2025 Vulnerability Commitment Good Practice Guide

Contents

Introduction

Vulnerability Commitment key facts

Approach and membership

The Advisory Board

Themes

1. Role of the Vulnerability Champion

Additional insights on Digital technology, AI and data

2. Data collected on vulnerable customers

3. Data collected from front-line staff

Next steps

Glossary

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Introduction

Welcome to Energy UK’s Vulnerability Commitment Good Practice Guide 2025. This shares our findings from its fifth year. This report is one element in our programme to drive continuous improvement of support to customers in vulnerable circumstances. It showcases good practice from commitment signatories to help suppliers learn from each other and to further transparency with stakeholders about how suppliers are evolving their services. We have also encouraged critical friends to offer challenge and create opportunities to develop further.

Last year’s report noted the changing landscape with a new Government determined to address fuel poverty, a refreshed Vulnerability Strategy from Ofgem, and ongoing cross-sector work to improve data sharing and to establish a multi-industry Priority Services Register. The previous Independent Chair, Steve Crabb, reported the significant progress made by energy suppliers during his four-year tenure.

I have been heartened to hear about and see the commitment of signatories – to go the extra mile and learn from others. They are doing a lot for those customers whose circumstances make it difficult for them to make the most of the fast-evolving energy market.

That said, there is still much more to do. We have seen that things this year are tougher than ever. Customers face many challenges, such as disability, mental health issues, ageing, complex home lives, and financial difficulties. Energy bills are still high. Energy debt is a major concern, and both the number of people in debt and the amount owed are increasing, especially among the most vulnerable. Ofgem reports that total energy debt has grown to £4.4 billion, up from under £1 billion in 2021 and having risen £740 million in the last year alone. Likewise, suppliers report that the number of customers on the Priority Services Register (PSR) is growing. Customer satisfaction with energy suppliers among those facing financial hardship has shown clear long-term improvement but is still below the record levels seen for other groups.

Our 13 signatories, the energy suppliers, are diverse. They are different sizes, have different customer bases, different regional focusses, and different product profiles. Some specialise in pre-payment meters, others in renewable tariffs. The proportion of customers on suppliers’ PSRs range from 15% to 50%. They are at different stages in their adoption of technology and different in the range of low carbon services they offer.

Without exception, their Vulnerability Champions affirmed their commitment to keep listening, measuring and improving their service to customers in vulnerable circumstances. They all want to cooperate with policymakers, Ofgem, charities and consumer groups, Local Authorities and other stakeholders.

This year’s three themes – the topics into which the Expert Panel took a ‘deep dive’ to assess how well participating energy suppliers are honouring the principles of the Commitment – demonstrated that ambition vividly.

Proactively treating each customer in vulnerable circumstances as individuals: We examined how suppliers personalise their support by having accurate and relevant data on customers’ circumstances, tailoring approaches, being accessible and communicating early, and having trained, empathetic and supported staff. Many are exploring using AI and third-party data to guide staff and streamline processes, although much of this work is in early stages. Some suppliers have specially trained teams, dedicated partnerships, or even in-house social workers to support customers in vulnerable circumstances.  

Delivering outcomes that address both the acute and enduring challenges faced by customers in vulnerable circumstances: Support begins with delivering and assuring good service. Leading companies clearly define their objectives, assess outcomes in a timely manner, and analyse performance for specific customer cohorts. They provide accessible communication channels and track metrics including debt levels, debt clearance, service delivery, customer satisfaction, and complaints. Suppliers combine aggregate measures with examples of positive impacts on individual households and are exploring ways to help vulnerable customers access and benefit from low-carbon solutions.  

Demonstrating how the Vulnerability Commitment is used to drive performance and improve outcomes for people and households in vulnerable circumstances: Leading companies have active engagement from a senior Vulnerability Champion and are committed to working with NGOs, charities, and peers to improve performance. While teams celebrate their achievements, all emphasised the value of more cross-industry sharing of experience and good practice. This remains a priority as the Vulnerability Commitment continues to evolve in 2026. 

We heard from many suppliers that there is a real challenge in engaging early enough with customers – being sufficiently attuned and trusted to be able to help before things have spiralled out of control. They have tried local, in-person events, partnering with local authorities and charities and use of a range of other digital channels. Despite these efforts driving some improvements, there is still a structural market gap in engagement.

