This page sets out Ofwat’s assessment of water companies’ draft vulnerability strategies and associated submissions.

 

Click below to see:

Executive summary

1. Introduction

2. Our assessment

• 2.1 High standards of service and support
• 2.2 Inclusive by design
• 2.3 Identifying customers
• 2.4 Recording needs
• 2.5 Vulnerability strategies

3. Next steps

Links to water companies’ draft vulnerability strategies

 

 

Last updated: 7 November 2024

 

Executive summary

• Our Service For All vulnerability guidance sets our clear objectives and minimum expectations for companies’ treatment of customers who need extra help.
• We required all companies to develop draft vulnerability strategies, setting out their plans for delivering these expectations.

• Companies submitted their draft strategies in June 2024
• We have conducted a holistic assessment of the strategies

• Many companies have put forward innovative plans in a number of areas, including:

• Stretching targets for growing priority services registers
• Improving support during incidents
• Using data sharing to identify customers who need support
• Using demographic analysis to conduct targeted action

• We also saw some areas where companies need to go further in order to develop clear plans that will provide the right support for customers who need it.
• All companies now have the opportunity to refine their plans before submitting final strategies to us by 30 June 2025
• We hope our assessment will allow companies to improve their plans, in partnership with customer organisations and the third sector.

 

1. Introduction

1.1 The purpose of vulnerability strategies

Everyone needs water every day, and many of us need extra help in the services water companies provide, including tailored support when things go wrong. That is why we expect the full diversity of customers’ needs to be identified, understood and met by companies in the services and extra help they provide.

In December 2023, we published our final ‘Service For All’ vulnerability guidance. This guidance consists of objectives and minimum expectations of the services that water companies deliver to customers who require extra help and the way they are delivered.

One of our Service For All objectives is Vulnerability Strategies.  This means that:

“Companies should have strategies in place to support the extra help needs of their customers. Companies should consider and plan how they can deliver extra help to all customers who need it in the short, medium and long term.”

The objective is supported by two minimum expectations:

• Minimum expectation 5.1: Companies should develop and maintain a vulnerability strategy setting out how they plan to support the extra help needs of their customer base.

• Minimum expectation 5.2: Companies should take steps to understand the likely underlying requirements for extra help in their areas.

We said that companies should publish their vulnerability strategies in draft form by the end of June 2024 and publish their final strategies by the end of June 2025. We sent submission guidelines to the companies to provide clarity around our expectations and direction on what we expected to see in their strategies, as well as format for submissions. CCW also worked closely with companies in the period prior to strategy submissions, providing feedback and challenge on companies’ plans.

We received strategies from all but one company. We were disappointed not to receive a draft vulnerability strategy from Severn Trent Services in time for us to include their strategy in our assessment. This has now been submitted to us. We will assess the strategy separately and provide feedback directly to the company.

We are now publishing our assessment of the companies’ draft vulnerability strategies.

1.2 Developing our assessment

We have conducted a holistic assessment of companies’ draft strategies by assessing:

• each company’s plan for complying with objectives 1 to 4 of our Service For All guidance and the associated minimum expectations (sections 2.1-2.4 of this document); and
• the quality of each company’s strategy in presenting a coherent and outward-facing plan for meeting those expectations, in line with objective 5 of our Service For All guidance and its associated minimum expectations (section 2.5 of this document).

Within this document, we have included information for what good looks like against each of our Service For All objectives. This sets out the information we expect to see in the strategies for us to consider them satisfactory in that area. Our assessment framework goes beyond this, and for a company’s approach to be considered exemplary they must have met all of our assessment criteria for that objective.

We have also worked with CCW to gather their feedback on companies’ strategies.

The purpose of our assessment is to support companies to develop high quality strategies that address the extra help needs of their customers and drive the delivery of support in the short, medium and long term. Where we have highlighted areas for improvement, companies should take action to improve their policies prior to resubmission.

Having a strong strategy is no guarantee of high standards of customer support. We will monitor company performance and customer experience in this area closely, including strategy commitments.

