Mitigating fraudulent claims must be addressed when establishing a shared Priority Services Register (PSR) between water and energy firms, Energy UK has said.
The trade association said that while the process for signing up to a shared PSR must not become too onerous for customers, it must find a way to prevent the system from being abused.
While Energy UK has called for the current “honour system” to remain in place for the shared PSR it has warned that it needs to be stringent enough to avoid fraudulent claims.
The honour system currently in place for the PSR is based on trusting customers to tell their providers the truth about their vulnerabilities, rather than making them prove it.
Energy UK’s submission to the government’s consultation on smarter regulation adds: “While the honour system should remain, the new PSR registration process still needs to look at ways to prevent fraudulent claims, that may be used to avoid meeting obligations such as paying a debt.
“Suppliers obligations to identify vulnerability should be connected to the PSR register.
“Suppliers should not have onerous, duplicate, and costly requirements to conduct additional checks to identify or confirm vulnerability to fulfil obligations where a customer is on the PSR.
“This would defeat the object of the new register which is supposed to provide a definitive source of information.”
It adds: “Individuals, as they can now, should still be able to self-report their vulnerability status and preferences directly onto the shared PSR.
“It is also important that nominated individuals can input PSR (data) on behalf of a vulnerable customer who may be unable to express their specific needs and requirements. This would also help address the challenge of ensuring the PSR data records are kept up to date.”
Energy UK has also called for an assessment to be carried out to ensure that the formation of a shared PSR doesn’t add costs to suppliers.
It adds that “any costs that suppliers incur must be planned for, ensuring that they are covered fairly and do not create any market distortion”.
The trade association’s submission adds that the best way to maximise the benefits of a shared PSR is to incorporate data sets held by government.
It says this would allow the most vulnerable members of society to be automatically enrolled to the register.
It adds: “The implementation of a multi-sector PSR would allow for government data to be utilised to enable auto-enrollment of customers who would be eligible for support for relevant affordability schemes.
“An example of this is the Warm Home Discount Scheme, where government data is used to identify eligible households who receive the Guarantee Credit element of Pension Credit or are on a low income and have high energy costs (including a range of qualifying benefits and tax credits to identify these households).
“This model could be used for further schemes such as the Energy Company Obligation (ECO) scheme as well as for any future targeted support – such as a social discount.”
As revealed by Utility Week, energy suppliers will soon begin switching from a process of explicitly asking customers for consent to share their data to one in which the substantial public interest clause is used to comply with data protection laws.
This will allow energy suppliers, who tend to have the richest data on customers, to share these details with water companies and energy networks. The latter two sectors began sharing their PSR data in March 2023 after resolving issues over a lack of standardisation in recording the data.