National Energy Action (NEA) published its response to the consultation on refreshing Ofgem's Consumer Vulnerability Strategy on 5 November 20241. The charity said the refreshed strategy must influence how suppliers, networks and Ofgem approach the identification and treatment of vulnerable consumers over the coming years1.
NEA set out the background to its response, noting that the current Consumer Vulnerability Strategy was created in 2019, before the energy price crisis that began in 20211. It said that when the current strategy was introduced the energy price cap was set at £1,179, and that it now stands at £1,7171. Accounting for changes to typical domestic consumption values, NEA said this means the typical household pays £500 a year more than in 2019, despite using less electricity and less gas1.
The response also cites debt figures. NEA said debt has risen from £1.3bn to £3.7bn between the introduction of the previous strategy and now1. It estimated that, on aggregate, consumers are paying around £1.5bn a year to service the costs of debt, and said elevated debt levels result in additional costs on tariffs for all consumers1. NEA's own polling suggests households are turning to rationing as well as debt to cope with high prices, with the charity recently finding that almost half of adults are likely to ration their energy this winter1.
"National Energy Action hopes that the update to this strategy will result in alleviation of pressure on the most vulnerable consumers."
The consultation itself is run by Ofgem, the energy regulator, whose role and remit are set out in our guide to what Ofgem does and what it covers. The Consumer Vulnerability Strategy sits within the wider process by which rules are proposed, decided and changed, which is explained in our guide to energy consultations and how policy is made. Ofgem's consumer protection work also extends to heat networks, covered in our guide to heat network regulation.
Why it matters for households
The strategy governs how suppliers and network operators identify and treat customers who may be vulnerable, which affects how problems such as debt, disconnection risk and access to support are handled in practice1. NEA's figures indicate the pressure on household budgets is greater than when the strategy was written: a typical household paying £500 a year more than in 2019 while using less gas and electricity, and aggregate consumer debt of £3.7bn1. NEA states that elevated debt levels feed into costs on all tariffs, so the way debt is managed has a bearing on bills beyond the households that owe money1. For a home's energy independence, the practical questions are how vulnerability is identified, what support follows, and how the costs of debt are shared across the customer base1.
What happens next
NEA's response was published on 5 November 20241. No date for Ofgem's decision on the refreshed strategy, or for any publication of the final version, is given in the response1.