Note – approach to assessing new appointees’ strategies All water companies, including new appointees, should have vulnerability strategies in place. Given the significant differences between new appointees and incumbent companies in terms of size and context (e.g. covering specific housing developments vs large regions), we know that different types of company will need to take different approaches to setting out their strategy. In conducting our assessments, we have taken this context into account. For example: a small new appointee may decide to take a different approach to supporting customers during an incident, which still achieves good outcomes. However, where we have found that new appointees’ strategies do not represent effective plans for supporting customers who need extra help within these contexts, we have assessed them as requiring improvement.

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2. Our assessment

2.1 High standards of service and support

The first objective of our Service For All guidance covers the standards of service and support that companies provide to customers with extra help needs. We said this meant that:

“Companies should provide high standards of service and support to customers requiring extra help. Customers who need extra support receive it and are happy with the service provided. Customers know what extra help they can expect from their company. Companies aspire to improve levels of service and seek to ensure that customers who have extra help needs are no less satisfied with their service than customers as a whole.”

This objective is supported by the following minimum expectations:

1.1 Companies should adapt their services to customers in line with any known extra help needs. This is especially important during times where there is increased risk of harm; for example, during incidents. 1.2 Companies should ensure that the level and nature of support available to customers is presented in a way customers can understand. 1.3 Companies should seek to continuously improve the service they provide to customers who need extra help. This may include finding innovative ways to design or implement services. 1.4 Companies should use a range of data to monitor the effectiveness of their extra help services, and the satisfaction levels of customers who have made such needs known

2.1.1 What good looks like

In their strategies, we want to see that companies have plans to deliver an appropriate level of support and adapt their services for customers who need extra help. We want to see evidence that they have considered the diverse set of circumstances which can lead someone to needing extra help, and that this is sometimes transient. Companies should be able to demonstrate that they provide this support across the full range of operational activity, from day-to-day activities to serious incidents.

We also want to see that companies have plans to proactively tell customers about the services they can expect to receive, for example, through a personalised letter. Should customers not receive the support they need, companies should make it easy for customers to seek redress.

We want companies to recognise that improving services is a journey and that their approach towards vulnerability should evolve. This may include considering new or innovative approaches, where appropriate, and learning from others within the sector and beyond.

Lastly, we want companies to show they track the effectiveness of their services using a range of data and insight. Key amongst these is monitoring the satisfaction levels of customers who need extra help, which should be compared to satisfaction levels amongst a company’s wider customer base.

2.1.2    Our assessment

Most companies set out the support they currently provide for customers and their plans to increase support in the future, and the majority of companies put forward satisfactory approaches to their plans to improve services. However, the quality of companies’ proposals against this objective was mixed and most companies lacked detail in one or more area: for example, how they planned to improve services, and what targets or monitoring they would put in place to support this.

We welcome the fact that many strategies provided clear lists of services available for different kinds of vulnerability. These lists can be used to help potentially eligible customers become better aware of the services they are likely to receive from their water company. However, such lists should be non-exhaustive, and companies’ approaches should be sufficiently flexible to provide support for any customer who needs extra help.

We particularly welcomed the submissions of those companies who provided a breakdown of their approaches to incident response. This information provides greater understanding of the services provided to customers who need extra help during an incident. Some companies did not provide sufficient detail on their services during incidents. Companies should ensure they account for incidents in their strategies with sufficient level of detail, as serious incidents can cause major problems for customers who need extra help.

Under our Service For All minimum expectation 1.2, we set out that we expect companies to make it easy for customers to seek redress if they are not satisfied with the provision of extra help they required. Only Thames Water and United Utilities were able to demonstrate that they make it easy for customers receiving extra help services to seek redress. We expect all other companies to improve in this area, including more information, when they publish their final vulnerability strategies.

We consider only Thames Water’s strategy to be exemplary for objective 1.

Dŵr Cymru, Icosa Water, South Staffs Water and Southern Water demonstrated the least developed approaches in this area. We will be engaging with these companies as a priority to ensure they improve their strategies in this area.

