Thursday 20 March 2025
10:00 – 12:30
Edinburgh, Consumer Scotland Offices
Present:
- Consumer Scotland – David Wilson (Chair); Sam Ghibaldan; Douglas White; Eleanor Mullan; Andy Murphy; Grace Remmington; Catriona Kirk.
- Advertising Standards Authority – Matt Wilson
- Advice Direct Scotland – Pam Stewart
- Competition and Markets Authority – Brendan McGinty
- Department for Business and Trade – Carol Rice
- Federation of Small Businesses – Vikki Manson
- Financial Conduct Authority – Euan Macfarlane
- Ofgem – Kathryn Kennedy
- Communications Consumer Panel – Jenny Borritt
- Trading Standards Scotland – Fiona Richardson
- Ofcom – Ross Hamilton
- Ofcom – Dion Barnaby
- Trust Alliance Group – Craig WIlson
- Ofcom – Hannah Mummery
- Citizens Advice Scotland – David Hilferty
Apologies:
- Scottish Government – Wendy McCutcheon
- Scottish Public Services Ombudsman – Andrew Crawford
- Scottish Legal Complaints Commission – Vicky Crichton
- Ofgem – Adam Cochrane-Williams
- WICS – Andrea Mancini
- Which? – Tim Mouncer
- Society of Chief Officers of Trading Standards in Scotland (SCOTSS) – Alex Connell
- Transport Focus – Robert Samson
- Federation of Small Businesses – Stacey Dingwall
- Trading Standards – Fiona Richardson
Welcome and introductions
1. The Chair welcomed everyone to the meeting with a round of introductions, and thanked everyone for attending. Welcomed guest speakers and gave an overview of agenda.
Minutes and matters arising
2. Members approved the minutes of the December 2024 Consumer Network meeting for publication on the Consumer Scotland website. Also noted that as of 1 April the final guidance on the Consumer Duty would be going live – many members had expressed an interest.
Future of the Universal Postal Service; Ofcom
3. Ross Hamilton, Regulatory Affairs Manager, and Dion Barnaby, Policy Graduate, gave an overview of Ofcom’s consultation on the review of the universal post service and other postal regulation. Summary of main points:
- Ofcom keen to encourage responses on consultation which is open until 10 April.
- Highlighted the need for USO reform; policy has remained largely unchanged since 2011, whilst letter volumes have decreased, parcel volumes have increased.
- Reform required to better support consumers. Risk of current obligations becoming financially unsustainable as declining letter volumes have driven up average cost of delivery.
- Ofcom are required to assess the extent to which the UK postal market is meeting the needs of users prior to making any potential changes to the USO.
- Ofcom believe that needs of most users would still be met with a reduced delivery frequency for Second Class, provided next day delivery continues.
- Targets are comparable to or higher than European and International standards.
- Noted that RM must achieve significant growth in parcels, manage decline in letter volumes, and improve efficiency by adapting accordingly.
- Unlikely that Ofcom can do more under current regulatory framework to respond to challenges facing the universal service.
- Noted RM running pilot of operating model at present. Consultation closes 10 April, Ofcom decision likely in Summer ’25.
4. Grace Remmington, Head of Post at Consumer Scotland, gave an overview of Consumer Scotland’s response to Ofcom’s consultation. Summary of main points:
- CS have conducted a number of pieces of consumer research related to USO reform, including work with low income and rural consumers.
- Note that there has been a large decrease in some post volumes, however, important that USO works for consumers now and in the future.
- Need fuller understanding of the implications of a 2.5 (alternate day) delivery model for consumers.
- Impact on rural communities needs to be better understood – especially impact for those exempt from quality of service standards.
- Affordability remains a key issue, and how consumers make the choice between cost and service.
5. Grace provided some guiding questions on screen to kick-off wider group discussion.
Group Discussion
· Will change to delivery model contribute to a higher quality service? There is a degree of conditionality. Proposals are an attempt to assist with future viability of postal service. Weekend deliveries will be maintained for first class letters. Some behaviour changes needed on part of consumers – i.e. thinking about when post will actually arrive. Will require better preparation on the part of consumers.
- Question around whether alternate day delivery has been put to consumers directly. Ofcom noted that while the proposal was based on user needs research, the specific alternate weekday model had not been tested as part of this. Noted general expressions of dissatisfaction more common than feedback on specific aspects of the changes.
- Point made that alternate day model is potentially confusing for consumers, and will require careful communication if rolled out.
- Further details requested by members on enforcement regime – where is the incentive for RM to improve service? How can performance be improved? What are current limits, and what other levers exist? RH noted he can provide more info on enforcement regime – info to be circulated to the group.
- What assurances can be given on improvement of service? What is Ofcom’s confidence level? Ofcom noted that they wouldn’t be proposing changes if they were not realistic to achieve.
An update on energy debt in Scotland
6. David Hilferty, Director of Impact at Citizens Advice Scotland provided an overview and update on the above.
- CAS has returned £160m to communities in Scotland through ongoing advice work – much of this in energy.
- Energy is second highest advice area. Almost one in five people supported by network needed energy advice.
- 55% of people supported with energy also needed advice on social security.
- Since 2022 – 56% increase in those seeking trust fund applications, 34% increase in those seeking prepayment meter advice.
- Price cap, inflation, and other issues are contributing to consumer harm.
- Energy debt is out of control and has more than doubled since 2018. Unique issue as consumers are continuing to use energy whilst racking up debt.
- Debt write-off in energy should be considered. The problem is rooted in markets not in people. Consideration should also be given to some kind of social tariff.
- Kathryn Kennedy from Ofgem noted that she can share more information on ongoing consultation.
An update on Consumer Scotland’s Work Programme
7. Douglas White, Director of Policy & Advocacy, provided an overview of CS’ work programme, and how the outcomes therein can assist in developing themes for the Network moving forward.
- Overview provided of overarching WP outcomes:
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- Fair and affordable markets
- Investing for the future
- Trustworthy, high-quality services
- Consumers at the heart of Scotland’s society and economy
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- Discussion followed on what items Network members would like to see explored / discussed by the Network.
- Noted that it would be useful for any investigation / research reports that CS and others are undertaking to be shared.
- General agreement that it would be useful to have something on financial services and the FCA consumer duty – opportunity to share learnings on the two duties.
- An exploration of green home heating would be welcomed. Perhaps something in partnership with CS investigation outcomes.
- Some members noted appetite for an item around economic growth, given current government focus, and how this intersects with consumer outcomes.
Flash updates
- Ofcom have launched telecoms access review for 2026-2031. Focused on economic regulation of the wholesale market of fibre.
- FSB noted that their small business survey has just closed. Likely published at the beginning of summer.
- FCA noted that their recent review of fair treatment of vulnerable circumstances has completed. Also, their new 5-year strategy being launched late March – details will be shared. Themes will centre on growth, protecting consumers, financial crime, and being a more effective regulator.
- CMA noted similar focus on growth at their end, and also that they had recently welcomed a new Chair (Doug Gurr). Noted that regulation of Legal Services Scotland Bill has completed second stage.