Initial Advice to Scottish Government

The Scottish Fuel Poverty Advisory Panel give initial advice to the Scottish Government on immediate actions which can be taken to alleviate the impact of escalating energy prices on those suffering fuel poverty.

SFPAP – final advice for publication – 30-11-22.pdf

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1. Optimise Advice Agencies’ Delivery to Mitigate the Impact of Rising Energy Prices, and Other Cost of Living Challenges, on Households

Even before the latest energy cost cap announcement, advice agencies report that they were struggling with multiple issues in delivering their energy management and money advice services. The Panel has heard that:

  • demand for their services is increasing10 week on week
  • queries are more complex and therefore more time-consuming to resolve
  • there has possibly never been greater need for their services but for some clients they no longer have answers. For a growing cohort of those seeking advice, all efforts to increase their income and adopt those home energy efficiency measures within their power, have already been done. There is nowhere else to go in trying to bridge the gap between money coming in and essential spend
  • the emotional toll on staff of work-demand and supporting sometimes desperate people, whom they do not necessarily have the tools to help, is having a detrimental effect on staff mental health. Much consultation time has moved from energy and money advice to counselling. This is not a skill set which these advisers necessarily have. Face to face support is often the most impactful but it is the hardest to deliver – it comes at an emotional as well as financial cost
  • there is anecdotal evidence that some energy supplier debt response departments lack the resources and skills to engage when advice services approach them on clients’ behalf and there has been a move away from offering ‘charity hotlines’ into some energy suppliers. As a result advice agencies waste time sitting in phone queues or being passed around different parts of the organisation only to be connected to customer service advisers without the knowledge or power to help. This dissipates the energy and resources of already stretched advice services and results in poorer outcomes for clients whose debt – with no agreed management plan – continues to escalate
  • some agencies are also reporting that suppliers have removed Freephone numbers from their websites – leaving some people with increasing phone charges as they sit on hold in lengthy ‘phone queues, adding to feelings of hopelessness and despair
  • sourcing funding for advice services is challenging. Many agencies are chasing the same money and the short-term nature of funding has negative repercussions for service provision, detracting energy from the focus on their core advisory service. Short-term contracts, necessary from a budgetary perspective, make the employment and retention of staff difficult. Even as the Panel were engaged in conversation with advice agencies, one reported that two experienced members of staff had just handed in their notice to take NHS jobs which, in spite of lower remuneration, offer permanent contracts and secure employment.

Immediate action

Recommendation 1 – ensure that advice agencies can focus on the delivery of frontline services. This can be supported in the short-term by providing the additional funding commitment, made through Programme for Government, with a multi-year guarantee.

The energy crisis has been characterised by the First Minister as a “humanitarian emergency”.11 (There are also several recent reports, from a number of well-regarded organisations, whose analysis of the current poverty challenges in Scotland supports the First Minister’s reflection).12 As with the public health crisis caused by the pandemic, it requires a covid-style response for front line services. Advice services have a crucial role to play in frontline support.

The additional, targeted funding, which the Scottish Government have committed, will increase, at least in the short-term, the resilience of advice services. It will help to secure existing resources and enable some scaling up and increase in advisory capacity in the face of what, some agencies are calling, a “tsunami” of demand. It could also provide some short-term help for staff in coping with emotionally vulnerable clients, as well as “keeping the lights” on by helping agencies with their own escalating energy costs. The collective insight, however, is that further support will continue to be necessary.

Recommendation 2 – launch public information campaign, targeting specific communities, as soon as possible to keep people warm and healthy this winter.

The Panel welcomes the Scottish Government’s recently launched Cost of Living website and the public information campaign, running to the end of November, to promote it. The website is a valuable source of support and information through its “one-stop” shop design – signposting to the help available to cover: energy bills; benefits; health support, those with disabilities and families. The accompanying media campaign, across a variety of media channels, highlights the website well. It would be beneficial to embed the website and build on this asset further through adding a non-digital version, ensuring that the website is accessible to those with visual or audio difficulties, and to those whose first language is not English.

The Panel think there would be benefit in extending this media campaign through a series of simple messages, with different themes and target audiences in mind, to help keep people warm and healthy this winter. Covering themes such as how to heat your home, how to cook while managing your energy consumption and where to obtain crisis help. This would ensure that continued information was available throughout the winter as the risks of the consequence from living in fuel poverty and rationing energy consumption increase. The Panel has heard from both advice agencies and those with lived experience, about the need for continued, but simple to access and act upon, advice that can be trusted and is available at the point of need or crisis.

Recommendation 3 – Scottish Government should broker a voluntary priority protocol between itself, advice agencies and energy suppliers to achieve the best outcomes for those struggling with energy bill payments and debt.

