Energy debt hits vulnerable customers hardest. Many are on low or fixed incomes, have health conditions, or rely on energy for medical equipment – making it difficult to cope with rising bills. According to Citizens Advice, they helped over 92,000 people with energy debts in 2024 – the highest on record. The average debt among those clients swelled to £1,400 by December 2024 (up from £1,250 a year prior).  

Falling behind on energy bills is stressful and harmful – it often deteriorates mental health and forces people to ration energy or cut back on essentials like food. Vulnerable customers can become trapped; once in debt, they face restrictions on switching tariffs and risk being stuck on unaffordable plans. Ofgem’s recent consultation recognises that the energy affordability crisis is “far from over” and that without new approaches, debt and its impact will continue to grow.

Ofgem’s push for personalised energy support 

As part of its debt reform agenda, Ofgem aims to introduce a “debt outcome” or “debt guarantee” that ensures all customers in payment difficulty receive compassionate, empathetic support. This includes tailored solutions for vulnerable customers. Ofgem explicitly wants suppliers to never forcibly leave a vulnerable person without energy supply and to provide “appropriate, tailored and proactive advice” to anyone struggling, so they never feel forced to self-disconnect. 

In practice, this means moving beyond generic repayment plans. Suppliers will be expected to consider each customer’s individual circumstances – their income, essential expenditures, and any vulnerabilities – when formulating debt relief or repayment options. It also ties into a proposed one-off “debt relief scheme” targeting those hardest hit by the energy crisis. Ofgem is currently consulting on a scheme that could write off £0.5–1 billion of energy debt for customers in severe financial difficulty, particularly those in vulnerable situations with crisis-era debts. Such a scheme, if implemented, would directly reduce the burden for thousands of the most distressed households and give them a chance to recover. 

The role of Income & Expenditure (I&E) tools in personalised debt relief

To meet these expectations, suppliers need a robust way to capture and act on each customer’s unique financial situation. Embark is an income & expenditure digital tool designed to do exactly that. It enables energy companies to view the financial health of each customer through an affordability assessment, in a user-friendly format. Here’s how Embark can empower suppliers and vulnerable customers:

• Holistic financial assessments – Embark guides customers (or agents) through documenting all sources of income, outgoings, and priority expenses. This holistic I&E assessment ensures nothing is overlooked – from rent and food costs to disability-related expenses. By seeing a comprehensive picture, suppliers can determine what a customer can genuinely afford to pay, without hardship. This prevents the all-too-common scenario of setting payments that look feasible on paper but leave a vulnerable person choosing between heating and eating.
• Tailored payment plans and free debt advice signposting – The data from Embark allows for truly tailored solutions. The assessment can pull in open banking and credit reference agency data to provide a complete picture, this enables suppliers to have a more rounded and open discussion with the customer of what is affordable. Further signposting to other services can also be made after the assessment is completed. Embark has the ability to connect you to our partner PayPlan for free debt advice, staying within one customer journey.
• Notably, Ofgem has encouraged the use of “debt repayment holidays” to give struggling customers breathing space. If the Embark profile shows the customer can only afford £20 per month towards their arrears, the plan can be set accordingly. This level of personalisation helps ensure repayment arrangements are sustainable and compassionate, in line with Ofgem’s envisioned debt guarantee of high standards.
• Identification of vulnerabilities – Embark can be configured to capture vulnerability indicators – for instance, if a customer is of pensionable age, has a disability, or relies on electric medical equipment. Identifying these factors is critical. It triggers suppliers to apply relevant safeguards (like registering the customer on the Priority Services Register, if not already) and to consider debt relief options more readily.
• Empowering customers through self-service: One of Embark’s strengths is that it can be offered as a self-service digital tool. Customers, at their own pace, can fill in their income and expense details via a secure online portal (with phone support if needed). This is empowering for vulnerable customers who might feel embarrassed or anxious discussing their finances live with an agent. They can involve a family member, carer, or support worker in the process if they wish. By handing more control to the customer, Embark makes the debt assistance process feel less daunting and more collaborative. Importantly, it also captures an accurate and honest account of their finances, since the customer has time to gather bills, check bank statements, and ensure everything is included. The result is a more reliable I&E assessment, leading to a more effective solution.

Aligning with Ofgem’s “Debt Relief” vision 

Using Embark directly supports the outcomes Ofgem is looking for. Ofgem wants customers in difficulty to “easily access and understand empathetic and sustainable options to manage their debt”, including forbearance when needed. By presenting options based on a customer’s Embark data – such as reduced payment plans, writing off small balances, or applying for grants – suppliers can demonstrate compliance with this principle. Moreover, should a formal Debt Relief Scheme be introduced, having Embark in place means a supplier can efficiently identify eligible customers (for example, those who meet certain income thresholds or vulnerability criteria) and handle the application process. In its consultation, Ofgem noted that an application route for debt relief might require an income/expenditure assessment, which has the side benefit of boosting engagement between consumers, suppliers, and debt advisors. Embark would be the ideal platform for such assessments – making it straightforward for customers to submit their financial information as part of a relief program. In short, Embark helps transform Ofgem’s vision of “compassionate and empathetic support” from words into a working reality. 

Treating customers as individuals Empowering vulnerable customers requires deep personalisation – a nuanced understanding of each household’s challenges and a commitment to adjusting solutions accordingly. Ofgem’s consultation makes it clear that the era of superficial, one-size-fits-all payment plans is ending; in its place comes a more humane, data-informed approach to debt relief. Paylink’s Embark tool is a key enabler of this approach. By harnessing Embark, energy suppliers can confidently demonstrate that they treat customers as individuals – especially those in vulnerable situations – and provide the empathetic, tailored relief that the new framework demands.