Publications

In May 2019, The Scottish Government committed to establishing an independent Energy Consumers Commission (ECC) to enhance the voice of consumers who reside in Scotland within the energy market. The Commission was formed in July 2020 consisting of representatives with a wealth of experience in national consumer advocacy and advice bodies, academia and local groups serving energy consumers in their communities.

The Priority Services Register (PSR) is a record held by energy suppliers and network operators which enables them to provide additional support services to consumers in vulnerable situations.

Ofgem practices principles-based regulation in relation to vulnerability, and although suppliers and network operators broadly determine who can benefit from their PSRs, a level of consistency is ensured across the industry by a common framework of needs codes and vulnerability flags.

Previous research has found that the strength and depth of priority services, and those they seek to support, varies both between different PSR holders, and across different parts of Great Britain.

This briefing, based on research commissioned from Changeworks, examines how experiences of the PSR vary in Scotland in the context of the COVID-19 pandemic and the early stages of the transition to low carbon heating and electric vehicles. It also summarises the Commission’s recommendations on how the services offered and/or the range of vulnerabilities provided for under PSRs and other energy industry vulnerability initiatives can be improved.

The day-to-day activities of citizens are becoming increasingly dependent on their ability to use telecommunications services, such as mobile phones, broadband or landlines. The COVID-19 pandemic has highlighted the essential nature of online connectivity and access to internet data, with many people relying on internet access for working from home, staying informed or interacting with welfare services.

Executive Summary

CAS generally supports the measures proposed by Ofcom. In summary:

• The voluntary measures to support consumers introduced by providers during the outset of the COVID-19 pandemic were welcomed by CAS, as an effective response that has assisted in reducing consumer detriment over the past year.
• With consumers facing potential economic uncertainty as furlough and support schemes taper and Universal Credit uplifts look likely to be reversed, we believe it is timely to reconsider whether the protections for people in debt or struggling to pay remain appropriate, or whether there is a case for strengthening them.
• CAS supports measures which allow consumers in debt or at risk of disconnection to be treated fairly and have every opportunity to resolve these issues before disconnection takes place or service restrictions are imposed.
• CAS welcomes proposals to improve how providers identify and communicate with vulnerable consumers.
• CAS agrees that there should be more consistency in the ways providers communicate regarding debt and the ways they seek to obtain payment from customers in debt.
• CAS would wish to see the Consumer Principles embedded within the development of future measures, guidance, and regulations.
• CAS remains concerned regarding affordability issues and would welcome an early engagement approach by providers which aims to prevent a build up of debt
• We believe that further work is required to encourage providers to not only provide but to actively encourage take up of social tariffs for consumers who may be at risk of falling into debt.

Citizens Advice Scotland has responded to the call for evidence from the Scottish Parliament's Criminal Justice committee on the reform of Legal Aid. 

Scotland’s Citizens Advice Network is an essential community service that empowers people through our local bureaux and national services by providing free, confidential, and independent advice. We use people’s real-life experiences to influence policy and drive positive change. We are on the side of people in Scotland who need help, and we change lives for the better.

Citizens Advice Scotland are pleased to respond to the department of Business, Energy, and Industrial Strategy's consultation on Reforming Competition and Consumer Policy. CAS plays a significant role in the provision of consumer advice and advocacy in Scotland, and we recognise the significance of the proposed reforms for consumers. We welcome the UK Government’s focus on Consumer and Competition policy and the role it can play in promoting long-term economic development and consumer protection during the post pandemic recovery. 

Executive Summary

CAS welcomes the opportunity to respond to this consultation. We also welcome many of the proposed reforms, however it is essential that reform results in meaningful improvements in the consumer journey and achieves positive outcomes for consumers. We believe the consumer needs to be placed at the heart of consumer policy and would recommend that the consumer principles and the principle of “fairness by design” be used as an overarching guide to assess and inform consumer policy.

In relation to the detail of the proposed reforms CAS’s views are as follows:

• We support the granting of additional powers to the CMA but have mixed views on whether the CMA’s priorities should be informed by governmental direction.

• We wish to see a greater ability for regulators to respond to the differential impacts of competition across the devolved nations.

• We are of the view that these reforms provide an opportunity to further strengthen and enhance the function of the Consumer Protection Partnership to improve collaboration and responsiveness on consumer protection issues.

• We believe that further action is required to equip consumers with the skills and knowledge to participate in online markets safely; in this regard we support proposals to reform the use of subscription services.

• We wish to see reforms which make it easier for consumers to understand their rights and to take swifter, more effective action to enforce these rights.

• We believe there is a need for better education on consumer rights as well as a need for clearer information to be provided about Alternative Dispute Resolution (ADR) so that consumers understand what it is.

• We are of the view that the ADR landscape is overly cluttered and would support streamlining to provide for one consumer ADR provider in each sector. As a minimum, there should be a single branded entry point for people wishing to access ADR on consumer matters.