Good practice example: Thames Water’s plans for incident management In its strategy, Thames Water has clearly laid out its current approach to incident management. It also recognises that there is still room for improvement and puts forward several proposals to deliver these improvements in the short, medium and long term. In serious supply incidents, some customers need bottled water to be delivered by their company. Thames Water sets out its tiered response to incidents, based on the customers’ level of need. For example, those who are medically dependent on water are prioritised. In the short term to 2025, Thames Water is upgrading its field resource capacity to respond to serious supply incidents and exploring how contact from customers who need extra help can be prioritised. From 2025 to 2030, Thames Water plans to personalise the welcome letter which is sent to each customer when they register for extra help. This will set customer expectations around water delivery. Thames Water will also insource field teams to create additional resource when responding to serious incidents and provide rapid communications to ensure that customers receive consistent information and support during incidents. Thames Water commits to developing new metrics to monitor the success of these plans. For example, it will measure the satisfaction of customers who need extra help following an incident and the delivery of bottled water during an incident.

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2.2  Inclusive by design

The second objective of our Service For All guidance covers the expectation that companies should design their services with customers who need extra help in mind. We said this meant that:

“Water companies’ systems should be designed to meet the needs of their diverse customer base. Services and communications should be designed in an accessible and inclusive way that does not harm customers who have undeclared extra help needs. Companies should collaborate with service users and subject matter experts in designing their services.”

This is supported by the following minimum expectations:

2.1 Companies should interact with customers in a way that is inclusive for a diverse range of audiences. This should be underpinned by relevant insights, which may include research, engagement and accreditation. 2.2 Companies should offer their customers a range of ways to interact and communicate. This includes allowing customers to opt for third party billing where appropriate. 2.3 Companies should consult with CCW, and engage with stakeholders and other customer representatives, when making significant changes to their proposed service offering around vulnerability.

2.2.1    What good looks like

We expect companies’ strategies to recognise and account for the wide range of extra help needs that their customers may have. Companies should use plain English or Welsh to ensure that customers’ undeclared communication needs are met.

Companies should offer a range of communication and billing options which can be adapted to suit the needs of customers. Companies must ensure that communications for customers with extra help needs are also adapted effectively during incidents to reduce harm.

We want companies to set out their plans for consulting with relevant organisations and stakeholders reviewing their extra help provision. Organisations like CCW are able to provide insight and, where appropriate, challenge to ensure that companies are serving customers effectively.

2.2.2   Our assessment

Companies’ strategies were generally strong in this area. Most companies set out how they consider the extra help needs of customers when designing their services and offer a wide range of communication and billing options. The most notable approaches were set out by the companies that had consulted with organisations representing customers with specific communication needs to ensure that they reach the hardest-to-reach customers. Companies should ensure that they explicitly address communication during incidents in their strategies, as serious events carry a significant risk for customers with extra help needs.

Many companies have carried out research and consulted with stakeholders and customers in developing their strategies and their current service offering, and indeed many commit to carrying out further research and consultation.  As companies continue to develop their approaches towards vulnerability, it is important that these approaches are underpinned by relevant insights. We would therefore expect all companies to demonstrate how they will do this in their strategies.

We consider the approaches of ten companies to be exemplary in this area. These were: Affinity Water, Anglian Water, Dŵr Cymru, ESP Water, Northumbrian Water, South East Water, South West Water, Thames Water, United Utilities and Wessex Water.

Icosa Water, Portsmouth Water, South Staffs Water and Southern Water demonstrated the least developed approaches in this area. We will be engaging with these companies as a priority to ensure they improve their strategies in this area.

Good practice example: Anglian Water’s approach to gaining insight Anglian Water’s strategy clearly demonstrated that its approach to vulnerability is underpinned by insights from customers and stakeholders. Anglian Water has a community of customer champions, comprising over 100 customers and 150 partners, who provide feedback on its service offering. It also undertakes research with customers, engages with relevant organisations such as CCW, and pursues external accreditations which benchmark its services against economy-wide standards. It seeks to understand customer experiences and priorities. It uses customer personas to ensure that it considers a wide range of extra help needs when designing its services. It monitors customer journeys to understand how customers with extra help needs access their services and identify areas for improvement. Its current support offering is tailored for those who need extra help. For example, it offers a wide array of accessible communication options, including British sign language interpretation. Furthermore, its planned actions for operational and service delivery clearly follow from customer priorities. The strategy commits to continuous engagement to further understand the needs and preferences of customers and think creatively about how it can improve and tailor services even more. Anglian Water will actively seek feedback from its customer champions and stakeholders as its service offering evolves.

