CAS strongly welcomes Ofgem’s Draft Vulnerability Strategy 2025. It signals to industry, Ofgem’s renewed commitment to strengthening its own work in supporting consumers in vulnerable situations, as well as placing greater onus on suppliers and network operators to do more in this area. We recognise that since the publication of the first Vulnerability Strategy in 2013, Ofgem and industry has already made good strides in this area.
It is notable that the first Strategy, which defined the range of vulnerable circumstances, has helped to elevate the issue of vulnerability within industry and across other sectors – putting emphasis on Priority Service Registers for example, and improving the identification of vulnerable consumers.
This is a positive step forward, yet there is much further to go. With unprecedented levels of change in the energy system and wider industry, it is important that this next 5 year Strategy, carefully pre-empts and future-proofs for pinch-points where vulnerable consumers could face more detriment than the average consumer. We propose a number of key factors which we think can be used to frame all components of the revised strategy.
1. Compliance with existing obligations and regulations
2. A universal service no matter where you live or who you are supplied by
3. Integration and streamlining of support services across sectors (networks, retail, water etc.)
4. Getting the basics right to reduce detriment (billing, meter reading, digital access)