• We recommend that ADR providers should report to regulators on trends. This would close the feedback loop and help drive up standards across regulated industries by enabling regulators to take action to prevent consumer detriment.

• We would wish to see Competent Authorities play a role in setting and monitoring common standards across the sector, including in relation to how providers support vulnerable consumers.

The universal broadband service is intended to give everyone the right to request a decent and affordable broadband connection, subject to certain eligibility criteria. CAS was pleased to see Ofcom investigate this issue and welcomes commitments from the Universal Service Provider, to change its approach for quotes, to refund affected customers and re-issue quotes it has previously provided. We note from the Connected Nations report that around 3-4% of Scottish properties are currently unable to receive a decent broadband connection and may therefore be eligible for a USO connection and this move will make it easier for those households to gain access to decent and affordable broadband. It will also make it easier for communities in affected areas to work together to share costs of connections where costs would make connections unaffordable for individuals. The submission below confirms our support for these measures. 

The Scottish Campaign on Rights to Social Security (SCoRSS) is a coalition of organisations who advocate for a reformed social security system that reflects the five principles set out in our Principles for Change. SCoRSS (previously the Scottish Campaign on Welfare Reform) encompasses over 40 organisations from key third sector organisations, charities, faith groups, and unions. Our members have a diverse range of experience and expertise and a strong understanding of social security and its impact on the people and communities we work with.

Focusing on the impact the £20-a-week cut to UC will have to Scotland, our briefing shows that:

• Nearly three quarters (74%) of Scottish Citizens Advice Bureau clients on UC will struggle if the cut goes through;
• 1 in 4 people claiming UC in Scotland say they are ‘very likely’ to need to skip meals when the cut hits, and 17% say they are very likely to use a food bank;
• As many as 4,000 low-income households (8,000 children) will lose entitlement to Scottish Child Payment if the cut goes ahead, due to the passporting of Scottish Child Payment from UC, meaning these families may face an income cut greater than £20-a-week; and
• More than half a billion pounds a year will be removed from the Scottish economy, cutting support for some of the most deprived parts of the UK.

SCoRSS is calling for the £20 weekly increase to Universal Credit to be made permanent.

This report, the second in a three-part series on UC during the pandemic, covers our clients’ experiences living on UC during the pandemic. Our research found that rising costs during the pandemic have pushed an already-too-low social security system to breaking point:

• 67% of people surveyed said the UC payment they received was inadequate for their needs, with more than half of these people (55%) describing UC as ‘very inadequate’.
• Over seven out of ten (71%) said the amount of UC they received was lower than they are used to living on.
• More than a third (38%) said their outgoings had increased in the period before they had to claim for UC and now, with a majority (56%) reporting that their spending had gone up on necessities like heating and electricity (50%), food (40%), and housing costs aside from rent (27%).
• Almost two in three (64%) had to cut down on at least one basic necessity during their UC claim, with one in five (20%) cutting down on food.
• Over one in four (27%) had to borrow money in order to pay for essentials.

With this in mind, the UK Government’s decision to cut UC by £20 a week in September is a step in the wrong direction. Our research found that:

• Most said they would be unable to cope if their UC income dropped, with 61% unable to cope if it dropped by £10 per week, 74% unable to cope if it dropped by £20 per week, and 78% unable to cope if it dropped by £30 per week.
• If these cuts went ahead, 26% said they would be unable to pay for essentials and 14% said they would be unable to buy food.

The UK Government must urgently review and uprate the level of support UC offers to ensure no-one is left without essentials. Increasing UC is the right thing to do, both to protect individuals from hardship and to support our post-pandemic economic recovery.

The Impact Team at Citizens Advice Scotland helps deliver the second aim of the Citizens Advice network in Scotland; taking the issues we see across our network and using that to inform policy advocacy to deliver social change for people.

This impact report demonstrates how we achieved our key outcomes for 2020-21. 

Citizens Advice Scotland (CAS) gathers evidence from the more than 171,000 clients a year supported by our network. Many of the problems faced by our clients are rooted in or linked to their incomes not being enough to meet their needs and live a dignified life. For many people coming to see us they simply do not have enough money to make ends meet: YouGov in May of this year indicated 1 in 7 Scots is struggling on their present income even with the temporary financial support measures put in place as a result of the pandemic. In fact, 56% or half a million pieces of advice provided by our network every year can be attributed to income maximisation. During the pandemic CABs unlocked £147million for people through things like social security payments, employment entitlements and lower bills for utilities. A Minimum Income Guarantee would mean the Citizens Advice network could ensure people have even more security and opportunity.

This evidence base, from over 80 years as Scotland’s largest free, impartial and confidential advice network, gives CAS a unique understanding of the issues that IPPR proposes could be addressed by a Minimum Income Guarantee. In addition, our experience supporting clients over the course of the pandemic shows that even those who were coping before the crisis still found themselves vulnerable if their income dropped or costs went up even slightly.