Scotland’s Citizens Advice Network is an essential community service that empowers people through our local bureaux and national services by providing free, confidential, and independent advice. We use people’s real-life experiences to influence policy and drive positive change. We are on the side of people in Scotland who need help, and we change lives for the better.
Citizens Advice Scotland are pleased to respond to the department of Business, Energy, and Industrial Strategy's consultation on Reforming Competition and Consumer Policy. CAS plays a significant role in the provision of consumer advice and advocacy in Scotland, and we recognise the significance of the proposed reforms for consumers. We welcome the UK Government’s focus on Consumer and Competition policy and the role it can play in promoting long-term economic development and consumer protection during the post pandemic recovery.
CAS welcomes the opportunity to respond to this consultation. We also welcome many of the proposed reforms, however it is essential that reform results in meaningful improvements in the consumer journey and achieves positive outcomes for consumers. We believe the consumer needs to be placed at the heart of consumer policy and would recommend that the consumer principles and the principle of “fairness by design” be used as an overarching guide to assess and inform consumer policy.
In relation to the detail of the proposed reforms CAS’s views are as follows:
• We support the granting of additional powers to the CMA but have mixed views on whether the CMA’s priorities should be informed by governmental direction.
• We wish to see a greater ability for regulators to respond to the differential impacts of competition across the devolved nations.
• We are of the view that these reforms provide an opportunity to further strengthen and enhance the function of the Consumer Protection Partnership to improve collaboration and responsiveness on consumer protection issues.
• We believe that further action is required to equip consumers with the skills and knowledge to participate in online markets safely; in this regard we support proposals to reform the use of subscription services.
• We wish to see reforms which make it easier for consumers to understand their rights and to take swifter, more effective action to enforce these rights.
• We believe there is a need for better education on consumer rights as well as a need for clearer information to be provided about Alternative Dispute Resolution (ADR) so that consumers understand what it is.
• We are of the view that the ADR landscape is overly cluttered and would support streamlining to provide for one consumer ADR provider in each sector. As a minimum, there should be a single branded entry point for people wishing to access ADR on consumer matters.
• We recommend that ADR providers should report to regulators on trends. This would close the feedback loop and help drive up standards across regulated industries by enabling regulators to take action to prevent consumer detriment.
• We would wish to see Competent Authorities play a role in setting and monitoring common standards across the sector, including in relation to how providers support vulnerable consumers.