The prepayment meter scandal did not happen because firms ignored vulnerability. It happened because the systems designed to protect vulnerable customers were never embedded into the processes that affected them most.
When the scale of forced prepayment meter installations became public, the response was swift. Ofgem intervened. Licences were reviewed. Suppliers promised change. The headlines focused on the behaviour of individual firms. But the underlying problem was structural, and it has not gone away.
The firms involved were not, for the most part, firms without vulnerability policies. Many had training programmes, identification processes, and published commitments. What they did not have was a reliable connection between those commitments and the enforcement and collections processes that were causing the most harm
Where the system broke
Prepayment meter installations sat at the sharp end of the collections journey. By the time a customer reached that point, they had often passed through multiple touchpoints where vulnerability could have been identified and acted on. In many cases, it was identified. The vulnerability flag was there. But the collections process was not designed to respond to it.
This is the pattern we see across utilities. Vulnerability is recognised at the front end of the business. Contact centre teams know what to look for. Priority Services Register (PSR) data is collected. But the further a customer moves into operational processes, the less visible their vulnerability becomes. By the time they reach enforcement, debt recovery, or meter operations, the vulnerability flag is either so far buried it’s not visible, or it was never designed to travel that far down the customer journey.
The Ofgem Consumer Vulnerability Strategy makes it clear that suppliers must embed vulnerability in their operations. Not just in customer-facing interactions, but across the full range of processes that affect vulnerable customers. The prepayment meter crisis showed what happens when that embedding does not reach the parts of the business where the stakes are highest.
What has actually changed
Since the intervention, many suppliers have strengthened their controls around prepayment meter installations. Some have gone further, reviewing how vulnerability data flows through their operational processes and where it drops out. These are positive steps and we highlight good practice when we see it.
But the question is whether these changes are structural or reactive. A process change made in response to regulatory pressure is not the same as a service redesigned around the needs of vulnerable customers. One is a fix. The other is an embedded way of working.
The firms that have made the most progress are the ones that used the crisis as a catalyst for something broader. They mapped their vulnerable customer journeys end-to-end, including the operational and enforcement stages. They asked colleagues in those teams what they see and what they need. They looked at the data, not just the complaints, to understand where foreseeable harm was most likely. They consulted vulnerable customers for the true picture of what happens.
Critically, they also looked at what was working well. Not every part of the collections journey failed vulnerable customers. Some teams had developed good practices informally, adapting the process to meet customer needs without formal support. Identifying and scaling these practices is often quicker and more sustainable than designing from scratch.
The question nobody asked
Before the prepayment meter crisis, few suppliers had asked a simple question: what happens to a vulnerable customer when they enter our enforcement process? Not what should happen. Not what the policy says. What actually happens.
This is the question that lived experience discovery is designed to answer. When you sit with vulnerable customers who have been through these journeys, when you speak to the colleagues who deliver them, and when you follow the data through the process, the picture that emerges is often very different from the one the policy describes.
The firms that ask this question before a crisis, rather than after one, are the ones that protect their customers and their reputation. They do not wait for a regulator to tell them where the gaps are. They go looking.
And the question applies beyond prepayment meters. Every operational process that touches a vulnerable customer, from disconnections to debt recovery to engineer visits, carries the same risk. If you have not mapped how vulnerability flows through these journeys, you do not know where needs are not being met and your next crisis may come from.
Let’s talk
If you want to understand how vulnerability sits across your operational and enforcement processes, not just your customer-facing interactions, we can help. We work with financial services, utilities and housing suppliers to map vulnerable customer journeys end-to-end and identify where gaps pose the greatest risk.