Committee for Consumers in Vulnerable Circumstances
Minutes of meeting, Meeting 11, 12 February 2026, 10.00am – St Vincent Plaza, Glasgow
Attendees
Angela Morgan, Chair (Board, Consumer Scotland)
Douglas White (Director of Policy and Advocacy, Consumer Scotland)
David Wilson (Chair, Board, Consumer Scotland)
Sam Ghibaldan (Chief Executive Officer, Consumer Scotland)
Kendal Morris (SP Energy Networks)
John McKendrick (Glasgow Caledonian University) – Scottish Equality and Poverty joined remotely
Artemis Pana (Scottish Rural Action) - joined remotely
Jane Williams (Head of Research, Consumer Scotland)
Kirsten Urquhart (Young Scot) joined remotely
Aaliya Seyal (Chief Executive Officer, Legal Services Agency)
David Jackson (Policy and Advocacy Officer, Consumer Scotland)
Sally Sandground (Finance and Governance, Consumer Scotland – Minutes)
Apologies
Twimukye Macline Mushaka (Representing herself)
Lucy Mulvagh (the ALLIANCE)
Karen Nailen (Chief Executive, West Lothian Citizens Advice Bureau)
Agenda Item 1: Arrival
Agenda Item 2: Welcome and Introductions
1. The Chair welcomed Committee members to the eleventh meeting of the Advisory Committee on Consumers in Vulnerable Circumstances.
2. Apologies were noted and members unable to attend had been invited to provide any feedback on papers via email.
3. The minutes of the previous Committee meeting held on 19th November 2025 were approved.
4. The Chair welcomed attendance at the meeting by the CS Chair and the CEO which was a recommendation arising from the committee review last year.
Agenda Item 3: Postal Affordability and Consumers with no fixed address
5. Grace Remmington, Head of Post Policy and Advocacy, and Rianna Price, Post Policy Officer were introduced to the Committee. They joined the meeting to deliver presentations on “Postal Affordability” and “Consumers with no fixed address in Scotland”.
6. Key points from the “Postal Affordability” presentation included:
- An overview of the current landscape relating to postal services reform
- The importance of post as a social necessity, particularly for households dependent on postal services for essential communication
- Affordability challenges for consumers, especially those reliant on post for essential communications.
- Ofcom’s ongoing work in this area and the wider regulatory context including the scale of the proposed reforms, described as the most significant since the introduction of the universal service obligation (USO), the continued focus of the USO on letters, and the Completion of Phase 1 of the review, in which Consumer Scotland had been actively involved.
- A summary of Consumer Scotland’s response, including our caveated support for a targeted scheme and the requirement for an effective, fair, and accountable price regime.
- Our concerns regarding the potential removal of the safeguard cap, which would place postal services out of line with comparable regulated markets.
7. The Committee were invited to provide feedback or ask questions. An overview of the discussion is below:
- The importance of accessibility to postal services for a range of communities, including deaf consumers
- Opportunities were identified to connect with small‑business and voluntary‑sector sectors who rely on wet‑signature legal documents increasing administrative costs
- Discussion on the impact on areas with limited access to legal aid services
- Discussion whether regulatory levers or financial incentives could be applied as well as fining powers, including a discussion around segmenting satisfaction metrics by service type and targeted consumer groups.
- The Chair thanked Grace for the overview and committee members noted their interest in this subject. It was agreed that the Post team would attend a future meeting to update members on this topic.
9. Key points from the “Consumers with no fixed address in Scotland” presentation included:
- Citizens Advice have been advocating for Address and Collect scheme since 2018, and have asked Consumer Scotland to become involved
- This service could be of benefit to consumers who are homeless, victims or survivors of domestic abuse, as well as Gypsy, Roma, and Traveller communities
- Address and Collect scheme is a proxy address to collect at post office which gives consumers the opportunity to access post safely and privately
- Consumer Scotland have sought views from stakeholders in Scotland, which were positive and broadly supportive
- It was explained that Scotland’s unique legal, rural and island context could potentially require localised adaptations
- For homeless consumers this scheme would provide a continuous address to better support their needs
- For victims or survivors of domestic abuse this scheme would provide a safe alternative, especially if trauma informed to minimise administration barriers
- For gypsy, roma, and traveller communities this scheme would provide help to overcome existing barriers providing a neutral location, language accessible and available across the UK
10. The Committee were invited to provide feedback or ask questions. An overview of the discussion is below:
- The importance to engage with organisations regarding post for vulnerable consumers where victims are still living in the family home. Other issues included the need for accessible formats such as Easy Read, and challenges around building credit for those in temporary accommodation. A trauma‑informed approach would be important to avoid repeated retelling of traumatic experiences, as well as considering the risk of financial abuse.
- Concerns were raised about the lack of established systems for post to support asylum seekers with no access to public funds. Some homeless centres are currently being used informally as a base for such support, raising questions about appropriateness and consistency. It was recognised there is a need to understand the legal implications and ensure processes are safe, compliant, and suitable.
- A discussion was had around young people rarely engaging with traditional routes such as Citizens Advice, so there is a need for flexible and accessible options, perhaps the use of lockers. Partnerships with initiatives like the Young Scot card would be beneficial to help improve reach as well as access to legal ID
- There will be an upcoming roundtable involving Ofcom, DBT, the Post Office and Royal Mail, covering issues such as cost, GDPR, and operational considerations. This provides an opportunity to ensure that the Scottish context is considered in the design and development of future proposals.
11. The Chair thanked Grace for the overview and committee members noted their interest in this subject. It was agreed that the Post team would attend a future meeting to update members on this topic.
