Vulnerable customers must be treated fairly

Published: 24 February 2023
Last updated: 16 March 2023
  • Ofcom sets out how phone, broadband and pay-TV companies should treat those who are struggling
  • Covers those in debt, suffering physical or mental health problems, bereaved or victim of crime

People suffering financial, health or emotional problems should be treated fairly and given the right support by phone, broadband and pay-TV providers, under best practice industry guidance issued by Ofcom today.

The coronavirus pandemic has increased the potential for customers’ circumstances to change suddenly and providers are already offering additional support to people who are struggling to pay their bills to help them to stay connected.[1] But anybody can face circumstances that make them vulnerable – either temporarily or permanently. These might include physical or mental health problems, debt or unemployment, bereavement or becoming a victim of crime.

The graphic shows some statistics of how people in the UK are affected by circumstances that make them vulnerable. It sets out that 14.1 million people have a disability, that 2.5 million people are living with cancer, almost 1 million people are affected by dementia, 1 in 6 adults experience common mental health problem every week and 318 people are declared bankrupt or insolvent every day.

Ofcom’s job is to make sure that, whatever a person’s vulnerability, communications providers offer a high level of customer care, and the services and support people need.[2]

We require providers to have policies and procedures in place to make sure that vulnerable customers are fairly treated.[3] Today we are setting out the practical measures that providers could adopt, in light of these rules.

Jane Rumble, Director of Consumer Policy at Ofcom said: “We’re setting out industry best practice to help ensure vulnerable people are treated fairly and sympathetically by their phone, broadband and pay-TV providers.

“This is especially important at a time when many customers may be worried about their physical and mental health, as well as their finances.”

What providers can do

  • Plan for treating vulnerable customers fairly. Companies must publish clear, up-to-date policies which are easy to understand. These should be led from the top, with senior leaders accountable for embedding them in their organisation’s culture. We recommend that providers consult with experts, consumer bodies and charities to strengthen their understanding of different vulnerable customers’ needs.
  • Identify and communicate with vulnerable customers. Customers may be more willing to share information about their vulnerability if they know they can get extra support from their provider by doing so. Providers should therefore ask  customers at the earliest opportunity whether they have any accessibility or customer service needs that the provider can help with, and offer a range of ways to explain the help, support and services available – such as online forms, phone, post, email, web chat or video and text relay.[4]
  • Keep information about vulnerable customers’ needs. Frontline staff should accurately record and update customers’ needs in line with data protection legislation. This should be shared with other frontline staff on controlled internal systems, to avoid customers having to repeat themselves if passed to another department.
  • Train staff appropriately. All frontline staff should be trained on how to communicate with empathy and support, recognising that some vulnerable people may be reluctant to discuss their personal circumstances. They should be trained to recognise the potential characteristics, behaviours or verbal cues of someone who might be vulnerable and also be fully aware of the additional services available to help them. Specialist teams who primarily deal with vulnerable customers, including those in financial difficulty, may benefitfrom additional training.
  • Monitor and evaluate. Providers should regularly monitor changes in complaints levels, customer service survey results or other customer feedback. They should also consider mystery shopping, as well as focus groups and panels to gain feedback and share best practice.

Best practice examples suggesting how customers should be treated

People who are behind on their bills

We would expect providers to:

  • prevent customers from being disconnected wherever possible, allowing the customer time to get help and support, without the threat of enforcement actionduring that period;
  • offer payment holidays or deferrals, or freeze additional fees and charges;
  • discuss a realistic, reasonable and flexible repayment plan;
  • offer tariff advice, whether switching to a cheaper tariff or social tariff;
  • refer customers to debt organisations or charities that can provide free advice and support; and
  • use a range of communications channels to get in touch with the customer.

Victims of crime

  • make sure victims don’t pay for mobile phone services they have been unable to use if their phone is taken away by the police as evidence;
  • listen carefully with empathy and compassion, taking time to ensure the customer has the right information, which might include a crime reference number;
  • avoid pressuring victims to provide any more information than necessary, to avoid them reliving experiences;
  • and offer new numbers, temporary SIMs or handsets where appropriate.

Next steps

The measures set out in our guidance are not intended to be exhaustive. Ofcom will work with providers and review the guidance over time. We will also monitor companies’ performance – including against our Fairness for Customers Commitments, which are designed to strengthen how companies treat their customers.

James Taylor, Executive Director of Strategy, Impact and Social Change at disability equality charity Scope, said: “It’s great that Ofcom are taking action to hold service providers to account when it comes to providing a fair and equal service to disabled customers.Disabled people face hundreds of pounds of extra costs every month, and this often comes from everyday things like bills.

“That’s why it’s essential that service providers are able to be flexible, and respond to disabled customers’ individual needs to make sure they’re getting a fair price and full access to services. Customers’ needs and situations can change over time, so it’s essential that service providers recognise and respond to this.”

Peter Tutton, Head of Policy, Research and Public Affairs at StepChange Debt Charity, said: “We are really pleased to see the recognition that customers in arrears will generally be vulnerable, and the regulatory expectation that firms will give them the support they need through breathing space, affordable repayment plans, social tariffs, or referrals to debt charities like us for more holistic debt advice.

“Communications services are vital tools of modern life, without which many vulnerable people would simply be unable to access other support services. Maintaining access on an affordable basis can play a crucial part in helping people get back on their feet financially in a wider sense.”

Sandie Barton, Director of Operations at Rape Crisis Scotland, said: "We have heard from many survivors of sexual violence who’ve experienced uncompassionate and unhelpful responses from mobile providers when their phones have been seized for investigation.

“Ofcom’s moves to address this issue are welcome and in particular the focus on preventing re-traumatisation and providing practical assistance. In signing up to these guidelines, mobile providers could prevent the financial burden and bureaucratic inconvenience that too many survivors face and make a real difference. We’ll continue to seek feedback from survivors to help monitor the situation and advocate for accountability and improved practice across the board."


  1. Article on how telecoms providers are supporting customers who are struggling to pay their bills during the pandemic to help them to stay connected:
  2. Many people find dealing with energy, water and telecoms companies too stressful an experience; more than a third (37%) of people who have experienced a mental health problem, for example, exhibit significant levels of anxiety when dealing with their essential service providers.
  3. General Conditions C5.1-5.5 came into force in October 2018
  4. Providers are required to provide text relay services and certain communications such as bills in large print or Braille to certain disabled customers.

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