Nov 23, 2023

Creating a Multi-Sector PSR

Ruminations on improving the Priority Service Register

Andy Bell

In the Autumn Statement, the government announced a consultation for a multi-sector Priority Service Register. The Priority Service Register, commonly known as the PSR, is a list of vulnerable customers. Currently each utility company maintains its own PSR.

At HelpFirst, we have got experience of frontline casework, data governance and digital product development. We’ve also got a sideline in mapping PSR application flows. So we had a think about key questions  and tentative answers.  

Q: What's your initial reaction to the suggestion of building a universal PSR? 

A: It’s a good step. When providing frontline support, it is time consuming getting clients signed up to the right PSR. It made it harder for them to move energy suppliers and ensure they were on the best tariff. Navigating the PSR would probably be a minor inconvenience for most people reading this article, but for the people it is intended to serve - the most marginalised - it is often a complete blocker. In addition, the fragmentation of PSRs means it has lower awareness, and hence less usage, than it otherwise would have.

Q: What are some of the challenges with a universal PSR? 

A: Challenges that spring to mind include: 

Data ownership

Many people with vulnerable characteristics are worried about the government, especially the DWP, getting access to their data. It would be great to see a federated or perhaps blockchain-style solution, which allows the consumer to properly maintain ownership of their data, but those approaches are technically challenging with few examples of real success. The government mentions the DWP’s Tell Us Once as an inspiration, but Tell Us Once has less challenges around data ownership.

Keeping the data up to date

Currently utility firms have a responsibility to ensure that their data is verified every two years. With a universal PSR, who would take that responsibility?

Populating the universal PSR in the first place

Utility firms have made a big effort to get millions of people onto their PSRs. Our article Mapping the PSR shows each firm asks different questions, making the data incompatible. To populate the new universal PSR, either you’d have to start from scratch or find a way of dealing with the incompatible data. 

Q. Who has done good work in this area? 

A: Experian’s Support Hub is good. Two things they do well. Firstly, rather than worrying about the names of the vulnerabilities, the focus is on the implications of the vulnerabilities (e.g. “Send in giant print (20-32 point)”, “I use text-to-speech software to communicate - please take this into account” or “I prefer to meet or wait in a quiet space (if available).”) Secondly, they have taken the principle of co-design to heart, meaning their service is truly user-centred.

Q: If a universal PSR is better known and easier to use, might too many people sign up? 

A: That’s not really a risk. The help you get from being on the PSR is only useful to customers with vulnerabilities. It’s not like signing up for a package of freebies.

Q: Have you got any concerns about the idea of a universal PSR?

A: One criticism of the PSR approach is that it shows the government is retreating from caring for its people and leaving it to private firms. A universal PSR might be seen as a continuation of that retreat. But it is the route we are going down as a country so, short of a revolution, we probably need to make the best of it.   

Q. How would a universal PSR impact HelpFirst?

A: Our mission is to use AI to better care for the most vulnerable in society. If the data from the universal PSR was shareable, with appropriate protections, that could make our job much easier and allow us to go much further. 

Q: Any other thoughts? 

A: HelpFirst is funded through CivTech, a brilliant scheme which combines government projects with start-up innovation. The CivTech Process acknowledges that there are often multiple design approaches for any digital product and creates the space to explore several approaches. A universal PSR probably shouldn’t be controlled by the government or by a private firm. A CivTech-style competition could be a way to kick-start an innovative, data-centric, not-for-profit, independent organisation to build and run the universal PSR.

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.