Sep 19, 2023

AI: the missing link in Ofgem’s Vulnerability Strategy?

To care for vulnerable people at scale, you must first define who is vulnerable.

Andy Bell

Definitions make the world go round

If you want to care for vulnerable people at scale, you must first define who is vulnerable.

Ofgem know this. Documents like their Vulnerability Strategy 2025 and the Prepayment Meter (PPM) Code of Practice are heavy on definitions.

The Vulnerability Strategy’s first objective is ‘We want energy companies to act swiftly to provide support to the people who need it.‘ The appendix then contains 4 pages of definitions of how to identify those people.

The PPM Code of Practice says that utility companies should not install meters for high risk individuals, and then spends half a page defining ‘high risk’.

Lots and lots of words.

How utility companies puts this into practice

Suppose you run a utility company. To implement Ofgem’s regulations, you need everyone in your contact centre to understand their definitions. That’s the only way to implement their regulations. How are you going to make that happen?

You’d need to train thousands of contact centre agents. This takes months to organise. You need to rely on everyone turning up for training, then listening to the training, understanding the training and remembering the training. When that’s done, you need to start again with any new starters.

Then each agent needs to apply these definitions to thousands of cases, day-in day out. This time-consuming, and prone to errors. Surely, there must be a better way to implement Ofgem’s definitions across the business?

A better way

Large Language Models (LLMs) became famous on November 30th, 2022 when ChatGPT was released.

LLMs are a giant leap in the ability of computers to parse nuance and ambiguity in language. If a system can parse nuance and ambiguity, then it can scour through text to find instances that match particular definitions.

We can use LLMs to power a system that flags markers of vulnerability. With the right user interface, this could be a be a great assistant, alerting agents when there is a case that matches Ofgem’s definition of vulnerability.

Observant readers might notice that this sounds like keyword matching which has existed for ages. One difference is LLMs get much deeper into the meaning of language. The other difference is that it works.

This is what we are building at HelpFirst.

Three cool things about the HelpFirst approach

1. Definitions for computers in human language

Developing the HelpFirst prototype last week, we got stuck on how to identify consumers with safeguarding concerns. One bright spark suggested we base our definition on work by Social Care Institute for Excellence:

Does the case note mention any of the following kids of abuse:physical, sexual, psychological, financial, material, discriminatory, organisational/institutional?  Does it reference neglect by carer or self-neglect?  Does it referto domestic violence or is the client demonstrating suicidal ideation/self harm?

Once we add this definition to HelpFirst, the system can look for people who match that criteria.

This approach is effective for explainability. If a vulnerable client were to slip through the system, we can review the analysis to determine whether the definition was incorrect or whether the system failed to identify someone who met the definition.

This approach enhances credibility. We are not defining vulnerability on the fly. Instead, we build on the insights from experts.

This approach also facilitates organizational implementation. We can gather around a table to discuss and refine the definition of safeguarding in a more accessible language.

2. Dynamic vulnerability identification

Over the last decade there has been increasing awareness that vulnerability is often a transitory phenomenon. For instance, Ofgem’s Vulnerability Strategy says:

Vulnerability can affect anyone at any time and for many different reasons. It may be permanent or long-term, but equally it can be transitory following a bereavement or relationship breakdown. A consumer can quickly fall into a vulnerable situation, but it may take them time to recover from it.

Current approaches (that is, putting someone on the PSR) don’t really fit with this transitory model. HelpFirst, on the other hand, is really just observing what the client said most recently.

3. Goodbye self-reporting

Self-reporting is problematic. The Money and Mental Health Institute say that self-reporting  systematically disadvantages those who are less able to advocate for themselves.

In their response to Ofgem’s Vulnerability Strategy, they note:

Research with the Money and Mental Health Research Community found that just one infour (24%) respondents had ever told an energy supplier about their mental health problems. This identification-focused approach is most inadequate for the 36% of people with a common mental disorder who have never even received a diagnosis - equivalent to more than three million people in England alone.

HelpFirst can see what the customer is saying, without needing explicit prompts.

Examples from other industries

Perhaps you are thinking  it is too soon to be using LLMs in the enterprise. Here’s some evidence that it is happening already.

OpenAI use ChatGPT for their own content moderation challenges. Viewed abstractly, content moderation is a similar problem to vulnerability detection: lots of incoming text that needs to be matched against an organisation’s policies.

The article contains a nice animation (well worth taking a minute to look at) explaining how this works, showing how a policy is set, then experts observe where it fails, and then the policy is tweaked, all in human language.