The other plea we heard time and again was for clearer guidance in prioritising effort and activity. Faced with a growing wave of potential needs (the expanded Warm Home Discount, the growing numbers on their Priority Services Register and rising energy debt), they are looking to policymakers, regulators and community groups to help them make the best impact with their resources as well as looking to share best practice across the industry. It is to be hoped that the Government and Ofgem will hear this as they look at the future evolution of the retail market and policies to support people in vulnerable circumstances.

The Commitment has also evolved the membership of its Advisory Board; you can find the full list on page 6. I would like to thank this group for their wise counsel on the key challenges and areas of focus for our work.

In addition to the members of the advisory board, I’d like to thank:

• Alex Belsham-Harris of Citizens Advice and Dhara Vyas of Energy UK for their tireless work as members of the Expert Panel that scrutinised participating suppliers.
• Rosie Nurse of Energy UK for her outstanding work managing the Commitment this year. She has been critical to its success.

I’d also like to thank the 13 energy suppliers that are currently participating in the Commitment for their hard work on behalf of customers who need extra support, Ofgem for its encouragement and positivity towards this voluntary, industry-led initiative, Steve Crabb for his stewardship of the commitment, and Energy UK for the leadership it has shown since the Commission on Customers in Vulnerable Circumstances was first conceived.

Paul Spence

Independent Chair of the Vulnerability Commitment

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Vulnerability Commitment key facts

Approach and membership

In 2025, the Vulnerability Commitment had 13 signatories, covering more than 95% of the domestic UK market. Compliance to the Code is confirmed by a signed statement from the board-level Vulnerability Champion at each participating supplier. This is backed up with a detailed Request for Information giving evidence of compliance on 20 specific commitments, and Expert Panel hearings to challenge suppliers individually on three areas:

• Proactively treating customers in vulnerable circumstances as individuals 
• Delivering outcomes that address both the acute and enduring challenges faced by customers in vulnerable circumstances 
• Demonstrating how the Vulnerability Commitment is used to drive performance and improve outcomes for people and households in vulnerable circumstances

This year’s deep dive topics were finalised with input from the Advisory Board, reflecting those areas where the Board would like to see suppliers focus their efforts. The Board met throughout the year to scrutinise and challenge the work of the Vulnerability Commitment. It also reviewed the specific commitments made by suppliers to ensure these remain relevant to consumers.

The Expert Panel heard many examples of good practice from signatories this year. As well as delivering on the 20 detailed requirements, all 13 signatories had much to say on the year’s three key themes. Many gave impressive examples of continuous improvement and innovative, forward-thinking approaches to help customers in vulnerable circumstances in a variety of areas. While there are many of these examples we could have included in this report, we have chosen to highlight a selection we hope will be valuable to share across the sector.

The Advisory Board

Paul Spence I Independent Chair I Energy UK Vulnerability Commitment

Dhara Vyas I Chief Executive I Energy UK

Alex Belsham-Harris I Head of Energy Consumer Markets I Citizens Advice 

Lauren Kennedy I Senior Policy Manager I Ofgem

Ed Dodman I Managing Director and Chief Ombudsman I Energy Ombudsman  

Louise Walsh  I Chief Customer Contact Officer I Utilita

Julia Lynch-Williams I Policy Director | E

Katie Orme I Head of Service for Social Work I Octopus 

Niall Cave I Policy Lead | DESNZ

Chris Fitch I Vulnerability Lead I Money Advice Trust

Matt Copeland I Head of Policy and Public Affairs I National Energy Action

Anthony Pygram I Member I Committee for Fuel Poverty

Matthew Cole I Founder I Fuel Bank Foundation

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Themes

The first theme that the Expert Panel wanted to hear about was how suppliers are proactively treating their customers in vulnerable circumstances as individuals. Vulnerability looks different from one household to the next, so knowing and understanding each customer’s individual needs is vital to providing effective support. This means staff being equipped with accurate and relevant data, tailoring support to the person rather than the process, and having teams who are trained, empathetic, and properly supported to respond effectively.

Many suppliers emphasised the importance of early intervention in supporting customers in vulnerable circumstances so the right help can be offered at the right time and future crises can be avoided. Many companies referenced improvements to their websites or apps to allow customers to self-serve and update their PSR information. E said that circa 81% of its customer base now have a smart meter, which means it can use data from smart prepayment meters to help it identify when a customer is about to self-disconnect or has self-disconnected, prompting advisers to reach out via various communication channels including text or email to connect with the customer.

