Consumer Vulnerability Strategy Refresh CAS response

Key reflections on the Vulnerability Strategy

• There is no time to waste deliberating extensively over the definition of vulnerability – the priority of the regulator must be focused on tangible action to improve outcomes for consumers.
• Improved data collection needs a sector-wide agreement on what data is needed and a “one size fits all” approach to the data collected so it can be mapped across suppliers and sectors.
• The Strategy needs to go further in including debt write-off schemes by suppliers to mitigate for debt that can never be repaid. When debt is unavoidable and intractable, this indicates that the problem is rooted within markets and not within people at risk of or already experiencing vulnerability.
• A standardised approach to an inclusive and accessible service must be considered, specifically the Inclusive Service Kitemark, which is independently assessed and therefore can be more robustly enforced.
• Consumers, particularly those in vulnerable situations should be proactively involved in the development, design and delivery of innovations that support the transition to net zero.
• Consumer Vulnerability Panels should be further developed to ensure they are robust and fit for purpose.