The new consumer trilemma?

By their very nature, essential services such as energy, credit, and insurance, are needed by everyone. However, these markets have been designed in a way that results in many people being treated less fairly. As Fair By Design’s research shows, poorer people pay more for products and services than those who are better off – known as the poverty premium.

The University of Bristol found that the poverty premium affects almost every low-income household, costing an extra £490 a year, on average. Low-income households experience the poverty premium in the energy market in a number of ways. They may use pre-payment meters for domestic fuel rather than paying by direct debit, or may prefer to pay on receipt of a bill to help manage a budget. Many low-income households are also not switched to the best fuel tariffs, which is also a poverty premium. These households are less likely to switch sometimes because they have other more pressing issues to deal with, which manifests in less capacity to engage in the market, which is known as the ‘scarcity mindset.’[1] It is not the same as consciously avoiding actions that might upset tight financial control, such as switching providers. They also may not be able to switch because of higher rates of digital exclusion, owing to a lack of ability or equipment to go online.

Research commissioned by Fair By Design found that people with certain protected characteristics are more likely to be paying a poverty premium, even when compared with low-income households as a whole. People from Black, Asian, and other ethnic minority households are more likely to be paying extra costs for energy, and paying on receipt of a bill, rather than by direct debit, which is usually cheaper. Single parents are more likely to pay for energy through more expensive prepayment meters. These groups are more likely to be in low-paid or insecure work and therefore need flexible payment methods to help keep control of their finances. Disabled people are more likely to be paying by either of these methods, than non-disabled people.

The poverty premium is particularly pertinent at the moment since poorer households suffer disproportionately in hard times. There are now millions more people facing economic hardship as a result of the pandemic. The ongoing gas price crisis means that the cost of heating the average home could also double.

Why does the poverty premium exist?

Essential products and services are too often designed for ‘super consumers.’ These are people who never become ill, always have a steady income, are able to understand complex terms and conditions and always have the time and technology to easily find the best deal. This is not a reality for everyone. There is a disconnect between social and regulatory policymakers and people’s lived experiences of poverty and exclusion, and a belief that a market based on competition benefits all consumers. In practice, firms compete for the most profitable and engaged consumers. It means that for many people products and services do not meet their needs or even that they are excluded altogether.

Inclusive Design: Understanding how different groups and consumers experience products

Across essential services regulators, inclusive design is increasingly recognised as a way to ensure markets are fair and inclusive, especially for consumers in vulnerable circumstances and on low incomes.

Inclusive design is a toolbox that helps design products and services that are accessible to as many people as possible. It is different to ‘traditional’ market research in that it is not simply about testing pre-existing solutions and hypotheses. It starts by talking to people with additional needs to understand the problems from their perspective, and designing from there. Rather than shaping the consumer around the product or service, firms start with people where they are, and co-design with them. This is especially important as the energy system becomes increasingly digitised, and we transition to net zero.

Instead of designing for a mythical ‘average’ user, firms should therefore understand people’s actual experiences and how these might put them at a disadvantage. In other words, what are they vulnerable to, and why?

There are huge benefits to firms from adopting an inclusive design approach. By involving customers in the process of product design and development, it increases the likelihood of adoption, and reduces the need for solving problems after they occur, through customer service, for example.

The role of government and regulators

At the same time we know that firms will only design inclusively, to a point. There are always going to be some consumers that are deemed less desirable and for whom competition alone will not help. Markets need to be regulated to serve everybody. This means that Government (BEIS) and regulators (Ofgem) should not only be encouraging firms to design inclusively, they should be applying inclusive design principles to their own work. They should shape their own policies around the consumer, especially those most vulnerable and least heard – rather than trying to make such consumers fit their desired regulatory intervention. It is not enough to rely on competition and the belief that empowered consumers drive the market.

For instance, consumers have a role in designing the appropriate policy steps towards decarbonisation. This is very important, since we need to ensure that the cost of the transition to renewable energy sources is not placed disproportionately and unfairly on low income groups. Although many UK households are reportedly willing to accept some increase in their bills to help finance the future energy transition, this will not be possible for all households – particularly those with little slack in their existing household budgets, or who do not own their own home.

Ofgem and BEIS should adopt an inclusive design approach to understanding the needs of all consumers (particularly those on low incomes) and use this approach to help set their priorities, develop and implement interventions, and assess their effectiveness. This means doing things differently, and engaging with low income people directly – placing them at the heart of decisions.

To help with this, Fair By Design, along with our partners Money Advice Trust, has published a practical guide on what inclusive design means and how it can be incorporated into the work of regulators.

The future of price protections

An inclusive design approach to policymaking will help identify where the limits are for the market serving certain groups of consumers, and for whom additional protections – such as price caps and targeted “social” tariffs – are needed.

In a Fair By Design study of low income households accessing Turn2us’ services, researchers compared the costs of the energy poverty premium in 2016 and 2019 to assess the degree to which the retail energy market has changed. [2] While their findings showed the positive impact of regulation, low-income consumers still face excess costs for their energy.

For example, the gap between the Standard Variable Tariff and the best online-only fixed tariff had reduced from £317 in 2016, to £213 in 2019, a reduction of over £100. [3] The gap between the best pre-payment meter tariff and the best online-only fixed tariff had almost halved, dropping from £227 in 2016 to £131 in 2019.[4] This shows a strong correlation between price protections and a reduction in the poverty premium.

This is very welcome news and shows that sensible regulation and a focus on price to protect consumers is achieving good outcomes. The focus now should be on how to narrow the gap even further, to entirely remove the poverty premium, through a combination of inclusively-designed innovations and policy changes.

About Fair By Design

Fair By Design is dedicated to reshaping essential services, such as energy, credit and insurance, so they don’t cost more if you’re poor. People on low incomes and in poverty pay more for a range of products including energy, through standard variable tariffs; loans and credit cards, because of higher interest rates; and expensive insurance premiums, by living in postcodes considered higher risk. This is known as the poverty premium.

We collaborate with industry, government, and regulators to design out the poverty premium. Our Venture Fund provides capital to help grow new and scalable ventures that are innovating to make markets fairer. The Barrow Cadbury Trust runs our advocacy work, and Ascension manages the Venture Fund.

To download the Fair By Design and the money Advice Trust guides on inclusive design visit: https://fairbydesign.com/inclusive-design/  There is one for regulators (and social policy makers) as well as one for firms.

Martin Coppack is Director at Fair By Design and Carl Packman is Head of Corporate Engagement.

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