Ofgem's consultation on proposed changes to its Consumer Vulnerability Strategy closed on 5 November 2024, the deadline for responses1. The regulator had opened the consultation on 10 September 20241. Ofgem received 67 responses, which it said it considered in shaping the final refreshed Strategy1.
The decision was published on 15 April 20251. Ofgem said it had decided to introduce a narrower and more targeted Consumer Vulnerability Strategy, following stakeholder consultation1. 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, with a fifth cross-cutting theme on working with others across sectors1.
"Following stakeholder consultation, we have decided to introduce a narrower and more targeted Consumer Vulnerability Strategy."
The document sets out the scale of the issue. As of July 2024, approximately 5.6 million households were in fuel poverty in the UK1. 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 adults behind on their energy, council tax and water bills1. In April 2024, 15% of respondents aged 65 and over with a household income of £15,000 or less reported being in debt to their energy company1.
Ofgem also cited population data on vulnerability: an estimated 16.1 million people in the UK had a disability in 2022/2023, accounting for 24% of the total population; one in three, or 18 million adults, are deaf, have hearing loss or tinnitus; and over 2 million people are living with sight loss1. For disabled working-age adults, 47% reported a mental health impairment1.
The Strategy sits alongside other Ofgem work. Ofgem published its Debt Strategy in December 2024, setting out four components of work to reduce debt and arrears in the domestic energy market1. In February 2025 it published a consultation on a zero price cap variant in the domestic retail market1. In December 2024, the Department for Energy Security and Net Zero announced a Review of Ofgem's duties, mandate, powers and approach to enforcement1. Ofgem said that once that review is finalised and government has determined Ofgem's future role, it will work through any implications for the Vulnerability Strategy, including its themes and outcomes1.
Why it matters for households
The Strategy is the framework that shapes how suppliers are expected to identify and treat households in vulnerable situations, including those struggling to pay. Ofgem said it considers its definition of vulnerability should remain intentionally broad, so the sector focuses on all aspects of vulnerability, and that financial-specific definitions are best picked up within its Debt Relief Support Scheme and government's energy affordability work1. The Strategy consolidates existing guidance on that definition and how companies should apply it1.
For a household, the practical effect runs through supplier conduct rather than through any direct payment. Ofgem said it will hold Vulnerability Focus Sessions with suppliers annually, as part of existing senior meetings, to discuss good practice and challenge suppliers on how they could go further1. It will report findings from those sessions, alongside data on outcomes for consumers in vulnerable situations, in a Consumer Vulnerability Strategy progress report1. Ofgem also said it wants to work with industry on improving the data it gathers1.
The Strategy's work programmes include heat networks regulation, networks activity through the Vulnerability and Carbon Monoxide Allowance, and delivery of government fuel poverty schemes such as the Warm Home Discount and Energy Company Obligation 41. Ofgem's wider work on standards for all consumers, including its Consumer Confidence programme, runs alongside it1.
What happens next
The Strategy was published on 15 April 20251. Ofgem said that on 10 April 2025 it published its decision to activate dormant supplier licence condition SLC 31G.3A(c), taking effect from 1 August 20251. The new payment level of £40 per failure took effect from January 20251. Ofgem said the government's review of its role may have a bearing on how it protects all consumers, including those in vulnerable situations, and that it will work through any implications once that review is finalised1.
Sources1 cited
- Consumer Vulnerability Strategy, ofgem.gov.uk