The Centre for Sustainable Energy (CSE) has submitted a detailed response to Ofgem’s Consumer Vulnerability Strategy refresh consultation, drawing on decades of experience supporting people in fuel poverty and pioneering research into fairness in the energy market.

Our response emphasises the critical importance of ensuring the transition to a green, smart and net zero energy system doesn’t leave people in vulnerable circumstances behind.

“Through our advice services, we see firsthand how vulnerable consumers struggle to navigate today’s energy market,” says Dan Stone, policy officer at CSE. “As we move toward a smarter, more flexible energy system, it’s crucial that innovation doesn’t create new forms of exclusion.”

Key recommendations from our response include:

• Developing stronger methods to assess how the costs and benefits of an expanded electricity system are distributed across different consumer groups.
• Requiring energy suppliers to proactively evaluate whether their smart tariffs could benefit existing customers.
• Mandating standardised information about smart energy offers to help consumers compare products and understand costs.
• Improving the monitoring of smart meter functionality, particularly for vulnerable customers.
• Investing in independent smart energy advice services to help people navigate increasingly complex energy choices.

Drawing on findings from CSE’s Smart and Fair research programme, we emphasise that inclusive innovation must extend beyond consumer products to encompass network planning and infrastructure investment decisions. This approach helps ensure that the benefits of the energy transition reach all communities, not just those able to adopt new technologies quickly.

Our response also highlights the importance of robust enforcement from Ofgem to ensure energy suppliers properly support vulnerable customers. CSE advocates for clear accountability measures, including transparent reporting on service quality and customer outcomes.

A key issue identified in our response is the need for energy companies to provide interpreting services for vulnerable customers who have difficulty communicating in English. Currently, when we liaise with energy suppliers on behalf of these customers, CSE must fund the necessary phone-based interpreting services. The charity sector should not have to pick up this financial burden. Read our blog which talks more about our views on translation services.

Our future energy system must also be a fair one. CSE’s experience supporting thousands of people each year through our energy advice services, combined with our research into emerging smart energy markets, shows that achieving this requires careful attention to consumer protection alongside technological innovation. Ofgem’s Consumer Vulnerability Strategy refresh is an important part of this because it will shape how vulnerable households are protected and supported as we transition to a net zero energy system that works for everyone.