Industry Watch·6 min read

Nobody is going to signpost you

Dan Warrener·

On 10th September the Public Accounts Committee published its report on the regulation of water, energy and broadband. The coverage led on the soft finding: the regulators are not doing enough for vulnerable customers. True, and unarguable, and not much use to anybody with a live complaint.

The finding underneath it is narrower, harder, and worth more. Sitting under the PAC report is National Audit Office work which recommends increasing the percentage of consumers who are effectively signposted to the relevant ombudsman when a complaint goes unresolved. The ask is to increase the percentage who get told where to go next.

That is a procedural failure at a single handover point, and it is the most consequential thing in the report.

Rights without a route

Every consumer protection in these three sectors is enforced through a scheme. The Consumer Rights Act 2015 is enforceable because you can eventually put it in front of someone with the power to decide. Ofcom's automatic compensation rules matter because an ADR scheme will hold the provider to them. The right and the route are not two things. A right you cannot route is decorative.

So when the NAO says consumers are not being effectively signposted, it is saying that at the exact moment the protection becomes live, the person who needs it does not know it exists. The company is under no commercial pressure to tell them. In most cases it is the company's own final response letter that is supposed to do the telling.

The PAC then asks Government two questions that give the game away. When will there be a statutory water ombudsman with legally binding powers. And which organisation is responsible for providing free advice to telecoms consumers. Both are polite ways of saying that in two of these three sectors the thing you are meant to be signposted to is either not statutory or not clearly anybody's job.

The volume arriving at the water scheme is not small. On 16th September the Consumer Council for Water reported that complaints escalated to it rose 84 per cent to 15,115, with complaints made directly to water companies up 56 per cent to 321,347 and billing complaints up 72 per cent. Cases where a customer could not get a meter installed rose 464 per cent. That is what is currently landing on a body Parliament is still asking Government to put on a statutory footing.

What the regulators did next

Ofcom launched a Consumer Hub on 11th September, the day after the report, at ofcom.org.uk/onyourside. Money-saving tips, switching guidance, an explanation of protections customers are unaware of, and how to complain when things go wrong. Ofcom's own research alongside it says out-of-contract bundled customers could save over £100 a year by switching.

On 15th September Ofcom closed the compliance case it had opened against BT over how it migrated vulnerable and telecare customers to IP voice. BT agreed to additional system alerts, agent verification of telecare customers before an order progresses, strengthened welfare restoration and updated vulnerability policy. Most measures are in place; the rest are due by the end of November, ahead of the PSTN switch-off completing on 31st January 2027.

Both of those are real work, but neither of them changes the mechanism. A hub is a place you have to already know to visit. The BT settlement fixes one migration process at one provider. The gap the NAO identified is that the route is disclosed at the discretion of the party who benefits from you not taking it, and nothing published this week alters that.

The substitute does not work either

Here is the part nobody joined up. When consumers cannot find the route, the market sells them one. That is what claims management companies and professional representatives are. And the ombudsman has now published what they are worth.

Between April and December 2024, professional representatives brought 47 per cent of the cases that reached the Financial Ombudsman Service. They won 26 per cent of them. Consumers who came direct, unrepresented, free, won 38 per cent.

The FOS response was to charge. Professional representatives pay £250 to refer a case, with £175 returned where the outcome favours the consumer. Consumers referring their own complaint pay nothing, and neither do family, friends, charities or voluntary organisations.

Read that as a funding measure and it is a levy on bulk claims. Read it as evidence and it is the ombudsman putting on record that the intermediary you pay to know the route performs twelve points worse than you do on your own.

The honest caveat: cases brought by representatives are not a random sample, and motor finance commission claims distort the period badly. But the distortion runs in a direction that makes the point stronger rather than weaker. FOS upheld 26 per cent of everything it resolved in Q1 2026/27 and 30 per cent once you strip motor finance commission out. The ordinary escalated complaint does better than the headline. The represented one does worse.

What to do about it

Treat signposting as something that will not happen and build around its absence.

Establish the route on day one, not at the point of failure. When you open a complaint, write down two things next to the reference number: which scheme hears it, and the date you become eligible. For an FCA-regulated firm that is eight weeks under DISP 1.6, or earlier on a final response. For telecoms it changed on 8th April 2026 and is now six weeks rather than eight, or immediately on a deadlock letter, to either the Communications Ombudsman or CISAS. For water, note that the scheme you will be sent to is an industry arrangement rather than a statutory ombudsman, which is precisely what the PAC is asking Government to fix.

Then go direct, on the numbers rather than on principle.

One date worth putting in the diary while you are there. The Financial Ombudsman's Modernising the Redress System rule changes take effect on 1st October 2026. If your case will still be live then, the route you wrote down in week one is worth re-reading in week twelve.

The regulators have now said in public that the handover is where consumers get lost. That is useful information. Use it as a warning rather than as a promise.


Also worth your time this week

Nine things worth knowing from the week of 12th to 19th September 2026.

  • Collective actions consultation closes on Thursday. The Department for Business and Trade's consultation on making opt-out collective actions swifter and simpler closes at 11:45pm on 25th September. It covers how class actions are funded, how damages reach class members, and Competition Appeal Tribunal resourcing. This is the main reform route for UK consumer class actions, and the window to say anything about it is now under a week.
  • Motor finance: Scheme 1 firms must confirm by 30th September. Under the FCA's redress scheme in PS26/3, firms have until 30th September to tell consumers with 2007 to 2014 agreements whether they are owed money and how much. If you have an agreement in that window and hear nothing, that silence is the thing to chase.
  • Water complaints are up sharply. The Consumer Council for Water reported complaints escalated to it rose 84 per cent to 15,115, with direct company complaints up 56 per cent to 321,347 and billing complaints up 72 per cent. Thames Water and South West Water were named as the poorest performers.
  • Five OPSS recalls in three days. Diall 16A site connectors and sockets sold through Kingfisher retailers, a Cambridge Audio ceiling speaker fire hood, a Smyths Toys cornhole set, a Baylis and Harding hand wash refill and a La Redoute bathrobe. A recalled product is not of satisfactory quality, which means a remedy from the retailer you bought it from under the Consumer Rights Act 2015.
  • BT email users got flooded with password reset codes. Some reported up to 1,000 PIN messages in short bursts. BT says the cause was automated abuse of its reset form rather than a compromise of its systems, and that mitigations are in place. Ignore the codes, watch the account.
  • One in six people now ask an AI chatbot for legal help. JUSTICE research published on 15th September found the most common subjects are housing, employment, debt and consumer problems, which is almost exactly the territory legal aid does not cover. Only 6 per cent relied on AI alone.
  • Broadband exit fees, ranked. Research covering 2,472 households put the median early exit charge at £279, from Virgin Media at £340 down to TalkTalk at £135. Bundles cost more to leave than broadband alone. Worth knowing before you accept that a mid-contract price rise leaves you stuck.
  • HMRC is posting a million pension letters. Around £70 each to low earners whose workplace pension used a net pay scheme. Genuine contact is a letter plus a Personal Tax Account message. HMRC will not phone, text or email about it, so anything that does is a scam.
  • Crypto still has no ombudsman route. The FCA published perimeter guidance on the new cryptoasset regime. Authorisation opens on 30th September 2026; the regime itself goes live on 25th October 2027. Until then, most crypto activity sits outside FCA conduct rules and outside the Financial Ombudsman Service.

Stand stronger. Start a free case.

D

Dan Warrener

Consumer rights advocate

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