability Tracker found that 46 per cent of consumers thought their supplier made it easy to contact them, down from 51 per cent in Spring 2022, while 24 per cent said their supplier did not make it easy to contact them1. Fifty-six per cent thought the language in their bills was easy to understand, with 20 per cent disagreeing, and 54 per cent agreed their bills gave guidance on what to do if they were worried about paying1.
The final report from the Scottish Energy Insights Coordination group, for which Consumer Scotland acted as secretariat, highlighted increased pressure on the advice sector when suppliers fail to meet customer service obligations. One member estimated that 20 per cent of calls received in winter 2022-23 came from consumers who could not contact their supplier1.
"Consumer Scotland broadly agreed with Ofgem's priorities for improving standards of service in the retail market"
The response sets out three additions Consumer Scotland would like to see: an outcomes-based approach to compliance that goes beyond meeting targets; moves towards a minimum standard on the supplier provision of agency lines; and suppliers being encouraged to achieve a recognised accreditation for customer service, such as BSI ISO 22458:20221. It said suppliers could meet individual metrics while still delivering a sub-optimal service, and that the quantum of available advice, not just opening hours, is key to an effective enquiry service1.
On the draft guidance, Consumer Scotland said the requirement for a digital channel could benefit from clearer definition, warning that a channel provided through a social media platform would be unlikely to suit all consumers1. It cited estimated wait time messages in call queues and call-back options with clear timeframes as examples of good practice Ofgem should consider citing1. It also said the use of artificial intelligence needs careful framing1.
Why it matters for households
The standards under consultation govern how easily a household can reach its supplier, which matters most when something has already gone wrong: a loss of supply, a billing problem or difficulty paying. Consumer Scotland's figures suggest that a substantial minority of households find contacting their supplier difficult, and that some of that demand is displaced onto advice agencies, which then have less capacity for work such as energy efficiency advice or support with low-carbon heating1. For a home's energy independence, the practical point is whether a supplier can be reached and can act when supply is interrupted or a payment problem arises. Consumer Scotland's response also links poor customer service to barriers to the changes consumers are being asked to make as the sector decarbonises1.
What happens next
Ofgem intends to publish a decision on any licence changes by early October 2023, for any licence changes to go live in December 20231.