Chief Executive's Foreword
This winter continues to be a challenging one for consumers, with freezing temperatures across Scotland when energy prices remain at historically high levels. After two years of high bills the energy debt owed by GB consumers has nearly doubled from £2.04bn in autumn 2022 to £3.84bn in autumn 2024. The recent bill increases are likely to make this situation worse.
High bills and increasing debt underline the need for governments to design and deliver better targeted energy affordability support for consumers. In particular, Consumer Scotland has recently made a number of recommendations to improve the targeted energy bill support provided to those who are terminally ill, disabled people and those with health conditions.
Affordability for consumers on low incomes was central to our recent recommendations on water charging policy, which included proposing an increase in the level of the Water Charges Reduction Scheme to provide greater relief to eligible consumers.
The level of water bills for a six-year period running from 2027 is being considered in the Strategic Review of Charges 2027-2033. As the statutory water consumer advocacy body Consumer Scotland is working hard to ensure consumers’ priorities are placed at the heart of this process. We have reached agreement on a new Memorandum of Understanding with the Water Industry Commission for Scotland and Scottish Water.
This is an innovative approach that will ask consumers whether Scottish Water’s final Business Plan commands their support before the final determination of charges for 2027-2033. You can read more about the Consumer Scotland water team and the work they do in the spotlight section of this Newsletter.
Under our founding legislation, one of Consumer Scotland's functions is to promote sustainable consumption of natural resources. In carrying out this work, we have a delivered a significant programme of work to understand and track consumers’ priorities for, and experience of, the transition to net zero.
Our research has highlighted a significant gap between public concern in Scotland over climate change and the levels of consumer action currently being taken to tackle it. Our report found cost and convenience are the key factors which drive consumer purchasing decisions rather than environmental benefits. As a result, Consumer Scotland has set out a package of recommendations to make it easier for consumers to make sustainable choices.
Other areas of our work in the past quarter include our continued engagement with the energy industry’s plans to mitigate the end of the Radio Teleswitch (RTS) service this summer. Electricity suppliers were due to have informed all affected customers of this change by the end of 2024 and are required to take all reasonable steps to provide an appropriate alternative metering arrangement by the end of June 2025 to all RTS customers that engage with their supplier’s meter upgrade programme. We continue to encourage consumers who have an RTS meter - or those who are not sure if they have one - to contact their electricity supplier for advice as soon as possible.
In October, Consumer Scotland published an insight report into dynamic pricing. The issue attracted significant public attention across the UK following the sale of tickets for Oasis concerts. Our insight paper examines the core issues including to what extent dynamic pricing is either illegal or unfair to consumers, what the government and regulators are doing about it and what more could be done. We are engaging with the Competition and Markets Authority on this important issue which has implications for consumers across a number of different sectors of the economy.
In the postal market Consumer Scotland has described as "unacceptable" the fact Royal Mail has once again missed its delivery targets at a time when the price of post has risen sharply. As part of ongoing changes to the Universal Service Order Consumer Scotland will work hard to ensure future reforms meet the needs of consumers.
October also saw the publication of our Annual Report and Accounts 2023-2024 which sets out Consumer Scotland’s development and our work on behalf of consumers in our second full year of operation.
Consumer Scotland will continue to advocate for change across a range of markets over the coming year to tackle harm to consumers and encourage action that will boost consumer confidence across the economy. Next week we will publish our draft Work Programme for 2025-2026 for consultation and would welcome your feedback.
Sam Ghibaldan Chief Executive
Latest News
Terminally ill need more help with their energy bills
Action is needed to improve energy support for the terminally ill, disabled people and those with severe health conditions.
Consumer Scotland research has shown these individuals often have higher energy expenditure because of the cost of running essential medical or mobility equipment such as oxygen concentrators, home dialysis machines and electric wheelchairs or hoists.
Some disabled people or those with severe health conditions are dependent upon life-saving medical equipment.
These consumers also may need to keep their homes warmer to manage medical conditions such as pain, respiratory illnesses and fatigue.
However, income-related support does not tend to account for the impact of higher expenditure to meet disabled consumers’ greater essential energy needs.
Consumer Scotland has asked the Scottish Government to consider targeting energy affordability support at those who are terminally ill - who are already identified through the benefits system.
We have also recommended that the UK and Scottish governments work together to create an energy affordability scheme which includes disabled people and those with health conditions.
Urgent government measures needed to engage consumers on climate change
New research by Consumer Scotland has highlighted a significant gap between public concern in Scotland over climate change and the levels of consumer action currently being taken to tackle it.
Our research also found consumers are unclear about the actions required to meet net zero targets.
The report found cost and convenience are the key factors which drive consumer purchasing decisions rather than environmental benefits.
As a result Consumer Scotland has made a number of recommendations to make it easier for consumers to make sustainable choices. This includes the need for the Scottish and UK governments to provide clearer leadership on this issue.
The report states: “To help consumers change their behaviours in a real, long-term and impactful way there must be action at all levels of government and industry.”
