Petitions Committee

Okay. Moving to item 2 then, it's our first evidence session on petition P-06-1326, 'The Senedd should scrutinise the prepayment meter scandal in Wales'. Before we go to questions from Members, can I welcome the witnesses? We have Bethan Sayed, Luke Young and Ben Saltmarsh here with us today. Perhaps I could start with you, Bethan, to introduce yourself for the Record of Proceedings.

Shwmae? My name's Bethan Sayed, and I'm campaigns co-ordinator for the Warm this Winter campaign for Climate Cymru.

Diolch. Luke.

Thank you, Chair. My name's Luke Young. I'm the assistant director of Citizens Advice Cymru.

My name is Ben Saltmarsh, and I work as head of Wales for National Energy Action.

Well, thank you, all, for that, and thank you for taking the time to come to committee today. I think this is a particularly important petition. We will jump into questions from Members. I think I should probably start by noting my interest in this area, and others—I know committee members have been interested in this area. But it is something that has affected many, many people across Wales and the United Kingdom. There's a limit—we'll set it out at the start—to what the committee may be able to do, but, nevertheless, it's important, I think, that we do undertake this piece of work and see where we get with it.

I'll move straight into questions, because we've got about 40 minutes of this session. Buffy Williams.

Thank you, Chair, and thanks for joining us this afternoon. My question is to Bethan. Why did you submit this petition, and what are you hoping to achieve?

Thank you for the question, Buffy, and thank you, also, to the committee for hearing us out and for taking this issue seriously, and for all your hard work on it as individual MSs as well.

We wanted to put this petition in because we know that it's a massive injustice, what's happening with the prepayment meters. It's a scandal, basically, that people are being forced onto prepayment meters during this cost-of-living crisis. And, in Wales, as part of Climate Cymru's work, I run the Warm this Winter campaign, which is part of a UK-wide campaign, looking at the cost of living, but looking at how we can come up with solutions, through energy efficiency, through renewable energy, and through ending fossil fuel here in Wales.

So, it's a massive injustice, but what I want to say is that we do have the solutions. So, only this morning, me and my team were visiting the hydro scheme at Ynni Ogwen, and they make £500 a day that can go back into the local community and take money from people's bills, so that they can afford to pay, and that they can, then, afford to live in a way that's comfortable during the most difficult times.

So, my question is back to the Welsh Government and to the UK Government: what more investment can we put into renewables in Wales, so that communities can do things for themselves? What can we spearhead in our own communities to make them stronger and bolder during these difficult times? That's a challenge I want to pose to you as Members.

And before anybody else comes in, I just want to finish on this. At the end of the day, British Gas has made profits of £3.2 billion. The boss of British Gas has had a bonus of £3.7 million. Don't tell me there's no money for renewables. Don't tell me there's no money to get people out of this cost-of-living crisis. There is, it's just priorities. And unless we force these companies to stop them putting people on forced prepayment meters, they will not change. Therefore, Ofgem and others must come together, with Government, to stop these practices from happening. There's money there, but it needs to go the right places.

Thank you.

Thank you, Buffy. Thank you, Bethan as well. Before I bring other Members in—and we will go into perhaps some more detailed figures shortly—just before I came to committee, I saw a BBC article that said that 94,000 prepayment meters were fitted in the last year alone. That seems quite a remarkable figure. Bethan, you talked about solutions there. One of the things I'm wondering as well is whether you think Government needs to legislate, and I specifically mean UK Government here. We know that, in the late 1990s, the water industry was similar, and people legislated. I've read many stories on this and, my personal opinion is that if you changed water for energy, you could read the same story now in 2023. Do you think we're at the similar time and a similar need for legislation to protect vulnerable households?

Yes, definitely, it needs to emulate water, and I've seen that you've raised this in the Chamber, Jack, and Ministers have replied supporting your call for legislation on a UK level to ensure that they are not treated in the same way. This needs to happen so that people are protected and that, if they are in a vulnerable position, they're not put into a position where they are made homeless, or they cannot afford to pay their bills or they're indebted. So, I would like to see one of the suggestions coming from this inquiry to give it the same legs as water and for it to be treated as a public utility in every sense. Nobody should be denied access to energy, and that's why the UK campaign, Energy4All is something that Warm this Winter is endorsing as well.

Diolch, Bethan. Luke Fletcher.

