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 Digital Customer Communications: Regulated, 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, this conversation explores how regulation can raise the bar without getting in the way of better customer experiences.
"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.
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 therefore 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.
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 as well as 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 example discussed in the episode.
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
Jemma describes organisations using AI to support frontline staff with more relevant information in the moment.
Used well, 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 From This Episode
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
Why Ofgem Focuses on Customer Communications
Because customers cannot make informed decisions or seek support if they do not understand what organisations are telling them.
What Outcomes-Based Regulation Means in Practice
It focuses on the result regulators want to see, rather than prescribing the exact process to achieve it.
How Digital Exclusion Impacts Energy Customers
It means some customers cannot or will not use online channels, which makes alternative routes essential for fairness and access.
Whether AI Is Replacing Human Customer Service
No, the most credible uses focus on supporting staff and improving understanding, not removing accountability or judgment.
Sam Kendall is a marketing strategist with over a decade of experience working on how organisations communicate with people through digital channels. At Beyond Encryption, he leads digital marketing, collaborating closely with product and sales on secure, trustworthy customer communications. His work is grounded in research, buying behaviour, and practical experience, with a focus on clarity, consistency, and long-term effectiveness rather than short-term tactics.