Key issues to help consumers make more sustainable choices include regulation, incentives and information promoting the positive benefits of sustainable consumption including economic growth, cost savings and health benefits.
Consumer Scotland is now developing a vision, which sets out the key consumer values and outcomes, to support policymakers and industry to prioritise consumer issues in the transition to Net Zero.
Measures must be in place to protect consumers from the impact of RTS switch-off
Consumer Scotland has been highlighting the need for urgent action to ensure energy suppliers meet their responsibility to replace the remaining Radio Teleswitch (RTS) meters in Scotland by the end of June this year.
An agreement between Ofgem, industry and consumer groups to find a joint solution to the RTS switch-off has been welcomed by Consumer Scotland.
Customers who have an RTS meter - or those who are not sure if they have one – are being urged to contact their energy supplier for advice and make an appointment for an engineer to visit their home. Electricity suppliers were due to have informed all affected customers of this change by the end of 2024 and are required to take all reasonable steps to provide an appropriate alternative metering arrangement by the end of June 2025 to all RTS customers that engage with their supplier’s meter upgrade programme.
Chief Executive of Consumer Scotland Sam Ghibaldan said: “Measures must be in place before the switch off to avoid consumer harm. There has been ample time for the industry to plan.
“We continue to recommend urgent action to ensure consumers do not suffer harm as a result of the switch off.
“Consumer Scotland will continue to help efforts to ensure consumers in Scotland are protected though the joint taskforce involving the regulator Ofgem, industry and consumer groups.
“We encourage affected households to contact their supplier to arrange a meter replacement as soon as possible. Suppliers also have a responsibility to proactively seek out RTS consumers, who may not realise they are affected.”
As part of Ofgem’s working group on this issue Consumer Scotland will continue to help coordinate efforts to ensure consumers in Scotland are protected.
The challenges facing low income tenants driven into the private rented sector
Scotland’s property rental market is under intense scrutiny with many tenants struggling to access affordable and well-maintained tenancies.
Data collected in Scotland’s 2022 Census shows that about one-third (35.4%) of households were renting, of which 22.5% were in the social rented sector.
A 2022 study by the UK Collaborative Centre for Housing Evidence suggests that 30% of private rented sector tenants in Scotland find it difficult to afford their current rent. Social landlords have reported a historic peak in rent arrears, nearing £170 million at the end of March 2022.
The Scottish Parliament declared a housing emergency earlier this year and a hotly debated Housing Bill is currently progressing through Parliament.
Tenants on low incomes or with vulnerabilities are particularly feeling the pinch - often being driven into the private rented sector due to a shortage of available social housing.
Consumer Scotland has looked at the available evidence on the issues private and social tenants face in a new report and blog post.
Statement on Royal Mail fine for missing delivery targets
Consumer Scotland has responded to the decision by Ofcom to fine Royal Mail for missing delivery targets.
Consumer Scotland Head of Post Grace Remmington said: "It is unacceptable for Royal Mail to be once again missing its delivery targets at a time when the price of post has risen sharply.
“Consumers across Scotland depend on the postal service for vital communications, including sending letters to government departments, local authorities, banks, the health service and solicitors.
“Failing to meet the required service standards risks harm to these consumers - and all consumers are entitled to the service they pay for when sending mail.
“We welcome the latest action by Ofcom, but the regulator must ensure Royal Mail addresses these failings to ensure the postal service is reliable and affordable for all users in future.
“This is particularly vital for those who are most dependent on postal services including consumers with a disability or long-term health condition and consumers who live in rural and remote communities.”
Partnerships key to the work of Consumer Scotland
Consumer Scotland is developing its partnership working to ensure consumer interests are at the heart of policy decisions across a range of markets.
In November, Consumer Scotland and National Energy System Operator (NESO) signed a joint Memorandum of Understanding.
NESO, which is a new independent public body, and Consumer Scotland will support each other in working towards three main shared objectives: improved services, a just energy transition and informed stakeholders.
Consumer Scotland Chair David Wilson said: “For future systems to be successful they need to be affordable, fair and equitable, with consideration of consumers at their core.
“This partnership will help ensure the design of the future energy systems aligns with consumer behaviours to achieve a just transition.”
And in December we chaired the first session of the new Consumer Strategic Leadership Group to discuss how advice and advocacy bodies can work more closely together.
Chaired by Consumer Scotland Chief Executive Sam Ghibaldan attendees also included Chief Executive of Citizens Advice Scotland Derek Mitchell and Chief Executive of Advice Direct Scotland Andrew Bartlett.
Spotlight on our water team
Putting consumers at the heart of the water industry
The next few years will be particularly challenging for consumers in the water sector in Scotland and the Consumer Scotland water team will be working hard to ensure their interests are being addressed.
The future level of water bills for a six year period running from 2027-2033 will shortly be considered by the Scottish Government, the Water Industry Commission for Scotland (WICS) and Scottish Water.
As the statutory consumer advocacy body for the water sector in Scotland, Consumer Scotland will work with stakeholders to ensure consumers are placed at the heart of this process – known as the Strategic Review of Charges (SRC) - and we have already made a number of recommendations.