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2.3 Identifying customers

The third objective in our Service For All guidance covers how companies should proactively identify customers who need extra help. We said this meant that:

“Companies should have systems in place to effectively identify customers who may have extra help or support needs; and those customers who are willing or able to self-declare these needs should be able to do so easily”

This is supported by the following minimum expectations:

3.1 Companies should take active steps to identify customers who require extra help who have not yet been identified. 3.2 Companies should take steps to proactively increase customer awareness of the extra help available to those who need it. 3.3 Companies should train their staff to spot potential requirements for extra help, even when a customer has not previously declared it. 3.4 Companies should actively consider how they can reduce communication burdens on customers who need extra help; this could include establishing data sharing arrangements with partner organisations.

2.3.1   What good looks like

We want to see companies develop plans to proactively identify extra help needs, so that no customers are left behind. We expect to see clear plans for growing their records of extra help needs, like priority services registers (PSRs), backed up by firm targets.

We also wanted to see robust plans for raising awareness of the support available, such as by promoting support directly to customers at relevant points of the customer journey or indirectly on their websites and through campaigns.

We want to see plans put in place for appropriate training so that staff can engage sensitively with customers and spot potential extra help needs.

Finally, we want companies to consider how they can reduce the number of times that a customer has to declare extra help needs to various organisations, including their water company. This may include data sharing arrangements.

2.3.2   Our assessment

Since 2019, we have seen strong growth in the numbers of customers registered for extra help services. More customers have been identified than ever before. However, there is still a gap between those in receipt of extra help services and those who require them: currently only 10.2% of households are on their company’s priority services register.

Companies have set out a wide range of methods to identify customers who require extra help, such as through direct interactions with company staff, data sharing arrangements and partnerships with charities and advice organisations. The majority are pursuing more than one method to identify more of their customers who need extra help.

On raising awareness, we also saw companies taking multi-pronged approaches. This included promotional messaging on company websites, letters and bills or social media, promotional events or working with partner organisations. The most notable approaches were those that aim to increase awareness amongst those who currently need extra help, as well as their general customer base.

We would like to see companies setting measurable targets to support progress towards increasing the number of people they support and the awareness of their extra help services. Fourteen companies included a target for the number of people to be registered for extra help services. Only seven companies have set, or have committed to setting, a target for awareness of extra help support.  Under our assessment only companies who included or committed to setting targets for both have been considered exemplary.

We are pleased that the sector has continued to make progress on data sharing as a key method to identify and reduce the communication burden for customers with extra help needs. Most companies that have implemented data sharing arrangements with their regional energy Distribution Network Operator. We will continue to support industry-led work to build on this progress.

For objective 3, we consider the approaches of six companies to be exemplary. These were: Anglian Water, Northumbrian Water, SES Water, South East Water, Thames Water and Wessex Water.

Albion Water, ESP Water, Icosa Water and South Staffs Water demonstrated the least developed approaches in this area. Of these, Albion Water and South Staffs Water failed to meet any of the criteria we had outlined. We will be engaging with all four of these companies to ensure they improve their approaches in this area.

