Statutory Consultation - Consumer Standards

Consumer Standards - Statutory Consultation [ 180 kb]

Citizens Advice welcomes the opportunity to respond to this consultation. Ensuring that suppliers are easy to contact and improving support for customers struggling with their bills are two key challenges facing consumers in today’s energy market. These proposals make pragmatic adjustments to existing rules that address key gaps and should ensure that Ofgem can enforce higher standards. Given the ongoing cost of living crisis it is vital that these changes are in place ahead of this winter and that suppliers are held to account to deliver improved outcomes.

Firms already using best practice are likely to see little change as a result of these proposals, but there will need to be more rapid adjustments by companies with a higher appetite for regulatory risk. Ofgem must closely monitor the outcomes of these reforms to ensure those most in need can access the support they require, including those who need to communicate in a language other than English.

Adjustments to ensure more proactive measures for people falling behind with their bills are welcome, and should continue to tackle some of the unacceptable behaviours seen at some companies last winter. Companies will need to translate this into further work to enhance the training of frontline staff to offer support and improve their systems and processes to offer more flexible repayment schemes that meet people’s needs.

We support the use of reputational regulation to drive standards up, though its impact will depend on the evolution of competition in the market. We welcome the use of the star rating as an initial reputational indicator and look forward to working closely with Ofgem to define user needs for a new measure, designed in such a way to leverage Ofgem’s statutory powers to provide additional information for consumers.

We welcome Ofgem’s use of guidance documents as a tool to drive up standards and set out expectations for compliance. This should help firms understand regulatory risk and provide clarity over areas in which responsible innovation can drive up standards. We note that the level of prescription in the involuntary PPM installation guidance is somewhat higher than in the draft guidance on supplier contact ease. More flexibility for delivering outcomes can be valuable, but Ofgem should also use guidance to set clear expectations that firms who are unwilling to provide easy access to support will be swiftly identified and dealt with through robust compliance and enforcement action. We are particularly concerned that the guidance should give reference to other relevant rules, including the Complaints Handling Standards, and set clearer expectations around access for people who are digitally disadvantaged and the role for telephone services.

In the coming months we will continue to use our data to track the impact of energy supplier processes and decisions on the consumers we support, and work with Ofgem as it seeks to identify and tackle poor practice.