Tackling consumer vulnerability in energy and banking: towards a new approach

Abstract

This article examines the new approach to vulnerability developed by Ofgem and the Financial Conduct Authority to see whether it has been implemented at company level and had an impact on the ombudsman. It sets out the context within which this approach has been developed and then looks at its implementation through two case studies. The main lesson from these case studies is that establishing a broad concept of vulnerability, as has been argued for in the academic literature, is just a first step. Operationalising the concept presents major challenges especially in the context of systems dealing with large numbers of consumers.

Keywords:

• Consumer
• vulnerability
• essential services
• regulation
• Ombudsman

Acknowledgements

My thanks to Pablo Cortes, Richard Craven, Naomi Creutzfeldt, Christian Gill, Linda Lennard and two anonymous referees for their helpful comments. My thanks also to all those who participated in the research who must remain anonymous. All the views expressed and any factual mistakes are my own.

Notes

1. See: https://www.ofgem.gov.uk/investigations/investigations-and-enforcement-data (accessed 19 February 2018).

2. See http://www.financial-ombudsman.org.uk/about/actionplan-2016.pdf (accessed 19 February 2018).