Both energy suppliers and advice agencies, are telling us that they are concerned about the level of bad debt and its effect on consumers, as well as its potential impact on business viability. A voluntary protocol, providing priority access to services and debt management; leveraging of Priority Service Register data; sensitivity around customer credit reporting, and, targeted, simple “how to” messaging on household heating systems, would help to reduce customer demand on both suppliers and advice agencies and, critically, support better outcomes for the vulnerable.

Scottish Government can play a role in brokering a voluntary protocol between energy agencies and advice services. The recent Ofgem Market Compliance Review was critical of some suppliers and how they are supporting households experiencing difficulties in paying their energy bills. This aligns with what the Panel has heard in conversations with advice agencies and some suppliers (indeed some suppliers have acknowledged that they need to do more/are planning to do more). At the same time, the Panel has heard examples of very good supplier practice too, which suggest that there are opportunities for the sharing of good practice on customer debt management.

I. Energy supply companies should facilitate easy access for advice agencies through dedicated numbers for all advice agencies

Anecdotal evidence suggests that customer service demand for debt management plans is already outstripping what some suppliers have the capacity to negotiate and agree. Advice agencies are clear that this is impacting on the effectiveness of their services and leading to poorer outcomes for those already in debt and vulnerable. For example, the Panel heard that repayment plans are often problematic with some energy suppliers automatically expecting a high, and often untenable, repayment rate if paid via direct debit. A lower repayment plan can sometimes be agreed if a client can prove they have received debt advice but currently only a small number of advice agencies are recognised by suppliers. These certainly do not have the capacity to fulfil debt advice demand. Although many other advice agencies are available, few of them are recognised as debt advisers by energy supply companies.

If a direct debit repayment plan cannot be managed, a pre-payment meter can enable people to maintain their supply and payback debt over a longer time period. (Even though pre-payment meters are one of the more expensive ways to pay for energy services). In short, people’s capacity to repay debt and meet their current energy needs does not always appear to be the primary consideration in setting repayment plans, unless done via an energy company “recognised” debt advice service and there are few of these.

If suppliers restrict customer service capacity for the financially vulnerable for short term cost containment, which is what some energy suppliers appear to be doing, this does not make sense. Debt levels are only going to continue to rise as energy costs increase from their already unprecedented levels. The development of a protocol would strengthen lines of communication between advice agencies and energy suppliers. This would benefit all:

    • advice agencies, over and above recognised debt advice agencies, would have a direct line to those who can help set realistic payment plans for their clients. This would enable them to spend their time in helping their clients rather than navigating unhelpful systems and allow them to talk immediately to someone empowered to help
    • those [clients] already in fuel poverty would avoid escalating debt charges, giving them back a sense of control and avoiding the risk of them either self-disconnecting or being disconnected
    • energy companies would have a greater chance of recouping customer debt and reducing debt management costs.

II. Energy network and supplier companies should use data to enable more proactive identification of those in financial vulnerability

A tangible output of the voluntary protocol could be for energy companies to include more robust financial vulnerability code/s on their Priority Services Register13 as well as to consolidate and simplify these. [Energy suppliers and network operators each keep their own register: there are around 73-74 of these]. It would be an opportune time to explore introducing a single consolidated register that both energy supply and network companies access and update. Ofgem could also be encouraged to mandate proactive identification among Priority Services Register holders.

Companies could also use financial vulnerability code data intelligence dynamically in their management of financially vulnerable customers. For example, assessing whether movement to a pre-payment meter really is the best option for a particular customer.

The inclusion of a financial vulnerability code on Priority Service Registers would also facilitate the effectiveness of data-sharing and transparency on financial vulnerability between energy companies,14 enabling a more holistic approach to addressing the needs of those in fuel poverty. This would be taken to a whole new level of transparency, leading to targeted support, if a single, consolidated Priority Services Register, covering all energy companies, were created.

Connected to financial vulnerability, the Panel has heard some worrying evidence about the health and safety aspects of home energy management where fuel poverty was often the root cause. For example, gas boilers not being serviced and increasing evidence of tampering with the energy supply to avoid further debt by circumventing meters. Not only is the latter dangerous but it also results in the supplier cutting off the supply. [The original tampering is not necessarily carried out by the current tenants but supplier action appears to be based on the presumption that the current householder is guilty]. Supplier action does not necessarily include an assessment of the detriment that can be caused through supply isolation and how it is resolved. Loss of supply can lead to acute hardship with people left without lighting and heating for, in some cases, many weeks, unclear who to turn to and unable to readily get the supply reinstated. Communication can easily breakdown – particularly where different electricity and gas suppliers are involved. A more proactive approach, including more vulnerable people on Priority Services Registers, might help avoid these health & safety issues which can lead to disconnection. (Inclusion on Priority Services Registers, triggers greater access to free gas safety checks, priority assistance and Warm Home Discount assessments for those identified as vulnerable).