Making it easy to get in touch to support early communication is a priority for E. Its teams ensure that calls are on average answered within one minute and all emails receive a response within 24 hours. Customer feedback has also shaped E’s approach to engagement. It reported that customers found video calls particularly helpful for discussing practical issues like meter resets or accessing emergency credit. E has since equipped all advisers to offer video calls as part of its standard approach.

Several suppliers spoke about their customer-first approach for call handling and customer engagement, prioritising meaningful support over strict call length targets. Rather than focusing on metrics such as average call length, suppliers emphasised the importance of giving customers the time and attention they need, even if that can take a long time. Utilita, for example, has removed the hard metrics around average call time to allow advisers to concentrate on supporting the customer and resolving the issue as effectively as possible. Good Energy also reflected this ethos when speaking about its in-person engagement. The length and remit of these home visits have grown in the last couple of years, enabling advisers to provide more comprehensive and tailored support.

Utilita told the panel about the development of its high street hubs across the UK, where anyone, including non-Utilita customers, can drop in, to talk about energy or non-energy related topics. It recognised that providing free, welcoming community spaces can help to reduce social isolation and build trust as well as giving people opportunities to engage who may otherwise be reluctant.

All suppliers emphasised the importance of ensuring their frontline staff are confident and well-equipped to identify and respond to vulnerability. At many of the hearings, the Expert Panel heard from customer service representatives about the training, guidance, and support they receive and how this enables them to tailor their interactions and provide empathetic support to customers in vulnerable circumstances.

Outfox Energy told the panel that it employs a strong ‘Know Your Customer’ ethos when training its frontline staff and sharing learnings across teams. Training emphasises lived experience and practical readiness, with workshops and quality assurance checks used to make sure that its staff are fully prepared to support a wide range of customers. Case studies are incorporated to build empathy and understanding. Staff are also able, at their own discretion, to share their lived experiences to further enhance learning and encourage a customer-focused culture.

Utility Warehouse reported that it has invested heavily in trained, in-person frontline staff to provide tailored support. It is also exploring digital self-service routes, such as online surveys, to support these staff and its customers by simplifying information collection. So Energy highlighted that its learning and development team are required to attend a specialist third-party vulnerability course, which focuses on identifying and understanding vulnerabilities, including those that cannot easily be picked up on over the phone. Its customer service representative reported that this training has improved their advisers’ confidence and given them practical tools to come across more naturally when speaking with customers.

Similarly, Ecotricity has its frontline staff complete training-led workshops and has had more than 200 of its staff receive the Vulnerability Annual Certificate following training as of early 2025. In addition, recognising that some of its workforce includes people with neurodivergence, Ecotricity has developed a leadership programme around managing people with different needs.

E.ON Next runs affordability and vulnerability ‘mini businesses’ with around 200 people in the debt team, supported by 40 vulnerability experts. A four-week training programme creates clear specialist pathways, helping advisers develop expertise and confidence in supporting customers facing both financial and non-financial challenges.

Octopus told the Panel that its culture is built around trust in its energy specialists, which comes from the confidence that staff are well-equipped and trained to make informed decisions when it comes to treating each customer individually. Each Octopus energy specialist receives training from their first day and can choose to train further to become an expert in either financial or non-financial vulnerability.

All suppliers spoke about how their online tools can help to enhance personalised support for vulnerable customers.

ScottishPower presented on the development of AI tools designed to enhance staff training and provide real-time support for more tailored customer interactions. The Ask Bruce AI assistant allows customer service teams to receive instant answers to queries and support information during calls. Alongside this, Call Copilot provides agents with real-time guidance by transcribing live conversations and prompting agents on key actions. It emphasised the value of the teams’ feedback on the development of these tools and reported that the reception has been overwhelmingly positive.

The Expert Panel heard from multiple suppliers about the importance of signposting and referral partners to help provide further tailored support to customers in vulnerable circumstances. Sometimes a customer’s individual circumstances go beyond energy matters and can require a more holistic approach than a supplier alone is able to offer. Partnerships allow customers to access specialist advice and services to meet their individual needs. All suppliers signpost to Citizens Advice and StepChange, while several signpost or refer to Age UK, Scope or Christians Against Poverty.

EDF emphasised its approach to partnerships and highlighted itspartnership with TellJo. Through this EDF proactively offers support to disengaged customers through a digital wellbeing check, providing them with a safe and confidential way to share personal challenges if needed. As a result of this partnership, EDF has been able to set up more than1,000 repayment plans, valued at more than £1 million, to help customers manage debt.

