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Jemma baker Ofgem
6 min

Ofgem: Raising the Bar on Energy Communications

Posted by Picture of Sam Kendall Sam Kendall

Good regulation only works if customers can actually understand what organisations are telling them.

Jemma Baker is Deputy Director of Future Retail Policy at Ofgem, the energy regulator for Great Britain.

In this episode of Regulated Digital, Jemma joins us to unpack what “good” really looks like in regulated customer communications, why vulnerability and clarity are inseparable, and how outcomes-based regulation could reshape service standards across the energy sector.

From billing clarity and energy literacy to digital channels, AI, and accountability, the sections below cover how regulation can raise service standards without getting in the way of better customer experiences.

Watch the full episode above, or on YouTube or Spotify, or listen on Apple Podcasts.

Created from episode transcript

Raising the Bar on Energy Communications

Regulation and customer experience are often framed as opposing forces.

In practice, they are deeply linked.

Ofgem’s role is to protect the interests of current and future consumers, and communication sits at the heart of that responsibility.

Retail energy is complex by nature, with technical concepts, pricing structures, and regulatory requirements layered into everyday interactions.

When communications fail, trust erodes quickly.

When they work, they create confidence, understanding, and better outcomes for customers.

What Good Looks Like in Regulated Communications

Jemma outlines four principles that underpin Ofgem’s expectations for customer communications.

  • Plain language: Communications should avoid industry jargon and explain concepts in everyday terms.
  • Compassionate tone: Messaging should recognise that customers may be under financial, emotional, or cognitive pressure.
  • Choice of channels: Customers should be able to engage in ways that suit them, including non-digital routes.
  • Personalisation: Communications should be relevant to the individual, not only the average customer.

These principles shape how Ofgem develops guidance and rules, including work to raise service standards across the sector.

The aim is genuine decision support, not checkbox compliance.

Where Organisations Still Get It Wrong

Even with good intentions, organisations can trip up in predictable places.

Billing is perhaps the clearest example of this.

Why Billing Still Creates Distrust

Billing remains a common driver of complaints and escalations in the energy sector.

It combines technical calculations, specialist terminology, and real financial consequences in one place.

Customers need to understand what they used, how it was calculated, and what it means for what they owe.

When the bill is hard to follow, customers are less able to spot errors, challenge issues, or change behaviour confidently.

That pattern shows up repeatedly in complaints data.

"Bills can be quite complex, but it’s really important that customers understand how their usage has been calculated and what that means for cost."

Jemma Baker, Deputy Director of Future Retail Policy, Ofgem

Energy Literacy Is Not Evenly Distributed

Energy literacy varies widely across the population.

Some customers have years of experience managing bills. Others are navigating it for the first time, often alongside other pressures.

Financial vulnerability, mental health challenges, numeracy barriers, and digital exclusion can all compound the gap.

Designing communications for the “average” customer can leave many people behind.

That is why Ofgem places increasing emphasis on outcomes, evidence, and protections for consumers in vulnerable situations, including its vulnerability strategy.

Designing Communications That Work Under Pressure

Supporting vulnerable customers should be built into everyday service design.

Channel Choice Can Reduce Friction

One of the most practical levers organisations control is channel choice.

For customers in difficulty, calling can feel like the hardest first step.

Alternatives like SMS, chat, or app-based support can lower the barrier to asking for help.

At the same time, digital channels can't replace traditional ones.

Some households still lack reliable internet access, and many others lack confidence or skills to use online services comfortably.

Collaboration Improves Real-World Clarity

Jemma also points to collaboration with specialist organisations as a practical way to raise standards.

Groups focused on numeracy, lived experience, and vulnerability help suppliers test communications with real people.

That can shift design from assumption to evidence.

"When regulators set expectations for plain language and channel choice, suppliers still need delivery systems that keep messages consistent whether they go out by post, email, or an app."

Paul Holland, Founder and CEO, Beyond Encryption (Mailock)

Digital Channels, Trust, and Consistency

Digital communication has evolved relatively quickly. Apps, portals, and chat tools now handle sensitive customer information at scale.

Trust is critical for communications effectiveness.

Consistency Builds Trust Across Channels

For customers, trust is built through consistency.

Information should match across paper bills, emails, apps, and conversations with support teams.

