From crisis to opportunity: a new era for vulnerable consumers
Johnny Timpson OBE’s keynote speech from Utility Week Consumer Vulnerability & Debt Conference 2025 on 18 September 2024.
Hello, good morning and I add my own welcome to today’s Utility Week consumer vulnerability and debt conference.
I’m Johnny Timpson and, in addition to information about me in the bio provided by our hosts, I additionally chair essential regulated sector vulnerable customer support specialist MorganAsh and sit on the TrustMark warm homes scheme consumer protection panel. I have spent over twenty-five years liaising between charities, consumer groups, self-help groups and government bodies to improve consumer understanding, access, inclusion, value, service and support – plus, importantly, working to ensure that vulnerable consumers enjoy the same outcomes as anyone else.
My remarks today will focus on our need to be smarter and more joined-up on regulatory policy and practice, along with data-sharing – all to improve vulnerable customer interventions and support – together with the need to be passionate and hold ourselves, as vulnerable customer support professionals, to account in doing so.
With Ofgem announcing a 2% increase in the energy gap from October 2025, and the regulator’s refreshed consumer strategy now live, with a broader update on the regulator’s debt strategy awaited, our coming together here, today, to discuss and share how we can improve both the identification of, and support for our vulnerable customers is timely – with the need to be both innovative and proactive in delivering tailored solutions and support more pressing than ever.
The urgency is underlined by Uswitch saying that the UK is in an energy debt crisis; the average arrears for a gas and electricity customer is now over £1500 – this is where there is no time to pay arrangements in place and is only slightly less than this where there is.
On top of this, GPs and medical professionals in primary care, the gateway to our NHS, report that around 23% of their caseload – and increasing – is either caused by, or compounded by, financial health issues such as “how do I pay my gas/electricity bill and still meet my rent and other bills?” I took the very same social prescribing course as GPs, who told me that they feel more like advisers on debt, welfare benefit, housing, energy, water and finance as opposed to being medical professionals.
It’s past time for all of us in essential regulated sectors to realise, and respond to, the fact that when we fail our vulnerable customers, their support needs remain; this drama then becomes a multi-agency and pan-regulated sector crisis – with our NHS increasingly having to pick up the pieces.
I warmly welcome the leadership that is being taken by Ofgem and the Financial Conduct Authority – and that this has been stepped up over the last two years. This is particularly true since, in my experience, and no matter the sector, regulation is always playing catch-up when we are seeking to protect consumers from foreseeable harms. Therefore, regulation should be the beginning of our help for vulnerable customers, not the extent of it.
There is both a need and a commercial benefit to going beyond what regulators want – and to provide better and more targeted support. Let’s not kid ourselves, at the moment essential regulated sectors don’t do this particularly well – and we struggle to even identify those customers in need of support. On top of that, we make it difficult for those with support needs to engage with us. This, despite the fact that energy bills and billing have been with us since 1883!
I’m delighted to see Ofgem acknowledge that strides have been made in data-sharing, particularly between energy and water firms. This said, we need to go much further and far faster. For me, and for my colleagues across essential regulated sectors, who assisted the development of the recently published Money Advice Trust’s data-sharing principles, we should strive for a common vulnerable customer definition, lexicon, red flags and staff training. It’s great to see Ofgem, the FCA and Ofwat in this space, calling on Government – and other parties – to discuss on how this can be done.
The increasing needs of our vulnerable customers, and the regulations to help support them, spring from customers being exposed to foreseeable harms: customers in crisis; customers receiving ‘bad outcomes’ or being treated unfairly. Back in 2013, Ofgem was the first regulator to recognise the growing vulnerable customer support need – with the financial services sector quickly following – and, whilst today essential regulated sector firms are responding, we must challenge ourselves and ask: does our response go far enough – and are we missing what could be a significant opportunity to make a difference?
What does this ‘opportunity’ look like in practice? How do we move from simply identifying a vulnerable customer, to providing a truly segmented, personalised, meaningful and sustainable solution – supported by understandable communication and inclusive engagement channels?
Let’s consider a common and difficult scenario in the energy sector: an elderly homeowner, perhaps living, like me, with a disability – who is in fuel poverty. They are asset-rich, having owned their home for decades, but cash-poor; they may be getting Warm Home Discount, a warm homes local grant or WaterSure support. They face the daily, stressful dilemma of choosing between heating and eating. They don’t know what to do, who to turn to, are scared of being scammed – and, as a consequence, seek support from a trusted source … hence the growing financial worries and stress caseload experienced by GPs.