Good practice example: Northumbrian Water’s approach to identifying customers Northumbrian Water use a variety of proactive steps to identify customers who could benefit from, but are not yet signed up for, extra help. Northumbrian Water is leading the Support for All project in partnership with other companies. It is funded by Ofwat’s innovation fund. It aims to design and deliver a national, secure, cross-sector platform which stores data on customers’ extra help needs and shares it between relevant utilities and support organisations. Customers will only need to share their details once and they will be registered for extra help with each utility company, improving customer experience and allowing for more customers to be identified. The strategy outlines a data-driven approach. Northumbrian Water uses a digital twin which uses information on registrations for extra help and demographics to better understand their customer base. This allows it to identify and target certain areas and groups. It also has data sharing agreements in place and is committed to increase the number and variety of partnerships. Northumbrian Water uses a variety of methods to proactively promote its extra help services to both its general customer base and targeted groups of customers. For example: ·       It uses social and traditional media and outdoor advertising and carries out targeted campaigns following incidents ·       Customer-facing staff, including field operatives, are trained to identify and provide support and advice for customers ·       It attends community events, planned works and incidents in person to promote its services to customers who may be hard to reach ·       It supports its partner organisations, including charities and advice providers, to promote its services and directly refer customers It plans to further develop its strategy to identify more customers. For example, it will expand its partner network and further personalise targeted messaging. This is supported by measurable targets for both number of customers registered for extra help and general awareness of these services.

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2.4 Recording needs

Our fourth Service For All objective sets out our expectations around how companies should record the extra help needs of their customers. We set out that:

“Customers’ extra needs should be effectively recorded and reviewed, with customers informed about how their data is used and their views around privacy understood and taken into account.”

This is supported by the following minimum expectations:

4.1 Companies should take appropriate steps to record customers’ extra help needs. These records should be held securely and in line with wider data protection requirements. 4.2 Companies’ records should be reviewed regularly to ensure they are up to date. 4.3 Companies should consider how their records of customers’ needs can be designed in a way that can help deliver wider benefits to their customers; for example, reducing communication burdens for customers through data sharing. 4.4 In designing their approach to recording and, where relevant, sharing customer vulnerability data, companies should clearly explain to customers how their data will be used, including any choices available to them. Companies should take steps to understand how their customers who need extra help feel about the use of their data.

2.4.1    What good looks like

We want to see companies set out plans to take appropriate steps to record the extra help needs of customers once they have been informed about them, including consideration of data security and protection considerations.

We also want companies to commit to regularly reviewing their records to ensure that their information is up to date. This can account for the often changing or transient nature of vulnerability. We also wanted to see companies develop plans for recording data that would support wider benefits, including data sharing.

Finally, we want companies to commit to transparency in how they communicate with customers about their data. Companies should clearly explain to customers what data is recorded, how it is stored, with whom it is shared, and what choices are available.

2.4.2   Our assessment

Most companies set out satisfactory approaches in this area. Nearly all companies included information in their strategy on how they record the extra help needs of their customers, and all companies showed they store data in line with data protection regulations. We are pleased to see that companies take the security of customer data seriously. Where this information is not in a company’s draft strategy, we encourage them to include it in the final version.

At Ofwat’s 2019 Price Review (PR19), we set a common performance commitment for companies (excluding new appointees) to regularly contact their customers to ensure that their records of extra help needs are up to date (PSR data-checking). We see this as crucial and most of these companies have continued their commitments in this area.

Nearly all companies included information in their strategies on how they clearly explain to their customers how they use their personal data, which is key as data sharing arrangements are becoming more common in the sector. Where this information is missing from a company’s draft strategy, we would expect them to include details in their final version. Some companies could more actively use insights from their customers to inform their data strategy.

We consider that thirteen companies had exemplary approaches in this area. These were: Affinity Water, Anglian Water, Hafren Dyfrdwy, Leep Water Networks, Northumbrian Water, SES Water, Severn Trent, South Staffs Water, South West Water, Thames Water, United Utilities, Wessex Water and Yorkshire Water.

Albion Water and Icosa Water demonstrated the least developed approaches in this area. We will be engaging with these companies to ensure they improve their strategies in this area.

Good practice example: Affinity Water’s explanation of how it uses and shares data in its vulnerability strategy Complementing its existing policies around data protection, Affinity Water’s strategy included an explanation about how it stores data under the legal basis of substantial public interest and what this means for customers with extra help needs. It provides specific information about how personal data relating to extra help is used internally and in which circumstances it may be shared with other organisations. It also includes information on how a customer may request removal from its records, and links to Affinity Water’s privacy policy for further information. Including this information in its strategy is likely to provide welcome clarity for Affinity Water’s stakeholders.

