Publications

Citizens Advice Scotland (CAS) has served as Scotland’s designated consumer advocacy body for postal services for the past 8 years. From 1 April 2022, this function will be transferred to Consumer Scotland. During our time as the consumer advocate, we have made sure that the voice of Scottish postal consumers has been heard by regulators and service providers alike. Our work has been focused on making postal services accessible and affordable for all consumers, no matter where they live, or what their income level or personal characteristics may be.

This briefing highlights the key issues facing postal market consumers in Scotland today.

This briefing summarises the key findings of research conducted by YouGov in November 2021. The polling reflects the experiences of 500 senior decision makers in small to medium enterprises (SMEs) in Scotland.

The Fuel Poverty (Targets, Definition and Strategy) (Scotland) Act 2019 requires the Scottish Government to publish a fuel poverty strategy, outline what steps will be taken to meet fuel poverty targets and identify the characteristics of households likely to be in fuel poverty or for whom getting out of fuel poverty presents particular challenges.

The Citizens Advice network in Scotland gathers demographic data on those who contact their local Citizens Advice Bureau for support as well as information on the types of issues on which people seek advice, including fuel poverty. This demographic data allows for examination of CAB clients who have protected characteristics and whether they are more or less likely to seek advice on fuel poverty-related issues.

This report analyses that data within the policy context, considers other relevant literature, and makes a number of recommendations.

In May 2019, The Scottish Government committed to establishing an independent Energy Consumers Commission (ECC) to enhance the voice of consumers who reside in Scotland within the energy market. The Commission was formed in July 2020 consisting of representatives with a wealth of experience in national consumer advocacy and advice bodies, academia and local groups serving energy consumers in their communities.

The Priority Services Register (PSR) is a record held by energy suppliers and network operators which enables them to provide additional support services to consumers in vulnerable situations.

Ofgem practices principles-based regulation in relation to vulnerability, and although suppliers and network operators broadly determine who can benefit from their PSRs, a level of consistency is ensured across the industry by a common framework of needs codes and vulnerability flags.

Previous research has found that the strength and depth of priority services, and those they seek to support, varies both between different PSR holders, and across different parts of Great Britain.

This briefing, based on research commissioned from Changeworks, examines how experiences of the PSR vary in Scotland in the context of the COVID-19 pandemic and the early stages of the transition to low carbon heating and electric vehicles. It also summarises the Commission’s recommendations on how the services offered and/or the range of vulnerabilities provided for under PSRs and other energy industry vulnerability initiatives can be improved.

In May 2019, The Scottish Government committed to establishing an independent Energy Consumers Commission (ECC) to enhance the voice of consumers who reside in Scotland within the energy market. The Commission was formed in July 2020 consisting of representatives with a wealth of experience in national consumer advocacy and advice bodies, academia and local groups serving energy consumers in their communities.

Eradicating fuel poverty has been a policy priority for the Scottish Government since 2016, and has been a statutory obligation since the passage of the Fuel Poverty (Targets, Definition and Strategy) (Scotland) Act in 2019. While fuel poverty has been formally defined since 2019, and a fuel poverty strategy is expected in 2021, fuel debt has not been given the same attention by researchers and policy makers.

Fuel debt is likely to become more prevalent and more unmanageable this winter as energy prices rise, and financial support such as the £20/week Universal Credit uplift and furlough end. This briefing, based on research commissioned from Changeworks, examines how fuel debt differs from fuel poverty, what key issues exist in Scotland, and the Commission’s recommendations on how to address rising levels of fuel debt.

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. 

Executive Summary

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.

This briefing sets out the results of research conducted on CAS’s behalf by YouGov, in April 2021, using a representative sample of the Scottish population aged 18 or over. The sample size of respondents was 1,029.  This research focused on understanding consumer usage of postal services in Scotland, and it included questions regarding affordability, usage, surcharge and other issues covered by the Universal Post Service.

In April 2021, Citizens Advice Scotland commissioned a survey of 1000 adults from YouGov. The survey was aimed at gauging consumer knowledge of, and engagement with the subjects of energy and water efficiency, climate change, and low carbon heating. The findings and analysis of this work are available in our Consumer Voices report which can be downloaded at the link below.