The current approach is fragmented. Consumers are stuck – like a pinball in a bewildering maze of different organisations, having the same stressful conversations over and over. The data is siloed, and so are the solutions.
This is where the real opportunity lies: an opportunity to build a more holistic and supportive ecosystem.
Imagine if, with the customer’s explicit consent and control, we could securely link the data from their energy account with anonymised data from their financial and property assets. This isn’t about sharing data for its own sake; it’s about using it to be proactive – and to unlock a profoundly better outcome.
It would allow us to architect entirely new and innovative solutions. This could, for example, be a smarter and tailored time to pay, or a properly regulated financial instrument that empowers that homeowner to use a small fraction of their housing wealth to create a dedicated, ring-fenced ‘energy guarantee’. Or perhaps a protected fund that automatically pays their energy bills directly to the supplier – and the capital for the solar panel installation.
For the consumer, the benefits are transformative. Their fear, anxiety and distress are reduced and hopefully completely removed. Their dignity is preserved, and they can stay warm and safe in their own home.
For the utility provider, this is a game-changer. It moves beyond the endless cycle of forbearance and debt collection. It creates a secure, predictable payment stream, reduces arrears, and forges a genuinely positive, long-term relationship with the customer.
This is the very essence of what the UK Government and regulators are looking for: market-based innovation that provides more personalised, more sustainable, and more dignified outcomes than simply ticking the ‘meeting the regulations’ checkbox. This is what it means to truly move from crisis to opportunity: using data to build bridges between sectors – and create holistic solutions that empower consumers and change lives.
We need to use customer vulnerability data in a much more meaningful way – simply mining data to identify all those over the age of 65 may meet the PSR’s regulatory target – but it is a long, long way from where we can get to. AI both offers, and is giving us, fantastic opportunities, although yes – it must be used cautiously. Andrew Gething, my CEO from the digital vulnerability management firm MorganAsh, coined a saying: “If Amazon did vulnerability, they would call it personalisation”. This perfectly captures the opportunity of vulnerability. For example, firms are now using the personal profile information captured for vulnerability to power personalised AI-driven phone calls – massively reducing the prohibitive cost of agents chasing debts.
And, ever mindful of Uswitch’s energy debt insight and call to action, I look forward to Ofgem’s broader debt strategy update – and 100% agree on the need for further consultation on the following:
Improving customer trust and engagement, to ensure better support and debt outcomes for individual customers and for the sector – particularly where customers are vulnerable and facing hardship.
Ensuring a controlled, consistent and compassionate approach to credit – and the exploration of differing payment methods, plus reviewing how and when financial support should be offered to customers.
Tackling system inefficiencies and incentives to ensure that consumers are both supported and encouraged to pay their bills – plus improving relationships with debt advice agencies, with this critical to developing and delivering affordable repayment plans.
This echoes what is going on in the FCA’s regulated sector – notably around payment arrangements – and the water sector under Ofwat. We all recognise that the need for debt advice is growing – as is its funding – and I’m supportive of the call made in July by Clear Consultancy Services for a better funding model and new legislation to deliver it in the form of a debt funding bill.
While it is with good intentions that Ofgem and now Ofwat require the PSR, I hold that it is both far too simplistic and binary to provide meaningful data on consumers –and simply acts as a flag for further engagement. Digital vulnerability management systems now cover over three times the characteristics of the PSR – with nuanced ranges for severity of each characteristic, not just binary flags. There are systems in the marketplace – yes, from small innovative companies – that help with signposting to multiple firms, not just a handful of partners. Open Banking gives us access to transactional data and the pension dashboard coming soon will enable us to locate lost pensions more easily.
Hesitancy about GDPR, and that consumers will not provide the required data, is unfounded. I spoke with the ICO – and their overriding comment is they don’t want to stop anyone sharing data needed to help vulnerable people. Yes, there may be some technicalities to work through, but these are being worked on and will be resolved.
As utilities providers, you have a captured market, consumers have to work with you – financial services would bite off their right hand to have this type of access to consumers.
So, this is my ask of you, my call to action.
Vulnerable customer support colleagues, I ask you to share thinking and learning about what works, and what doesn’t, both with the delegates at today’s conference and your colleagues in the workplace. Let’s pledge to make a real difference for our customers.
We live in a digital world. Let’s manage our relationships and interactions better – and that’s with allcustomers not just the 50% who are vulnerable. Think about how you can engage with customers better by sharing data with other parties – with their consent, for their benefit. Grasping and making the most of this opportunity starts with good quality current personalised customer data – not a PSR tick-list.
Thank you.