The review will look at ensuring sufficient income is raised from customer charges to adequately fund existing services and invest in the infrastructure required for the future - as well as ensuring charges don’t unfairly burden current and future consumers.
However, Scottish consumers are likely to face above-inflationary increases to respond to the twin challenges posed by the climate crisis and ageing water infrastructure. Without action, this will result in increases in the number of Scottish households in water poverty.
Low income households need protection from future rises in water bills
Consumer Scotland is advocating for increases in existing discounts to help maintain the affordability of water charges for consumers on lower incomes at the start of the next charging period.
We want to see both an increase in the threshold of the existing Water Charges Reduction Scheme to limit rises in water poverty in future - as well as consideration of new proposals to target consumers who currently miss out on support.
Landmark agreement to put consumers at heart of future water investment and charging
As part of our work to protect consumers in the water sector we have also signed a new Memorandum of Understanding with WICS and Scottish Water.
Under the new joint agreement consumers, communities and the environment will be central to the forthcoming SRC. The MoU will ensure the public will be engaged throughout the price review process.
Consumer Scotland Head of Water Gail Walker said: “As the levy-funded advocacy body for the water sector in Scotland we work to ensure affordability of water charges, while also supporting the investment required to adapt to climate change.
"Increasing the level of discount available under the WCRS represents a cost-effective way of helping to keep bills affordable for many households in the short term and we want to see this in place when new charge levels come into effect in 2027.
“We know the decisions being taken in the SRC will have significant implications for consumers and our MoU will help ensure consumers are central to the decisions made during the strategic review of water charges.”
Meet the water team
Head of Water Gail Walker
Gail has a wealth of experience working in the water industry in Scotland representing the needs of consumers across a wide range of issues. Before taking up her current post her roles included Water Policy Team Manager within the Consumer Futures Unit at Citizens Advice Scotland. Before this Gail worked in strategic and operational project management across a number of industries including third world development in Malawi, pensions and insurance, supply chain management and the NHS. In 2008 Gail established a community action group engaging with local government and other organisations to address local flooding.
Water Policy and Advocacy Manager Shane Taylor
Prior to joining Consumer Scotland, Shane was Policy Manager at Aberdeen & Grampian Chamber of Commerce, advocating for the business community in the North-east of Scotland during periods of transformative change – including the COVID-19 pandemic and the UK’s exit from the European Union. He holds an MRes from the University of Strathclyde Business School and has worked in a range of organisations in both research and advocacy focused roles. Shane’s specific areas of interest within the water team include the affordability of household water charges and Consumer Scotland’s role in fostering a more effective non-household water market.
Water Policy Officer Shona Hamilton
Shona completed her MA English Literature at University of Glasgow and MSc at University of Stirling. Before taking the position of Water Policy Officer at Consumer Scotland, Shona worked for Police Scotland as Stakeholder Engagement and Collaboration Research Analyst. This role involved gathering and analysing data to support the creation of reports, briefings and engagement proposals for key stakeholders and Force Executives. Shona has a passion for advocacy as well as a deep understanding of collaboration and evidence-based policy making.
Forward Look
Over the next few months Consumer Scotland will continue our work to deliver better outcomes for consumers across markets and services in Scotland and across our priority themes of affordability, climate change adaptation and mitigation and consumers in vulnerable circumstances.
Over the next quarter we will:
- Publish the findings and recommendations from our first investigation into consumer protections in the green home heating market which will focus on helping consumers decarbonise and improve energy efficiency
- Publish the final guidance for the consumer duty which comes into force in April this year and aims to put consumer interests at the heart of strategic decision-making across the public sector to deliver better policy outcomes for Scotland
- Publish our Draft Work Programme 2025-2026 and launch a public consultation to help shape our priorities
- Begin work on a survey with small businesses to establish the common problems they face to help prioritise our work to support them
- Engage with Royal Mail, Ofcom and other stakeholders on reform of the Universal Service Obligation to ensure consumer views are taken into account. Our work will be informed by research with consumers on low incomes in rural areas. We will also publish research on decarbonising postal services
- Conduct research with disabled people living in rural Scotland to gather evidence on their experiences of a range of services including transport, health and social care and access to leisure
- Build on our previous assessment of issues in the rental housing market by conducting follow-up research into the experiences of low income tenants in the private rented sector
- Complete the first phase of extensive in-depth research on the views of consumers on investment in the water sector and future charges to inform Scottish Water’s draft business plan
- Undertake the next phase of our energy affordability tracker survey which has been running since Spring 2022. Energy work will also focus on the future of the retail market with a rapid evidence assessment of the key issues for consumers in Scotland as the market evolves
- Continue preparation for Consumer Scotland’s new responsibilities for heat networks consumer advocacy and advice. Work will include contributing to the development of heat networks regulation through upcoming consultation submissions to Ofgem and DESNZ
Contact Us
For more information about our work please get in touch via our email address at info@consumer.scot or write to us at Consumer Scotland, Thistle House, 91 Haymarket Terrace, Edinburgh, EH12 5HD.
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