Ofgem opened a consultation on 10 September 2024 on proposed changes to refresh its Consumer Vulnerability Strategy, with responses due by 5 November 20241. The regulator also announced further work on consumer standards through its Consumer Confidence work programme in September 2024, which it says seeks to drive improvements and culture change in customer service2.
The refreshed Strategy was published on 15 April 2025, following 67 responses to the consultation1. Ofgem describes the outcome as a narrower and more targeted document:
"Following stakeholder consultation, we have decided to introduce a narrower and more targeted Consumer Vulnerability Strategy."
The Strategy sets four themes: improving identification and smarter use of data; supporting consumers struggling to pay their bills; driving improvements in customer service for vulnerable groups; and encouraging positive and inclusive innovation. A fifth, cross-cutting theme covers working with others on issues that span sectors1. Ofgem says the Strategy sits alongside its Consumer Confidence programme, which looks at outcomes for all consumers across the whole market1.
The published Strategy cites figures on the scale of vulnerability and debt. As of July 2024, approximately 5.6 million households in the UK were in fuel poverty1. By the end of September 2024, individuals in arrears without a repayment plan owed an average of £1,568 for electricity and £1,324 for gas1. As of March 2025, around 7 million UK adults were behind on at least one household bill, with approximately 1.4 million behind on their energy, council tax and water bills1. Ofgem also reports that an estimated 16.1 million people in the UK had a disability in 2022/2023, accounting for 24% of the population1.
Separate survey findings published in November 2024, covering fieldwork in July 2024, recorded overall satisfaction with suppliers at 78%, up from 73% in January/February 2024, with satisfaction with customer service rising from 66% to 71%2. Satisfaction among those who said they made a complaint was low for the overall handling of the complaint (47%) and the time taken to reach the end of the process (37%)2. A third (35%) of households with a smart meter reported an issue with it in the last three months, consistent with 33% in the previous wave, while satisfaction with smart meters rose to 72% from 68%2.
Why it matters for households
The Strategy is the framework Ofgem uses to direct how suppliers identify and treat customers in vulnerable situations, which covers households that cannot pay, have health conditions, or need extra help with contact and billing. Ofgem says its definition of vulnerability should remain intentionally broad, and that financial definitions are better handled through its Debt Relief Support Scheme and government affordability work1. For a household, the practical effect sits in how a supplier recognises a change in circumstances and what support follows, including repayment arrangements and priority services. The survey evidence shows complaint handling remains the weakest area of the customer experience, with fewer than half of complainants satisfied with how their complaint was handled2. The Strategy commits Ofgem to annual Vulnerability Focus Sessions with suppliers and a progress report on outcomes for consumers in vulnerable situations1.
What happens next
Ofgem published a framework consultation in November 2024, and its Debt Strategy in December 2024, setting out four components of work to reduce debt and arrears in the domestic market1. In December 2024, DESNZ announced a review of Ofgem's duties, mandate, powers and approach to enforcement; Ofgem says it will work through any implications for the Strategy once that review is finalised1. In February 2025 Ofgem consulted on a zero price cap variant in the domestic retail market1. On 10 April 2025 it published its decision to activate dormant supplier licence condition SLC 31G.3A(c), taking effect from 1 August 2025, and a new payment level of £40 per failure took effect from January 20251. The next wave of the satisfaction survey was due to take place in early 20252.
Sources2 cited
- Consumer Vulnerability Strategy, ofgem.gov.uk
- Energy Consumer Satisfaction Survey – Findings Report – July 2024, ofgem.gov.uk