The two tweets below show discuss the current crop of startups at Y Combinator, the leading accelerator. Most of the current YC startups are doing something like HelpFirst, but in different industries.



If you are responsible for vulnerable people at a utility company or any other large consumer facing organisation, we’d love to talk to you.

We are confident that Citizen Advice Scotland’s Extra Help Unit, our initial client, is going to benefit from the HelpFirst approach. But thanks to the unique and amazing nature of CivTech funding, we can also help other organisations too.

We’d like to explore how you deal with vulnerability detection and understand your pain points.

The Priority Services Register (PSR) is a key tool that energy suppliers use to fulfil their responsibilities to vulnerable customers. But there isn't just one register. Every energy company has their own PSR and the application forms vary unpredictably from supplier to supplier. 

As part of our CivTech Challenge, we’ve been researching best practice across the industry. We were left with lots of questions:

  • Why is 'restricted hand movement' a vulnerability that almost all suppliers assess?
  • Why are archaic phrases like ‘bedridden’ used?
  • Why does only one supplier check if their vulnerable customers use ‘electric showering’? 

Alas, we weren't able to fully answer these questions. But here’s a visual guide to various PSR forms, so you can get an overview of the landscape.  


We accessed PSR application forms for Ovo Energy, British Gas, SSE, Octopus, EDF, Shell and Utilita. For many other suppliers, access is restricted.

The first observation is that the application forms are extremely varied: 

  • We’ve grouped questions into categories to make things a bit easier to read, however the forms themselves come in very different structures.  Some offer all their options in one long list, some separate into smaller sections.  Some only show certain sections once a customer has selected a particular option (e.g. selecting ‘sight loss’ gets you extra questions on the Shell application).
  • Several vulnerabilities are only mentioned by one supplier. Only one asks about autism, and another asks about breathing difficulties. The following options only showed up once: ‘female presence preferred’, ‘longer time to answer the door’ and ‘bedridden’.
  • For sensory needs: ‘blind’ and ‘partially sighted’ are separate options in all the forms. 'Hearing impairment' and 'deaf' are combined in half the forms and the former is not asked at all in one. This may be contentious, as hearing impairment and being deaf are very different conditions.
  • Some suppliers include options for accessible information provision in the same form (i.e. braille, large print letters, etc.) Others link to an additional form, or do not reference it at all.
  • When temporary conditions are mentioned, only some suppliers allow the customer to select a date when they believe the condition will no longer apply.
  • Most of the forms are multiple choice, limiting to what the supplier chooses to ask about.  Occasionally the supplier (e.g. EDF) gives the customer a larger space to talk about their conditions, equipment and needs in more detail.

Next, we dive deeper into the application forms.

Medical Conditions2

Question asked
Question asked (with variations)
Question not asked
Speech impairment
Poor sense of smell/taste
Mental health
Dementia(s)/cognitive impairment
Non-English speaker
Chronic or serious illness
Partially sighted
Developmental condition
Restricted hand movement
Pensionable age
Physical impairment
Unable to answer door
Learning difficulties
Anxiety or depression
Heart condition
Living alone
Breathing difficulties
Receive disability benefits

EDF’s application form has the highest number of options related to medical conditions (20 in total) with British Gas and Utilita featuring the lowest (13).  EDF also features options which cover multiple medical conditions (e.g. 'breathing difficulties', 'disability benefits') more frequently than other suppliers. SSE has the highest number of options for learning and mental health related conditions (including 'dyslexia', 'autism', 'learning difficulties' and 'anxiety/depression').

There is some overlap within options, which could be confusing. For example, SSE lists both ‘developmental condition’ and ‘autism’ separately, even though the latter is a type of the former. Another example is the ‘mental ill health’ and ‘anxiety/depression’ options, again found in the SSE form. It is not clear if customers should tick both or only the more specific option.

All organisations feature options to indicate older age, however they specify a variety of different ages as the lower threshold, including:  60+, 65+, 'pensionable age' or 'pensioner'.  British Gas have two separate options relating to older age ('pensionable age (65 and over)' and 'age 75 and over').

There is some degree of consistency across organisations. This appears to be where specific conditions have been mentioned within the Ofgem guidance (for instance, 'restricted hand movement' appears in all but one form, in spite of the fact this is a very specific need).

Language Used

The language used across suppliers is very inconsistent. SSE uses ‘hard of hearing’ and ‘deaf’ to describe hearing loss-related needs, while other suppliers employ terms such as ‘hearing impairment’ or ‘hearing impaired’.