Diolch, Cadeirydd. Some important points I think have been raised already. In terms of energy, just like water, it's essential for people, so there's a question as to why people are struggling as they are. And I was quite interested to read what Citizens Advice published—around 27,000 people, potentially, have been forced on to prepayment meters in 2022. If I could come to Luke in Citizens Advice, I'd be interested if you would be able to talk us through, perhaps, some of those findings from the 'Kept in the dark (Wales)' research and, as well, if there's any update to that figure for 2023 as it stands at the moment.

Of course, yes. So, the 'Kept in the dark' report was a mixture of some of our service data, but also some survey work that we did on the basis that we were in the middle of winter and all of our statistics and all of the data and evidence that we had were saying that there was a major problem with prepayment meters—being able to afford them and also our clients being forced on to prepayment meters.

So, for more up-to-date figures, actually, the statistics that the Chair mentioned, coming out today from Grant Shapps's department, show that around 97,000 households across the UK were forced on to prepayment meters. Looking at those, broken down by energy company—and we don't have Wales-level data on that yet; I've searched for it before this committee but that hasn't been realised by them as of yet that I've been able to see—it is a really stark difference. At the low end of the table, you've got one energy company with around 30 or so forced installations of prepayment meters last year in 2022. And then, at the top, you've two energy companies that, between them, are responsible for just under 50,000 forced installation of prepayment meters last year. And that is during all of the times and leading into winter when we knew that there was a problem, when everything about it said that there was a problem.

What we do know, in addition to 'Kept in the dark' and by looking at our service data, is who has come in to Citizens Advice for advice and support. Each month, we release a dashboard that shows some of the trends. Our latest dashboard is due out in the next week or so, but, actually, the trend has been the same since December and February time. We have seen a drop-off in the number of people coming to us for forced installation of prepayment meters. I mean, that's good, because you would expect that now that action has been taken and firmer rules are currently in place, but they still remain at a record high, which means that there are still some of those issues working through the system. But continually, the ability to pay for prepayment meters remains at record-high levels. So, separately to this stream of work, our work in debt is predicting that this year is going to be a year of a potential debt crisis, and we see prepayment meters as being symbolic of that.

In terms of the figures that Citizens Advice had quoted, those were based on just Citizens Advice service users, so the figures actually could be a lot bigger.

Well, in 'Kept in the dark' it was a mixture of survey data that we did, which had an estimate over Wales for how many thousands of people we thought would be on prepayment meters by the end of winter. I think, in committee in January, I quoted 4,000 extra people by the end of winter if no action was taken at that point. With our service data, our service data is those who come directly to us, so that's in the hundreds every month. For example, the number of people who were moved to a prepayment meter to pay off arrears in February was just under 100, and that number has been dropping over the months. So, that report in itself was a response to saying, 'We need a greater understanding of what's happening, because the numbers of people coming to us don't match up with all of the other bits of intel that we've got from around the system in saying that this is a big problem'. Often, what happens with Citizens Advice services is that people come to us when they're in crisis. So, we can fully expect that, had there not been action taken at the beginning of February and energy companies not having been shamed into action, our numbers would have continued rising over the next few months. But for up-to-date data from us, that should be out in the next week or so, and I will happily make sure that that's shared with the full committee.

Great, thank you. If I could just come back to the mention you made of UK Government figures around this, is it that the data they provide isn't aggregated to a Welsh level? And, if that is the case, do you think that there's a role for Welsh Government to collect this data itself?

So, the UK Government data is responding to Grant Shapps's edict to energy companies to fess up, pretty much, and that's been released in a press release today by his department. I looked in the Excel tables that have been released so far, and there wasn't a Wales breakdown. But if you have a think about the two worst offenders, as such, there, at the top of that table were British Gas, Centrica and Scottish Power, between them responsible for just under 50,000 forced installations across the UK, you can guarantee a big chunk of those will be in Welsh households as well. So, we're asking for the figures, and certainly, anything that the committee or the Welsh Government could do to get those would be useful.

I think the committee will ask for those figures, actually. It seems to me that it would be easy to get those figures. They've got the figures already in front of them, so a breakdown for Wales shouldn't be much of an issue. Ben, you wanted to come in, and then back to Luke.

Sure. I see no reason why those figures couldn't be made available, and they would be very welcome if the committee and others could push for those.

