Citizens Advice response to Ofgem consultation on providing financial protection to more vulnerable consumers
The case for strong action on energy prices has been broadly accepted. It is right that the policies and procedures are being put in place for a targeted cap despite the promise of a market wide cap. Firstly because of the uncertainty over if and when this wider cap will be in place but also because the need for targeted protection is likely to last longer than that of the wider market.
Looking at the three ways in which someone can be vulnerable to higher prices, we believe that low income households - both in work and out of work - with children, elderly people and those with disabilities or long term health conditions should be considered for protection.
Data-matching will be needed in order to target these groups effectively. Ofgem should consider including tax credits and the over 80 component of Winter Fuel Payment in the list of benefits to be matched.
In the absence of a data-matching process, stop-gap options such as PSR and account in debt or arrears would provide some protection as an interim measure. However, to the extent that the targeted approach will be required beyond winter 18/19 Ofgem should continue to engage with government departments to ensure the data-matching process is in place as soon as possible.