Following its participation in the Outside In project, facilitated by Three Hands, EDF reviewed and enhanced its approach to inclusive design, PSR identification, and communications with vulnerable customers. EDF has also engaged directly with customers, carers, and family members affected by dementia through a live insight session with the Alzheimer’s Society. Insights from the session informed the development of tailored customer journeys for people living with dementia, including regular updates and communications.

Similarly, Ovo has partnered with Lightning Reach to bring together its customer support schemes with thousands of partner programmes into one clear pathway. This approach reduces the need for customers to repeatedly share sensitive information or navigate multiple referral routes, making access faster and simpler. In addition, Ovo has signed up to the Experian Support Hub trial, which offers customers a ‘tell us once’ approach, further streamlining the processes for support.

British Gas also demonstrated broad commitment to partnerships to improve outcomes for vulnerable customers. It has significantly expanded access to its dedicated vulnerability phone line, increasing the number of charity and advice partners with direct access from five to 45 organisations, enabling faster and more efficient support. As a result, calls to the priority line are now answered, on average, in under 30 seconds. Alongside this, British Gas continues to work closely with 43 organisations within the British Gas Energy Trust network which has strengthened its collaboration across advice and charity sectors.

Customer debt in the energy sector has continued to rise, placing many households under severe financial strain. The Expert Panel was keen to probe how suppliers take an outcomes-focused approach to helping their customers in debt.

In addition, the Panel wanted to hear about how suppliers are helping their customers in vulnerable circumstances access low-carbon solutions and ensure they are reaping the benefits of their adoption. As the energy system decarbonises, it is important that suppliers are confident that none of their customers are not left behind.

British Gas detailed how its ‘You Pay, We Pay’ scheme has developed since the launch last year. The scheme matches any payments that a customer makes towards their debt over a six-month period, with no minimum or maximum threshold. British Gas told the Panel that its consumer group and charity partners have shown support by signing customers up to the scheme, boosting its impact. British Gas continues customer engagement after the end of the six months to maintain the payments and offer lasting support. At the time of the panel hearings, 14,000 customers had been supported through this scheme and £9.65 million paid by British Gas in matched payments.

The Panel also heard from British Gas about its PeakSave programme, which helps its smart meter customers save money while helping to balance the energy system by using less electricity at peak times. It is proactive in letting customers know in advance when they can take part so they can maximise opportunity to save. It has now also introduced PeakSave Green Flex events, which allow participating customers half-price electricity when it is expected that lots of renewable energy will be available.

Similarly, Octopus also spoke about its ‘You Pay, We Pay’ initiative and how this has led to re-engaging otherwise disengaged customers. Octopus found that this initiative has made a tangible impact on getting people out of debt and maintaining their payments. Octopus recognises that energy issues often overlap with a wide range of social challenges. It employs social workers who provide frontline staff, credit specialists, and others in the team with guidance to respond effectively to complex customer needs, enabling Octopus to take a holistic approach to customer support rather than focusing solely on energy debt. With customer consent, they can engage directly with them through home visits and make onward referrals when appropriate.

Octopus also told the Panel about its targeted decarbonisation offers, which includes the Warm Home Discount solar scheme. This is a data-driven, invitation-only scheme, which focuses specifically on customers in or at risk of fuel poverty and who have chronic health conditions as indicated on their PSR. Smart meters enable outcomes to be monitored, and advice is tailored from the start to encourage the uptake of solar and battery packages together to maximise savings and resilience.

E.ON Next described how its Winter Support Scheme used data-led operational campaigns to ensure that all eligible customers were contacted at least four times through multiple channels, helping to increase engagement from 12% to 32%. Around 200 specialists used PSR and affordability data to target support, providing £70 million to 31,000 customers in 2024/25. Smart meter data and wellbeing assessments were also used to identify risks early and offer tailored interventions including debt relief and practical support such as the provision of essential household items.

The Expert Panel heard from Ovo about its Extra Support package, aimed at customers already in or at risk of fuel poverty. The package has now evolved to become a centralised hub after feedback showed that customers found multiple referral routes difficult to navigate. Over the past 12 months, more than 40,000 customers have received help through this pathway, including 30,000 energy saving products. Alongside this offer, Ovo has taken a more community-focused, place-based approach to reaching hard-to-engage customers. It launched its first Ovo in the Community event in Newport 2024, bringing together trusted local voices to build awareness and connect with people to offer practical support.