Some options have multiple potential meanings: ‘carer’ could refer to the respondent either needing a carer or being a carer for someone else.

All suppliers ask about speech and language difficulties and broader language barriers. However there is no shared way of asking whether a customer speaks English. Variations include: 'unable to communicate in English', 'language barrier' and 'foreign language speaker'.

‘Unable to communicate in English’ (used by Octopus and Ovo) is somewhat ambiguous. Customers might take it to mean having a different first language or having a speech condition. The requirements are quite different: with the former you could use an interpreter or multilingual support, with the latter you would need different support.

Medical Equipment3

Question asked
Question asked (with variations)
Question not asked
Stairlift/hoist/electric Bed
Heart/lung or ventilator machine
Dialysis, feeding pump automated medication
Nebuliser or apnoea monitor
Careline/telecare system
Medicine refridgeration
Water dependent
Medically dependent on showering/bathing
Oxygen concentrator
Oxygen use
MDE electric showering
Mains powered electric medical equip
Life support
Wheelchair user
Medical or other critical dependency

Options Offered

British Gas do not offer any specific options for types of medical equipment: they solely offer the generic category ‘mains powered electric medical equipment’.  All other organisations surveyed have more specific options.  These are broadly consistent across suppliers with some more limited options (e.g. ‘wheelchair’, ‘MDE electric showering’). 

Most organisations (bar British Gas and EDF) also ask about reliance on water.

Language Used

It is unclear what is meant by the ‘life support’ option used by EDF. Often the phrase ‘life support machine’ refers to a ventilator, but EDF also have a separate option for ‘heart and lung ventilators’. It could mean life support as a condition or set of needs but that seems too broad for the PSR.

Temporary Changes

In a rare show of unanimity, all suppliers offer the same options for temporary changes.

Question asked
Young adult
householder <18
Children age 5
and under
Temporary life change (bereavement/pregnancy)
Post hospital recovery

Other Questions

Question asked
Question not asked
Additional presence preferred
Regular meter readings
Move meter to support access
Extra time to answer door
Female presence preferred
Duplicate bill to family
Power of attorney
Financial difficulties


All suppliers offered the option of setting up a password or PIN. This is usually so a technician can state this password as an additional security measure on home visits. Two suppliers required a 6-letter password, one an 8-letter password and one a 10-letter password.  A final supplier did not specify length.  An unfortunate side effect of this variation is that if an individual were to move supplier, they may need to change their password and remember a new one. (Note: not shown in an infographic.)

Life Scenarios

Varying from the multiple choice standard, Shell veer into first person narratives. In their ‘Nominee Scheme’ section of the form, they feature an additional tick box option: ‘I can be easily confused and worried by communications from my energy supplier’. When asking about meter support they offer: ‘I have a prepayment meter and no-one in my household is able to safely read it or top it up’.

Accessibility Information4

Question asked
Question asked (with variations)
Question not asked
Large print letter
Alternative language: please specify
Black and white letter
Colour contrast
Arial font
Large print letter in black and white

Organisations vary on including accessibility questions on their PSR form. Ovo offers seven different accessibility options for receiving information, while Shell offers a single broad range checkbox.


Suppliers diverge considerably in what information they collect on their customers to register them for Priority Services support.

On our travels we encountered the aspiration to create a more standardised or universal PSR. Initiatives like the Vulnerability Registration Service and Experian’s Support Hub aim in this direction. In the future we are keen to explore the user experience of these services and how they aid vulnerable customers.  

In the meantime, we hope this analysis will prove useful if you are looking to improve the experience of vulnerable energy customers. Any questions or comments, contact We’d love to hear from you!

  1. SSE was acquired by Ovo Energy in 2020.  They hadn't completed their move over when we started this research and were still registering people to their PSR. We’ve included them in this analysis as their approach was interesting with many mental health and developmental condition-type questions.
  2. Some questions have been condensed in the infographics. Numbers referenced in the discussion refer to the full options as available on the questionnaires, but the infographics demonstrate a condensed version for brevity and ease of visualisation. Full original data is available on request.
  3. 'Heart/lung machine & ventilator' is the most common formulation of question regarding this equipment. However EDF separates these questions into: 'heart/lung machine' and 'ventilator'.
  4. Octopus and British Gas do not ask about accessibility. Shell only offers a general ‘accessible information’ needs tick box if the customer has earlier selected that they have a visual impairment. This does not mean they do not record this information elsewhere, where these questions did not appear on their forms we were not able to verify what (or if) they ask about accessible information.