Ofgem published its refreshed Consumer Vulnerability Strategy on 15 April 2025, following a consultation that opened on 10 September 2024 and closed on 5 November 20241. The regulator said it received 67 responses, which it considered in shaping the final version1.
The strategy is narrower than its predecessor, published in 2019. Ofgem said:
"Following stakeholder consultation, we have decided to introduce a narrower and more targeted Consumer Vulnerability Strategy."
It sets out 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 innovation1. A fifth, cross-cutting theme covers working with others to solve issues that cut across sectors1. Each theme has one key outcome and more detailed sub-outcomes1.
Ofgem said the strategy sits alongside its Consumer Confidence work and its Debt Strategy, published in December 2024, which set out four components of work to reduce debt and arrears in the domestic energy market1. It also covers heat networks regulation, networks activity including 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 said it will hold annual Vulnerability Focus Sessions with suppliers and report findings in a progress report1.
The document cites figures on the scale of vulnerability and debt. As of July 2024, approximately 5.6 million households were in fuel poverty in the UK1. 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. 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. 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 said its definition of vulnerability should remain intentionally broad, and that financial-specific definitions are best picked up within its Debt Relief Support Scheme and government energy affordability work1. The strategy consolidates existing guidance on that definition and how energy companies should operationalise it1.
Why it matters for households
The strategy sets out what Ofgem expects from energy companies in how they identify and treat customers in vulnerable situations, and commits the regulator to publishing data on the outcomes those consumers receive1. For a household, the practical effect runs through supplier conduct rather than through any direct payment or price change: the themes cover how companies use data to spot vulnerability, how they handle customers who cannot pay, and the standard of customer service those groups receive1. The document also states that the government's review of Ofgem's role, announced by DESNZ in December 2024, may affect how the regulator protects consumers, and that Ofgem will work through any implications for the strategy once that review is finalised1. Ofgem's wider work on complaints and redress sits outside this strategy and is handled through existing routes.
What happens next
Ofgem said it will hold Vulnerability Focus Sessions with suppliers annually, as part of existing senior meetings, and will report findings alongside outcome data in a Consumer Vulnerability Strategy progress report1. Separately, Ofgem said it published a decision on 10 April 2025 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 also said it published a consultation on a zero price cap variant in the domestic retail market in February 2025, and a framework consultation in November 20241.
Sources1 cited
- Consumer Vulnerability Strategy, ofgem.gov.uk