The understanding that effectively addressing fuel poverty begins with reducing household energy consumption is at the heart of EDF’s delivery of outcomes for enduring challenges faced by vulnerable customers. EDF uses a variety of data sources, including Department for Work and Pensions data matching, Energy Performance Certificate ratings, and PSR indicators to ensure it maximises every opportunity to promote available energy-saving measures. An example that EDF shared is its partnership with SHINE, a north-London based initiative, through which Energy Doctors are equipped with thermal imaging cameras to pinpoint heat loss and deliver practical improvements such as draught excluders, secondary glazing film and reflective radiator panels. Following the success of this initiative in 2024, EDF is planning to expand its approach further for winter 2025.

E told the panel that it has built a system in which communication with meters is reliable, with circa 98% of smart meters operating in smart mode, and issues can be identified and resolved quickly. This is particularly important for E’s customer base, which is largely prepayment customers, as acute challenges can relate to a loss of supply or top-up problems – potentially leading to serious consequences. As E’s customers can report issues quickly, E can then act promptly to restore service and prevent potential hardship, with 80% of complaints resolved within a day and 100% within eight weeks.

Utilita spoke about its data-driven approach to helping its vulnerable customers, including those in, or at risk of, debt. Various aspects of customer interaction are measured, including silent times on the calls, to ensure that advisers communicate clearly, and customers always understand what is going on. Data from billing systems and Additional Support Credit is reviewed, allowing the Extra Care Team to identify customers who may benefit from further support, including energy efficiency measures. With more people now relying on Additional Support Credit, Utilita helps customers minimise the impact on debt by signposting to income maximisation services and debt charities.

Several suppliers spoke about how they work with government and industry stakeholders to help inform the design of long-term, evidence-based policies for supporting customers in vulnerable circumstances. For example, So Energy spoke about its collaboration with BFY on the Warm Homes Support Scheme report, which analysed the true extent of the fuel poverty crisis and provided actionable recommendations on improving fuel poverty interventions.

Many suppliers have been proactive in hosting and participating in local and national events to raise the profile of issues and identify practical solutions. Ovo described initiatives such as the Vulnerability Data Sharing roundtable, which explored how firms can work together to better serve customers, and its Glasgow Disability Summit, held in collaboration with Scope, which looked at financial challenges faced by disabled households, and led to a follow-up Caseworker 101 workshop.

ScottishPower presented on its work on improving operational performance, including delivering good outcomes on billings and complaints. It has daily billing checks and automated controls to help flag and resolve anomalies quickly, ensuring accuracy and consistency for customers. Scottish Power is proactively engaging with customers at risk of hardship, including a £25 low balance alert with a simple route to access further financial support. ScottishPower also highlighted its ongoing partnership with Plain Numbers, focused on ensuring customer communications are clear and accessible. This initial three-year partnership establishes accredited Plain Numbers Practitioners within ScottishPower to improve the clarity of bills and other communications.

Several suppliers shared with the Expert Panel that they take a flexible, tailored approach to supporting customers in debt, including actions like extended repayment terms and face-to-face welfare visits to ensure that support is responsive to each customer’s circumstances. Utility Warehouse said it does not follow one single process when it comes to debt. Instead, outcomes are shaped by a combination of policy requirements, staff training, and ongoing customer communications. Good Energy also emphasised the importance of sustainability of debt plans. It prioritises repayment plans that customers can maintain over time, and it proactively reaches out when payments are missed to prevent escalation. Similarly, Ecotricity emphasised re-engagement when supporting its customers in debt and spoke about how its partnership with ReachOut, a support service specialising in debt and affordability, is helping to engage its hard-to-reach customers. Ecotricity also spoke about how it has support available 24 hours a day and has extended its call hours in recognition that speaking with an agent can be beneficial for customers seeking support for challenging situations.

Outfox Energy described how it works closely with customers to design repayment plans that reflect individual needs, with flexibility on repayment plans for households who need it. Through a trial with Haste Metering Services, which has a specific focus on vulnerability, Outfox has introduced face-to-face welfare visits, typically involving at least two visits to build a fuller picture of customers’ situations and identify appropriate forms of support.

