This is Gemserv’s response to Ofgem’s Draft Consumer Vulnerability Strategy 2025.
As well as working across Health and the wider Public Sector, Gemserv is an established expert service provider within the Energy Industry. We work in a diverse number of areas, including Governance, Consultancy and Digital Innovation. Our interest in addressing vulnerability comes from two areas: firstly, through our role in managing the Electricity Central Online Enquiry Services (ECOES), where we have been working with industry colleagues to develop improvements in how the Priority Services Registers (PSR) can be used to track vulnerable consumers; and, secondly, through or work in information security and data protection, where vulnerable consumers are in particular need of additional support.
Having clear themes and outcomes focused on vulnerability and affordability is an essential part of the strategy. We agree with those identified by Ofgem and have several ideas regarding steps that can be taken towards achieving these. The Energy Market needs to be unified and we would echo the call for each company working in the market to have a ‘vulnerability champion’ on their board. We need to ensure this issue has sufficient focus at a senior level, in order to make progress quickly. However, we would add that qualification for this role is not restricted to those with specialist expertise and/or knowledge. It is possible that individuals with the right intent can acquire the right aptitude with suitable training and support.
For a number of consumers, energy bills make up a significant amount of their household spend, and it does not take long for a change in circumstance, such as illness or redundancy, to have a negative impact on these households and for them to find themselves in arrears. Affordability is central to this scenario and we agree that it needs the focus and coordination of government, as well as cross-party and industry collaboration. We see Ofgem as having an active role in raising the profile of this issue with government and market participants. This is another area where having vulnerability champions at Senior Executive level, with decision-making authority within companies, can aid government.
Gemserv strongly believes in innovation for all and the Energy industry needs to work better together to ensure consumers do not get left behind, regardless of their circumstances. This sentiment was shared by many attendees at the recent Utility Week Consumer Vulnerability Conference, as was the frustration at the pace of change to date. In many ways, the energy industry has traditionally been slow to innovate; and we need to do more to accelerate the introduction of new practices and systems, especially, when of these already exist in other sectors.
To read our full response please click the link below:
Please do not hesitate to contact us if we can support you in your work, share our thoughts and ideas and answer any questions you may have with regards to our response.