Protecting Vulnerable Consumers: Insights from Ofgem’s 2025 Vulnerability Strategy
Protecting Consumers Amid Rising Costs
Ahead of our Utility event on 30 April 2025, we explore the key updates from Jonathan Brearley, CEO of Ofgem, and the latest Ofgem Vulnerability Strategy. In a time of price hikes and persistent challenges, this strategy aims to protect vulnerable consumers, especially those struggling with problem debt.
Key Progress and Initiatives
- Tougher rules for energy companies to identify and support struggling customers
- Prepayment is now the cheapest method to pay for energy
- Prevention of involuntary prepayment meter installations
- Enhanced Priority Services Register (PSR) data-sharing between energy and water providers
This data-sharing framework is set to scale, improving service delivery for those most in need.
Core Objectives of the Strategy
The strategy provides guidance on how energy companies should:
- Identify consumers in vulnerable situations
- Treat them appropriately
- Embed vulnerability considerations across energy and water sectors
This focuses on consumers who are:
- Less able to represent their interests
- More likely to suffer substantial detriment
Alignment with UKRN Priorities
I support the strategy’s alignment with UKRN (UK Regulators’ Network) objectives, which include:
- Promoting collaboration
- Addressing vulnerability
- Championing effective regulation
UKRN’s upcoming Vulnerability Academy (in partnership with Money Advice Trust) will further support these initiatives.
The Priority Services Register (PSR)
Energy companies must maintain a PSR to identify customers needing additional support—such as those with medical equipment, small children, or health issues. Ofgem encourages firms to:
“Adopt a proactive and anticipatory approach, in which equality and inclusivity are integral to the design of service provision.”
Energy Costs and Debt Insights
- From April to June 2025, the average energy bill will rise 6% to £1,849/year
- That’s £9.25 more per month, and 9% higher than 2024’s equivalent cap
- While repayment accounts have stabilized, arrears without repayment plans continue rising, highlighting deeper affordability concerns
Refreshed Strategy: 3 Key Aims
- Re-focus priorities to better support vulnerable consumers
- Collaborate effectively across the sector
- Increase transparency about Ofgem’s expectations and outcomes
Strategy at a Glance
- Improving identification & smarter use of data
- Supporting customers struggling with bills
- Improving customer service for vulnerable groups
- Encouraging innovation that is inclusive
Cross-cutting theme: Collaborating with other sectors – aligned with FCA Consumer Duty.
Synergies with the FCA and Beyond
Ofgem emphasizes a collaborative, cross-sector approach. This includes:
- Learning from other industries
- Sharing non-financial vulnerability data
- Reducing the need for consumers to repeat their stories
FCA’s findings on bereavement and Power of Attorney reinforce these principles. See:
FCA Multi-Firm Review
Debt Strategy and Consumer Confidence
Following consultations in early 2025, Ofgem plans to:
- Create a Debt Outcome as part of wider Consumer Outcomes
- Introduce a Code of Practice for working with consumer groups
- Consult on affordable and flexible repayments
- Review billing and access to credit under the PPM rules
Ease of Engagement
Energy companies should:
- Be easy to contact
- Adapt services to consumer needs (e.g., language, digital skills)
- Use digital tools like AI to identify early risk and encourage disclosure
This will be discussed at the 30 April event by speakers including Chris Warburton, Martin Nielson (MEGA.AI), and Chris Fitch.
Inclusive Design and AI
- Bills must be clear and flexible
- Staff should be trained on supporting vulnerable users
- Innovation should follow inclusive design principles
- Ofgem will continue to consult on AI usage in the energy sector
Leadership Perspective
“We need to drive the energy transition and support those worst affected.”
— Jonathan Brearley, Ofgem CEO
“Our Vulnerability Strategy consolidates everything into one coherent plan to protect at-risk consumers.”
— Tim Jarvis, Director General (Markets)
Calls to Action
- Collaborate with stakeholders
- Adopt innovation to support vulnerable users
- Remove barriers to access and engagement
How Ofgem Will Monitor Progress
Theme 1 – Data & Identification
- Uptake of PSR
- Increased industry-wide data sharing
Theme 2 – Support for Struggling Customers
- Debt repayment improvements
- Bill accuracy and satisfaction
Theme 3 – Customer Service
- Clearer communications
- KPIs on engagement
Theme 4 – Inclusive Innovation
- Uptake of services by vulnerable users
- Ensuring equitable access
Appendix: PSR Needs Codes
These codes help embed actionable support into CRM systems and contact centers.
Explore the full 2025 strategy:
Consumer Vulnerability Strategy – Full Document
Other references:
Event on 30 April 2025
Topic: Financial & Non-Financial Vulnerability
Speakers: Chris Fitch, Chris Warburton, Martin Nielson, Andrew Gething, Beth Kennedy, Matt Baker, Craig Simmons, Steve Crabb
Sponsors: TransUnion, VRS, MEGA.AI
Contact for Consulting
Kevin Still MCICM
Principal Consultant, Kevin Still Consulting
📧 kevin@kevinstill.com | 🌐 Website
🔗 LinkedIn
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