This theme was chosen to explore how suppliers use the Commitment to drive performance and improve outcomes for customers in vulnerable circumstances. The Panel was particularly interested in how suppliers are sharing learnings and using insights from partnerships with NGOs, charities, and other suppliers to drive continuous improvement and innovation in support. The Panel also wanted to hear about how the Vulnerability Champions play visible leadership roles in keeping vulnerability on the agenda from board level throughout the organisation.

Several suppliers told the Panel that they value the good practice sharing element of the Vulnerability Commitment, as it helps them learn from others and benchmark their own progress. Many suppliers said they have continued to develop since their 2024 panel hearing and were keen to share the improvements they have made. Some also highlighted the importance of internal learning alongside external collaboration. Ecotricity, for example, described how its internal Vulnerability Panel supports staff when they are unsure of how best to support a vulnerable customer. Ecotricity found that the presence of the panel has helped to create a culture amongst its staff where they feel empowered to seek advice on complex or sensitive cases. Ecotricity also noted a growth both in its overall customer base and the number of customers on the Priority Services Register and explained how its Vulnerability Panel and wider processes are adapting to meet the needs of this expanding group.

Utility Warehouse also described its internal shared learning process, and how it is reinforced through strong governance and a clear culture of ownership in its teams. Its long-standing Vulnerability Steering Group and the Conduct and Risk Committee provide oversight to the team and staff are encouraged to think about how to help customers do, understand, cope, and manage. So Energy also spoke about its monthly Vulnerability Working Group and quarterly Vulnerability Steering Group, outlining that the Working Group feeds decisions and insights into the Steering Group, which then reviews, assesses, and drives improvements across the organisation. E said that senior management are directly involved in reviewing customer queries when things go wrong, and that there is a constant feedback loop with staff actively present to resolve issues.

EDF spoke about its focus on building its staff’s skills internally and sharing its knowledge and support available to customers across the energy community. Its Skills Academy allows each energy specialist to complete a foundation course and then progress to become an expert in certain areas. There are seven disciplines available with affordability and vulnerability deemed as the most important one.

As well as this, EDF described its Debt Expos, which will be held across three of its major sites. These showcase the work currently underway and outline the planned support initiatives for customers this winter. These events also give EDF’s customer facing teams the chance to engage directly with their partners and gain key insights into the challenges currently faced by customers.

There were several suppliers that spoke about the role of their Vulnerability Champion in ensuring that care for vulnerable customers is embedded throughout the organisation, from board level to frontline staff. Outfox Energy shared that its Vulnerability Champion leads best practice sharing after each Energy UK vulnerability sub-committee meeting.¹ At both Good Energy and So Energy, the CEO is the Vulnerability Champion, demonstrating leadership commitment at the highest level.

British Gas positions vulnerability as a priority across the organisation, describing how its Vulnerability Champion actively engages senior leaders through volunteering and supports the British Gas Energy Trust at roundtables focused on understanding and tackling fuel poverty. These actions are accompanied by community-focused events including outreach in Post Offices across the country and engagement with local Citizens Advice Bureaus by providing a British Gas-employed Solver to work on itspremises once a month to provide direct support to energy customers.

Likewise, Utilita described how its ethos of putting the customer at the heart of the organisation is embedded across all levels, from frontline agents to senior leadership. Its customer service leaders are the ‘voice of the customer’, challenging assumptions that a customer is not vulnerable and ensuring that each case is considered individually. Its focus on understanding customer circumstances has led Utilita to reflect on how complex energy can be for many people and to prioritise simplifying communication and processes so that customers stay engaged. As part of this, Utilita recognises that the role of customer service agents can be far-reaching and often demanding and has continued increase staff training to ensure that its teams have the skills and confidence to provide tailored, effective support.

E.ON Next highlighted the importance of partnerships and collaboration in enabling customers to engage easily and access support. It focusses on identifying and verifying financial vulnerabilities to enable personalised support and notes that addressing affordability in a sustainable way requires a sector-wide effort. It is achieving this through partnerships with organisations like the Wise Group and National Energy Action on place-based targeted debt and affordability issues.

In addition, by working with local partners, E.ON Next is testing a new initiative in Coventry that brings together debt support, energy efficiency measures, and behavioural advice to address the symptoms and causes of fuel poverty. Using data-driven targeting, its pilot focuses on low-income households in poorly insulated homes and provides energy efficiency solutions at no cost to the customer. This offers end-to-end advice and support to the customer and is delivered in collaboration with local and trusted intermediaries such as Coventry City Council and independent advice services such as National Debtline.