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2.5 Vulnerability strategies

In our Service For All guidance, our fifth objective is around vulnerability strategies themselves. We said this meant that:

“Companies should have strategies in place to support the extra help needs of their customers. Companies should consider and plan how they can deliver extra help to all customers who need it in the short, medium and long term.”

This objective is supported by the following minimum expectations:

5.1 Companies should develop and maintain a vulnerability strategy setting out how they plan to support the extra help needs of their customer base. 5.2 Companies should take steps to understand the likely underlying requirements for extra help in their areas.

2.5.1   What good looks like

We want companies to have strategies which constitute effective, well-rounded plans to support relevant activities, beyond the specific commitments made.

We want to see strategies that identify the gap between customer bases’ underlying needs and current extra help provided. Companies should take ownership of any areas where the company is currently falling short, recognise challenges to implementing its plans, and identify areas for improvement. This also means using relevant data on company performance and demographic information to identify current gaps, and plan for future changes and challenges.

We want strategies to respectfully consider the diversity of circumstances which can make someone vulnerable, and their resulting extra help needs. We also want strategies to detail the current support provided to meet the extra help needs of its customer base.

Beyond this, strategies should set out sufficient plans to increase support in the short, medium and long term. This would be likely to include clear and measurable commitments and/or targets. Good strategies demonstrate how progress and success in implementing change will be monitored, including through data and organisational oversight. Strategies should also show how customers and stakeholders had been involved in their development.

Finally, the strategies should meet our basic minimum requirements, such as being published online, being accessible to customers, and including a table which sets out the company’s commitments against each of the minimum expectations in Service For All.

2.5.2   Our assessment

Companies took a wide range of approaches to presenting their vulnerability strategies, with significant variation in format, length and style. These variations did not prevent companies from meeting our expectations.

Some companies’ strategies were focused on their current level of support and their approach to delivering it well. Other companies focused on analysing current gaps in their approach, and their plans for addressing them over time.

Our assessment found the following areas of strong and weak practice:

Area	Strong practice	Weak practice
Demographic analysis and insight	Using relevant regional demographic information, and comparison to national figures, to develop clear, actionable insights to inform the companies’ approach.	Lack of meaningful comparison between data. Failure to draw meaningful insights from analysis.
Articulation of support offer	A clear summary of what extra help they offer to their customers in different situations, and for different types of vulnerability.	Unclear what support the company currently provides, to whom, and in what circumstances.
Future plans	A practical plan to increase support for customers, with measurable, stretching targets.	Plans for developing approach insufficient or vague, and unclear how success will be measured.
Governance and accountability	A coherent approach to keeping track of progress in delivering the strategy, including at senior levels within the company.	No clear plan for staying accountable for delivering the strategy.
Co-creation	Showing that the strategy had been developing using feedback and insights from expert stakeholders and customers.	Unclear how the strategy was developed and how it takes into account the views of experts and / or customers.

Overall, we felt that Affinity Water, Anglian Water, South East Water, South West Water, Thames Water, and Wessex Water’s strategies were exemplary in demonstrating their approach to this objective.

Good practice example: South West Water’s approach to demographic analysis South West Water’s strategy presented a detailed account of the specific demographic challenges its area faces. These are benchmarked against national averages and include customer segmentation indicators such as age, disability, digital exclusion, rurality and financial vulnerability. It clearly drew out the challenges faced by these customers and their expectations. It also recognised the differences between the companies’ sub-regions. Building on this, the strategy identified clear and appropriate commitments against these indicators. They work towards specifically addressing the challenges faced by these customers. The strategy goes on to use demographic insight to inform the partner organisations the company works with, the staff training it implements, and the areas it targets for specific engagement.