Agenda Item 4: Consumer Scotland CEO and Chair Strategic Discussion how the CCVC supports our work
12. Sam Ghibaldan, CEO of Consumer Scotland and David Wilson, Chair, introduced themselves to committee members and both spoke about Consumers Scotland’s role as the statutory advocate for consumers and how the CCVC supports this work, which included:
- Consumer Scotland being required by statute to have regard to consumers in vulnerable circumstances, understanding detriment across markets and to promote fairness and which shapes priorities within the work programme and strategic outcomes. CCVC have and continue to provide valuable guidance in this area
- Our advocacy work must be evidence‑based and this is led and provided by our research and data‑analysis capabilities. The organisation is also evolving through building partnerships with advice bodies and becoming a grant provider, helping guide and drive the consumer‑advice landscape. This will be further reflected in the 2027–32 Strategic Plan
- As we are building our investigations function we need to ensure vulnerability is considered.
- We have worked with the Office for Product Safety on the product‑recall register
- Consumer Scotland works with CEOs of other organisations to improve information and advice provision, promoting consumer interests in various areas.
- Consumer Scotland statutory remit is unusual in the UK, as it includes some advocacy on GB‑wide issues such as energy. The increasing complexity of consumer challenges requires careful prioritisation to ensure the greatest impact for consumers, particularly those most at risk.
13. The Committee were invited to provide feedback or ask questions. An overview of the discussion is below:
- The members reflected positively on the importance of the Committee’s role in guiding and advising Consumer Scotland, in shaping direction and identifying priority areas affecting vulnerable consumers
- Members highlighted the value of building a broad, diverse representative group capable of making a transformative contribution, noting the strong foundations that enable continuous improvement rather than a tick box approach
- The Chair emphasised the ambition to ensure insights and solutions remain evidence‑based and rooted in research, supported by our strong partnerships
- Members stressed the importance of seeing the impact of their contributions and circle back on impact and outcomes
- Reflections included how the group’s work has already strengthened Consumer Scotland’s work on rural disability, transport and accessibility issues, however there is also the need to consider emerging risks such as misinformation, fake content and the influence of social media
- Members noted the importance of staying aligned with the original purpose of the group as it evolves and recognising the mutual benefit o Significant concerns were highlighted around metering and billing practices, as CAS reporting that 64% of heat‑network‑related cases relate to these issues. Problems include lack of individual meters, retrospective billing, disproportionately high standing charges, and risks associated with prepayment meters—where consumers are more likely to self‑disconnect. These issues are impacting both physical and mental health.
- f drawing on their networks, expertise and research
- The Chair thanked everyone for their input, as the cross‑sectoral perspectives provided by the Committee are unique, enriching Consumer Scotland’s understanding of consumer issues
- The Committee acknowledged the completion of this action.
Agenda Item 5: Regulation of non-surgical cosmetic procedures
14. Douglas White (Director of Policy and Advocacy, Consumer Scotland) provided an update on the Regulation of non-surgical cosmetic procedures
- Consumer Scotland are supportive of the regulations however calls for the regulations to be strengthened and advocates for more action in specific areas, for example, clearer action in key areas such as practitioner support, the involvement of Business Gateway, the Advertising Standards Authority and the need to consider indemnity insurance and improved signposting to specialist advice are important.
- Overall there is strong support so this Bill should pass and expected to go live in 2027
- David reiterated how important it was for the Committee to hear about this work and how is relevant to vulnerable consumers and wider consumer safety
Agenda Item 6: Regulation of Heat Networks
15. Alistair Hill (Head of Energy Transition, Consumer Scotland) was introduced to the Committee to provide an update on Heat Networks:
- Since 1 April 2025, Consumer Scotland has become the statutory advocate for heat network consumers, formally representing their interests and delivering advice through ADS for Tier 1 support, with the Extra Help Unit providing Tier 2 support, including for consumers in vulnerable circumstances
- He outlined where Consumer Scotland sits within the wider regulatory and advice landscape, highlighting its role in feeding evidence and insight into Ofgem’s decision‑making, alongside Citizens Advice
- Research undertaken over the past year identifying the key challenges faced by heat network consumers, providing an evidence foundation to understand issues, track impact over time, and shape future advocacy and policy work
16. Jade presented the Research paper which was produced as there is limited representative research and even less on consumers in vulnerable circumstances. Key issues identified include
- High prices combined with consumers’ inability to choose suppliers, privately owned networks operating without a price cap, and contract lock‑ins which allow price rises without any warning or limits
- Significant concerns were highlighted around metering and billing practices, as CAS reporting that 64% of heat‑network‑related cases relate to these issues. Problems include lack of individual meters, retrospective billing, disproportionately high standing charges, and risks associated with prepayment meters—where consumers are more likely to self‑disconnect. These issues are impacting both physical and mental health
- Further issues include debt and debt‑collection approaches, bundled charges linked to rent, and service‑quality concerns such as overheating (causing health risks to older people, children and those with chronic illness) as well as frequent unplanned outages
- Heat Networks consumers also from lack of consumer protection due to the limited regulation of the sector
- It was noted however there are some good practices in newer Heat Network examples—such as Clydebank and Edinburgh—which are delivering affordable, renewable heat
- This research will be used to inform further Heat Networks work
- The Committee members discussed whether HN regulations should mirror existing energy protections, and Consumer Scotland confirmed the aim to ensure the priority of securing strong protections for people in vulnerable circumstances
Agenda Item 7: AOB/Next Steps
17. The Chair noted there were some actions to be followed up
18. David Jackson informed the Committee that the next meeting was to be held in May.
19. With no other business, the meeting was closed.
Confirmed Dates for Upcoming Meetings
14th May 2026 – 10.00 – 13.00
August 2026 date tbc