When messages conflict, confidence collapses.

Respecting communication preferences matters too.

If a customer has asked for digital delivery, organisations should honour that choice, and keep non-digital routes available when needed.

Digital-First Cannot Mean Digital-Only

Digital-first approaches can improve access and convenience.

But regulated organisations still need to plan for exclusion, not assume it away.

 

Choosing The Right Customer Channel?

Read our research on portals, logins, email, and post before deciding how customers should receive important documents.

Read the customer preference research

Keeping traditional channels open supports fairness, accountability, and consumer confidence.

Energy Literacy and the Next Wave of Complexity

Decarbonisation is increasing the number of decisions customers need to make.

Heat pumps, solar, smart tariffs, and storage systems add new variables to everyday life.

Clear Communication Enables Better Choices

Customers are being asked to make more complex choices than ever.

They are weighing price, timing, behaviour, and new technologies.

Without confidence in the basics, these decisions can feel overwhelming.

Clarity is a prerequisite for trust and adoption.

Outcomes-Based Regulation and Innovation

Ofgem is exploring a shift towards more outcomes-based regulation.

This gives organisations more flexibility in their communications and customer experiences while empowering them to enhance service.

Focusing on Results, Not Process

Outcomes-based rules define what “good” looks like, rather than prescribing a single route to achieve it.

Being easy to contact is one practical example of an outcomes-based rule.

Organisations can innovate on how they deliver that outcome, while still being accountable for whether customers can actually reach them.

This approach can help regulation keep pace with technology and service change.

Testing Change Through Sandboxes

Sandboxes create space to test new approaches safely in coordination with industry.

Suppliers can also raise where rules create friction and explore whether there is a safe way to trial alternatives.

That collaborative model supports innovation without removing protections.

AI in Customer Communications

AI is already reshaping customer service across regulated sectors.

Where AI Can Help, Not Hinder

Organisations are using AI to support frontline staff with more relevant information in the moment.

Used carefully, this can reduce friction and improve first-contact resolution.

AI can also support clearer explanations of complex concepts, particularly where customers struggle with terminology or numbers.

Those benefits depend on careful design, oversight, and transparency.

Responsible AI Still Needs Guardrails

Ofgem’s interest is in how AI impacts real customers, including those in more vulnerable situations.

That means making sure automated tools do not create new barriers, confusion, or unfair outcomes.

UK guidance on AI governance highlights the importance of lawfulness, fairness, and accountability.

What Organisations Can Take Away

Strong communications start with centring on customer needs.

Those needs are diverse, and they change over time. Systems and processes need to adapt with them.

Listening, testing, and refining communications is the foundation of trust in regulated environments.

"Customers’ needs are diverse and evolving, and it’s really important that firms listen, respond, and refine their practices accordingly."

Jemma Baker, Deputy Director of Future Retail Policy, Ofgem

 

FAQs

What Makes Energy Communications Hard for Customers?

Billing, tariff changes, and service issues can be complex, especially when customers are under pressure.

What Does Good Regulated Communication Need?

It needs clear language, consistent channels, accessible support, and enough context for people to act.

Why Does Channel Choice Matter?

Customers need routes that fit the urgency and sensitivity of the message, not a one-size-fits-all journey.

 

References

Ofgem Unveils Plans for Overhaul of Energy Customer Service Standards, Ofgem, 2025

Energy Ombudsman Reports 24% Drop in Complaints, Energy Ombudsman, 2025

Digital Transitions: Analysis Using Ofcom’s Technology Tracker, Ofcom, 2025

Consumer Vulnerability Strategy, Ofgem, 2025

Guidance on AI and Data Protection, ICO, 2023

Jemma Baker, LinkedIn, 2026

Ofgem, Ofgem, 2026

Ofgem: Raising the Bar on Energy Communications, Jemma Baker, Ofgem (#34), Apple Podcasts, 2026

Reviewed by

Sam Kendall, 02.06.26

This content is for general information only and is not legal advice.

 

Originally posted on 24 02 26
Last updated on June 5, 2026

Posted by:  Sam Kendall

Sam Kendall works on digital marketing at Beyond Encryption, helping build B2B marketing activity around research, first principles, and sustainable growth. He writes about marketing effectiveness, positioning, customer communications, and digital culture, with longer-form work published at ATNL.

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