Response to Ofgem’s consultation on Standards of conduct for suppliers in the retail energy market
We are supportive of Ofgem’s proposals to strengthen the Standards of Conduct and add two new principles. These changes put the responsibility firmly on suppliers to achieve good outcomes for all their customers across all areas of the business. Ofgem will need to ensure its compliance monitoring and enforcement activities keep pace with these changes. Data and insight from across the Citizens Advice service will provide useful information about the performance of individual suppliers.
The introduction of a broad, enforceable vulnerability principle emphasises that energy suppliers, as an essential service provider, have special responsibilities towards vulnerable customers. We think this is an important step forward in protecting vulnerable consumers. While we agree broadly with the proposed approach, we think Ofgem needs to do more to make it clear to suppliers what is expected of them. We recommend providing guidance alongside the licence condition. This should explain the policy intent, as set out in the consultation document, and clarify a number of other points, as detailed in our response to question eight. In addition, we would like Ofgem to produce a short statement in Plain English setting out suppliers’ obligations towards vulnerable consumers. This would help suppliers and consumer groups to use the vulnerability principle on a day-to-day basis, particularly at the frontline level.
Finally, Ofgem will need to monitor compliance with the vulnerability principle very closely in order to ensure it delivers the right outcomes for vulnerable consumers, and take swift action where it does not. This should include detailed assessments of supplier policies and processes to ensure suppliers have considered and mitigated the different risks for vulnerable consumers across the business, before substantial and systemic detriment occurs. We will be happy to work collaboratively with Ofgem on this piece of work.
We have responded to all the consultation questions.