Fair By Design, which campaigns on the poverty premium, published its response to Ofgem's consultation on a refreshed consumer vulnerability strategy on 28 October 20241. The energy regulator first published its Consumer Vulnerability Strategy in 2019 and has consulted stakeholders on a "refreshed and more targeted strategy" in light of changes in the energy market since then1.
The organisation said its response was made "in line with our goal of eliminating poverty premiums in the energy market"1. Its key asks include a shift in who carries the responsibility for identifying vulnerable customers:
"We believe that the onus should be on energy suppliers to identify vulnerable consumers, not on vulnerable consumers to identify themselves to suppliers, and therefore would like to see more people automatically enrolled into support they are eligible for."
Fair By Design also called for Ofgem to "commit to involving people with lived experience directly in its work", and said it would be "very keen to see not only consumer organisations, but individuals with lived experience sitting on these panels" in relation to the idea of annual supplier presentations1. It asked Ofgem to "lead by example in incorporating inclusive design into its work and encourage energy companies to do the same", and said that as a first step Ofgem should "thoroughly investigate the risks to vulnerable groups posed by the move to market-wide half-hourly settlement"1.
The response also covers payment methods, which Fair By Design said need to be revisited "in light of the imminent introduction of variable recurring payments as part of the open banking roll-out"1. The full consultation response was published alongside the summary1.
Why it matters for households
The consultation concerns how energy suppliers and Ofgem identify and support customers who are vulnerable, which includes households on low incomes or in fuel poverty. Fair By Design's central argument is that suppliers, rather than customers, should carry the burden of identifying who is eligible for support, with more people enrolled automatically1. If adopted, that would change the process by which help reaches households: instead of a customer having to come forward, the supplier would be expected to find them.
The response also raises the treatment of payment methods, at a time when variable recurring payments are being introduced through open banking1. Fair By Design has previously argued that "the way people pay for their energy should not lead to an increase in costs"1. Its other stated positions include support for reforming standing charges, with a call for Ofgem to "ensure changes genuinely benefit low-income households", and support for expanding the Warm Home Discount, with a call for "further action to reach more households in need"1. It has also said it "warmly welcome[s] Ofgem's proposal for a debt relief scheme"1.
No figures for bill impacts, eligibility thresholds or numbers of households affected are given in the published response summary1.
What happens next
Ofgem has not set out in the published material when it will respond to the consultation or when a refreshed strategy would take effect; that has not been reported1. Fair By Design's asks, including automatic enrolment into support, lived experience involvement and investigation of half-hourly settlement risks, remain proposals put to the regulator1. The wider context of how consultations work and how consumers can take part is set out in our guide to consultations and discussion papers, within the regulation and policy section.
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