 

Good practice example: South East Water’s approach to setting out plans for improvement South East Water’s strategy laid out clear plans for stepping up support over time. Crucially, the plan breaks down future commitments into short-, medium- and long-term improvements that create a sequential plan for the next decade or more. Each future improvement is mapped clearly to a particular benefit for customers, making it clear how the commitment helps deliver the outcomes that customers want to see. The plan is supported by a set of clear targets that the company proposes to hold itself to account against over time.

 

Good practice example: Wessex Water’s approach to co-creating their vulnerability strategy Wessex Water included detail on how it had developed its strategy collaboratively. It provided a clear timeline which detailed their past engagement and committed to further engagement with customers and stakeholders as its strategy continues to evolve and is reviewed and updated annually. The strategy has been directly informed by insights gained from customers. Wessex Water has taken on customer feedback and carried out customer research with customers to understand their experiences and expectations. It has conducted research specifically to test the vulnerability strategy with a range of customers and it was generally well-received. Wessex Water has a Stakeholder Vulnerability Advisory Panel which was set up in 2013. It consists of experts from a range of stakeholders, including the Consumer Council for Water and relevant third sector organisations. It supports, advises and challenges the vulnerability strategy, oversees its delivery and monitors its effectiveness. More broadly, Wessex Water works with over 300 partner organisations and aim to increase the number and variety of partnerships. These partners are split into three tiers. Those in tier 1 are consulted on and have the opportunity to advise and influence the strategy.

We did not consider the strategies of any of the new appointees to be exemplary. However, we recognise that their size, age and context differ greatly to other companies. Among the new appointees, Independent Water Networks provided clear plans to improve its services which were supported by clear and measurable targets. We will continue to support new appointees as they refine their approaches.

We felt that the strategies of County Water, Dŵr Cymru, Hafren Dyfrdwy, Icosa Water, Portsmouth Water, and Southern Water required substantial further development, if they were to represent a clear and coherent plan for developing their support offer. We will be engaging with these companies as a priority to ensure they improve their strategies in this area.

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3. Next steps

3.1 Developing strategies further

All companies now have the opportunity to review, refine, and improve their vulnerability strategies, before they submit their final strategies to us by 30 June 2025.

Ways this improvement can be supported include:

• Engagement with Ofwat – we will provide more detailed feedback on our assessment to individual companies, prioritising those companies where we feel the most development is needed.
• Engagement with CCW – CCW will provide support and feedback to companies as they develop and refine their strategies.
• Working with stakeholders – we encourage stakeholders to engage with water companies to develop their strategies, especially those companies whose strategies we have said require further development.
• Working with each other – we encourage companies to learn from one other and share best practice.

Companies will also need to make any necessary updates to their strategies to reflect our PSR standards. These are currently open for public consultation and will be finalised in winter 2024-25.

3.2 Holding companies to account

A key benefit of companies developing publicly available strategies is that it allows stakeholders, including Ofwat, CCW, customers and customer groups, to hold them to account against their commitments and their performance. Even the strongest strategies are only as good as their implementation, and we want to see all companies make good on their commitments.

Once companies’ strategies are finalised, we will continue to monitor their performance against them, including through customer research, and stakeholder engagement.  Where companies are not meeting their commitments, we will take appropriate action. This could range from securing plans to address shortcomings and deliver the minimum expectations to enforcement of the new customer-focused licence condition (Licence Condition G) if we consider there has been a breach.

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Links to water companies’ draft vulnerability strategies

Click the links below to view each company’s draft vulnerability strategy.

Water and wastewater companies	Water only companies	New appointees
Anglian Water	Affinity Water	Albion Eco
Dŵr Cymru	Portsmouth Water	Albion Water – We will be asking companies to ensure their vulnerability strategies are available on their websites.
Hafren Dyfrdwy	South East Water	County Water – We will be asking companies to ensure their vulnerability strategies are available on their websites.
Northumbrian Water	South Staffs & Cambridge Water	ESP Water
Severn Trent	SES Water	Icosa Water
South West Water		Independent Water Networks
Southern Water		Leep Water
Thames Water		Severn Trent Services (trading as Severn Trent Connect)
United Utilities		Veolia Water Projects
Wessex Water
Yorkshire Water

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