Citizens Advice published its response to Ofgem's Consumer Vulnerability Strategy Refresh on 8 November 2024, welcoming the proposals while setting out where it wants more done1. The charity said the strategy must protect consumers and improve outcomes even as the market changes significantly due to technology and decarbonisation1.
Debt and affordability is described in the response as the most pressing challenge facing consumers and the sector. Citizens Advice estimates that over 5 million households live with energy debt, and says energy debt is the most common form of debt its advisers help people with1. It wants further efforts through proactive communication with consumers at risk of debt and manageable repayment plans, with debt costs allocated fairly and targeted bill support from the Government1.
"Citizens Advice welcomes Ofgem's Consumer Vulnerability Strategy Refresh, which outlines several positive proposals."
On billing, the charity welcomes a review of billing rules, which it says should enable a reduction in the current back billing period and reduce the risk of shock bills that can lead to debt. It adds that this will depend on the successful rollout of smart meters, and that Ofgem should do more, including through its review of Guaranteed Standards, which it says should be extended to include smart meter issues1.
The response supports proposals to review the priority services register (PSR), noting that many eligible consumers are not currently receiving support under the register. It emphasises the need for robust safeguards against unintended negative impacts on consumers should a multi-sector PSR be implemented, and for specific metrics to address self-identification before that happens1. On standing charges, Citizens Advice says proposed reforms require additional work to ensure consumers in vulnerable circumstances are protected, though Ofgem should continue work on minimising fixed costs in the energy system1. It also welcomes Ofgem's Consumer Confidence programme, including a commitment to consider introducing a Consumer Duty similar to the one in financial services, which it says could raise standards, focus firms on good consumer outcomes and ensure fair value while enabling innovation1. The strategy should also work for heat network consumers, where Ofgem will soon take on the role of regulator, and for flexibility and intermediary services where regulation is being developed1.
Why it matters for households
Energy debt at the scale described here, over 5 million households, is the backdrop against which protections for vulnerable customers are set. The standing charges that appear on every bill are one of the areas Citizens Advice says needs more work before reform, which matters to any household trying to judge what a fixed daily charge does to its costs. The back billing period determines how far back a supplier can chase payment for energy used but not billed, so a shorter period would reduce the risk of a large unexpected bill. The PSR is the route by which households with certain needs get extra help, and the response says many who qualify are not getting it. A Consumer Duty, if introduced, would change how firms are expected to treat customers. Households wanting to understand who handles complaints and consumer representation can read the site's guide to energy consumer bodies and to energy complaints and redress.
What happens next
The response is dated 8 November 2024 and sets out Citizens Advice's positions on Ofgem's refresh. No timetable for Ofgem's decisions on back billing, the PSR, standing charges or a Consumer Duty is given in the response1.