Ofcom proposals to amend: Treating Vulnerable Customers Fairly Guide - Which? response

Which? welcomes the opportunity to respond to Ofcom’s proposals to amend its ‘Treating Vulnerable Customers Fairly’ guide for communications providers (‘the guide’). It is critically important that broadband and phone providers treat their customers fairly when they are at risk of being disconnected due to financial challenges.

It is right that communications providers and Ofcom took steps to protect people in debt or at risk of disconnection during the pandemic. Which? believes it is essential that these measures remain in place and continue to be strengthened ‘post-pandemic’, given the continuing importance of connectivity, and worsening economic conditions for consumers, including the cost of living crisis, which disproportionately impacts those on low incomes. Which? research shows that incidence of financial difficulty continues to increase in the UK. 59% of households made adjustments to cover essential spending in April 2022 and 7.3% missed at least one housing, bill, loan or credit card payment.

As the UK’s consumer champion, Which? is broadly supportive of each of the proposals to amend ‘the guide’ put forward in this consultation, which all strengthen Ofcom’s existing guidance in important ways. These changes must be backed up by a robust and structured monitoring regime led by Ofcom. This would ensure that providers implement the necessary changes so that all vulnerable consumers are paying a fair price, provided with clear information, and protected from unfair or premature disconnection. This regime must include clear thresholds for what Ofcom considers successful industry change, and contingency steps if these thresholds are not met, including regulation. We appreciate that Ofcom has made clear its intention to monitor certain aspects of the implementation of these proposals, but we would like this essential aspect to take the form of a firm and detailed commitment.