III. Energy supply companies should manage the sharing of customer credit records for consumers that fall into debt this winter in the overall context of the customer’s credit record and with sensitivity to the exceptional circumstances of the energy crisis

With the projected fuel poverty figures, it is inevitable that debt levels will rise. The Panel has heard concerns that even those who would never previously have been vulnerable to having a poor credit record may now face this. A poor credit history not only makes borrowing in the future expensive – but also means paying a credit poverty premium15 for goods and services. The scale of the current crisis will make a whole new demographic vulnerable to the credit poverty premium jeopardising both their current and future financial wellbeing.

Energy companies should review whether their policies on passing on missed payments to credit agencies are fair in the current environment, particularly for those with a good payment history failing to make payments for the first time. Changing their reporting policies, to take account of this, would help protect people’s future access to: bank accounts; rental agreements; mortgages etc. At the same time, energy companies could use their influence with credit agencies to view the current financial environment as unprecedented and not harm people’s future credit ratings on the basis of a period of exceptional and temporary hardship.

IV. Energy supply companies should provide targeted information on the efficient use of heating systems to their customers – if they have not already done so

The Panel has heard from energy advice services, that it is very common to find that people do not use their heating systems in the optimum way for energy consumption efficiency.

Energy supply, and the pattern of customer use, mean that energy companies know what principal method of heating their customers use. Suppliers should be encouraged to analyse their customer data to ensure that households are provided with simple information about how to best utilise their heating system, and where relevant, their electricity tariff. This is particularly important for those with legacy multi-rate electricity tariffs.

Recommendation 4 – review the design of energy advice services, including the funding model for advice services, to inform funding and policy decisions in 2023/24.

There is a question of whether the current model for advisory service provision is as effective as it could be and immediate intervention is needed.

As recognised in recommendation 1, the tendency for multiple funding pots and short-term funding means that organisations spend a disproportionate amount of time securing grants and income. The provision of consistent, long-term, and more, funding for third sector advisory services would be transformative. It would:

  • streamline access to funding
  • facilitate long-term planning
  • enable responsive advisory services so that in rapidly changing situations, like the current crisis caused by volatility in the energy market, services could evolve quickly to address need
  • support staff retention
  • support the integration of mental health awareness and suicide training for advice staff
  • increase the availability of health and wellbeing support and counselling services for advisory staff.

The Panel would also note the benefit of face-to-face energy advice services in homes and communities as well as the benefit of community-organisation collaborations e.g. partnerships between food banks, food waste reduction schemes, soup kitchens for the elderly and energy advice. The efficacy of local champions (energy advice) and in-person advice has been a recurrent theme in promoting energy efficiency measures.

There are multiple ways in which advice services can be accessed – online, telephone hubs or face to face – but it is unclear how these services fit together and whether front facing services are accessible to everyone, for example, whether there are appropriate referral pathways for local care and support agencies. There is often a fragmented approach, for example, some local authority departments, such as housing and social services might typically use a referral pathway but other departments are often not aware that these exist.16 There is also a question of what skill sets and training are required across advice agencies to match different service delivery routes. These issues and their impact should be explored in reviewing the current funding model for advisory services. Data obtained through the Scottish Government “cost of living” website,17 launched at the end of September, to help people understand the significant range of support that they may be able to access, may make a useful contribution to a funding model for a review of advice services. Consumer Scotland would have a useful contribution to make too.

The Panel suggest that the scope of a Scottish Government review of the design of energy advice services, including the funding model for these, should focus on:

  • funding levels required and for how long to achieve effective service delivery
  • optimum balance of local and national advice services
  • staffing and skill issues
  • creating flexibility, in a dynamic and unpredictable environment.


10 A doubling of demand for services, even before the Winter has set in, is a ball park figure which several agencies have mentioned.
11 Programme for Government 2022-2023: First Minister’s speech – (
12 Poverty in Scotland_Oct 2022; JRF; Coronavirus Financial Impact Tracker | abrdn ( , July, 2022; Citizens Advice Scotland, 2022.
13 The Priority Services Register is a free support service to help people in vulnerable situations. Energy suppliers and network operators offer it. Each keeps their own register.
14 A review by Changeworks in 2021, noted that codes are the main way of sharing vulnerability data between companies.
The-poverty-premium-A-Customer-Perspective-Report.pdf ( 2022
16 East Ayrshire Council has a cohesive approach through their Financial Inclusion Pathway (referral pathway) and EA Money, gives information on local services offering advice and information on benefit and money issues.
17 Cost of living crisis – Cost of Living Support Scotland (


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