ScottishPower told the Panel that regular reviews of customer journeys and root-cause analysis mean it can fix issues quickly and learning is fed back into service design. Over the past year, ScottishPower has improved accessibility through extended opening hours, faster email response times, and enhanced agent training through its new AI tools. These changes have led to outcomes included reduced average call waiting times and improvement to its customer satisfaction scores. ScottishPower also highlighted its recognition of the role of trusted third parties in providing specialist knowledge on customers with specific vulnerabilities. This includes its engagement programme with Citizens Advice Plymouth, which is aimed at proactively contacting around 2000 vulnerable customers who already seek support from Citizens Advice. In addition, ScottishPower is building its relationship with Hope for You to provide further help to customers on debt journeys, including support with budgeting, affordable payment plans, and direct access to ScottishPower’s Hardship Fund.

Octopus said that being a signatory of the Vulnerability Commitment drives it to think proactively about how it can utilise partnerships to improve support for customers facing different vulnerabilities. For example, it has partnered with PayPlan to help assess and address cases where debt or household difficulties are linked to domestic abuse. In addition, after considering the potential stress and complexity that bereaved families face in managing multiple accounts after a death, Octopus has partnered with Settled to provide families with a ‘tell us once’ service that reduces the administrative burden and helps families to resolve matters more easily.

Good Energy recognised that vulnerability exists amongst micro-business customers and others on non-domestic tariffs. It highlighted that some of these customers may lack expertise in energy matters and outlined measures to support them, including proactive identification, clear and transparent communications, and signposting to the Energy Ombudsman and Citizens Advice for free, independent support.

Ovo offers multiple ways for customers to share information about any vulnerabilities and be added to the PSR, recognising that customers do not typically contact just to disclose a vulnerability, and it is usually a secondary action of a separate customer journey. Advisers across all customer-facing teams are trained to identify and record needs, with channels including calls, home visits, or at point of sale. Customers can self-serve via online forms, paper applications, or the Ovo app. Those applying for the Extra Support Package can register for the PSR at any point, and information shared through the Extra Support Hub is available in Ovo’s systems.

¹ Energy UK runs a quarterly sub-committee with members to support Energy UK’s policy and advocacy relating to the experiences of customers in vulnerable circumstances

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Next steps

This guide closes the monitoring phase of the fifth year of the Vulnerability Commitment, which found all participating suppliers to be compliant with its requirements. 

This year, Energy UK has been working with Paul Spence, the Advisory Board, and its signatories to review and update the Vulnerability Commitment to ensure that it is still relevant and having the positive impact it was intended to five years ago. The energy market is very different from when the Commitment was first designed, with significantly higher levels of customer debt and a much more challenging affordability landscape.

Looking ahead, Energy UK will expand the Vulnerability Commitment in 2026 to reflect the scale of today’s affordability and debt challenges. Building on recent joint work with Ofgem on debt standards, there will be further collaboration with affordability and debt stakeholders, as well as between signatories to shape and steer closer working. The aim is to improve the experience for customers in all types of vulnerable circumstances, including financial.

Glossary

Ask Bruce is an automated digital assistant that provides tailored money guidance and helps customers understand their options when dealing with financial pressures.

Billie is a digital tool that helps customers understand their energy usage and payments.

Call Copilot is an AI-assisted tool that supports advisers during live customer calls by providing real-time prompts, guidance, and suggested actions.

CARE+ is a customer support framework for suppliers to identify and assist households with additional needs.

Ensek is a software platform used by energy suppliers to manage billing, customer information, and operational processes.

Kaluza is an energy intelligence platform that helps energy companies overcome challenges and accelerate the shift to a clean, electrified future.

Kraken is the energy technology platform manages customer accounts and supports operational activity for energy suppliers.

Lightning Reach is a financial support portal that helps people find and apply for grants, local council schemes, charity funds, and help with bills via a single and secure platform.

National Debtline is a debt advice charity offering free, independent support for customers struggling with debt.

PayPlan is a provider of free debt solutions including free debt management plans.

Reachout is a proactive support service that contacts customers who may be showing signs of financial or personal difficulty, helping them access tailored assistance and third sector support.

Settled is a customer engagement tool used by some suppliers to offer structured repayment support, helping customers understand their balances and agree sustainable arrangements.

TellJo offers digital wellbeing assessments to help companies identify, engage, and support their vulnerable customers.

Three Hands is a social impact organisation that partners with businesses to gather insight from lived experts.