Just a note furthering what Luke just said as well, energy suppliers report on a monthly or quarterly basis under their social obligations reporting to Ofgem, and there's quite a lot of data within that that would be very useful about the levels of prepayment meters, be that traditional or smart, the levels of debt, if you are in arrears whether you're on a repayment arrangement yet or not, which are often disaggregated by nation, but not necessarily published disaggregated by nation. So, any pressure or support for more of that data to be disaggregated by nation and published would be very welcome as well, because that would give us a much clearer picture of exactly what the picture is in Wales and whether that is equivalent and comparative with what's happening in England, Scotland, and across GB, or whether, actually, there are particularly acute issues in one of those nations that are perhaps being masked by the fact that they are less severe in other nations as well. So, hopefully that's helpful.

I'd support that, Gadeirydd. Back to you.

Thank you for that. I can see Bethan nodding in agreement with that call, as well. Rhys, do you want to come in?

Yes. A couple of questions following that line of questioning by Luke. To the other Luke, now: why is there this huge disparity between the energy providers?

Oh. In all honesty, I'm not—. So, just for some clarity, you mean in the difference between the lowest and the highest who are forced to be on prepayment meters?

Yes. The level's incredible, isn't it? The level of disparity between the energy providers is incredible, but what reasons are given for that huge level of disparity?

I don't think we have clarity on what even their justification is at this point. I think the figures we have today are released by the UK Government after saying, 'We want to know how many people you've put on to prepayment meters', but those numbers, just looking at them as they've been released, are incredibly different. As I said, the lowest is there in the thirties and the highest two each have just under 25,000.

Now, if we take back, as to what we know, we already know that energy companies weren't listening to any of the warning signs that were given off last summer into autumn and into winter. The energy regulator failed customers from the beginning and wasn't listening or taking any action, despite how urgent—and many voices, including ones in this committee, were raised. And so, what we've got is this situation where—. And also, it's worth saying that this was at the same time when PR people for all of these energy companies, including the worst offenders, were having multiple meetings with Ministers of different Governments, saying, 'Oh, well we've done everything that we can, we're doing everything we can to support vulnerable people'. And then, you see the evidence today, which is that two providers are responsible for just under 50,000 forced prepayment meters in that period. So, there's a huge disconnect between the PR, what has been told to Ministers, and what is actually coming out today. So, I think there are some questions there that we would ask, and maybe the committee could as well. Those energy companies have met with Welsh Government Ministers multiple times. Do these stats that have come out today bear out what they were being told in meetings in the autumn and winter?

Yes, well, I think those are certainly questions we could level to those energy providers. When you answered the other Luke—Luke Fletcher—about the numbers you've had in, through Citizens Advice, it just made me worry about—. For people to approach you or to approach Bethan or any other organisation, they need to have some knowledge, don't they, to be able to go to these people, to these organisations. What concerns me are the people falling between the cracks, those people who don't appeal when their benefits are refused, these people who don't know how to challenge decisions. And we all know, from our professional lives, that there are loads of people who fall into these categories. What can be done to try and find these people? Because it's quite a thing for somebody to actually approach Citizens Advice, isn't it? How can we actually find and assist these people, because the energy companies won't signpost these people in the right direction, will they?

So, if I can illustrate that point and then come to your answer, which is—. I'm aware of a case in the Member for Rhondda's constituency, where a constituent had a debt relief order already in place and an energy company refused to move them on to a payment scheme. Within a few months—and this was why they had come to Citizens Advice, by the way, because they were in crisis by that point—they refused to move them on to a payment scheme and then took them to court a few months later, and the debt that they owed was already at over £1,000. They took them to court to put in a prepayment meter, which, at that point, you are basically saying, 'We're putting in a prepayment meter and you will be cut off this winter, because there's no way you can sustain that level of debt and payment'. Now, that's for someone for whom Citizens Advice was a viable option, they might've known the local brand, they might've called our national helpline, they got help and support.

But you are absolutely right, the thing that worries us and one of the reasons that we did some of the survey work in 'Kept in the dark (Wales)' is that we know there is a hidden population of people who are struggling, who don't always come to Citizens Advice, they may go to other services, but there is a wider group, throughout the cost-of-living crisis, who are finding themselves in need of advice for the first time ever. And that's why we, and also, with points from the Welsh Government, or campaigns for things like 'Claim what's yours', we all try to do our bit, and, actually, Ben will be able to speak as well, as chair of the Fuel Poverty Coalition, as to some actions that members of that have taken—we are one of those. But it is a continual struggle for us, obviously, to get that message out to those who are in distress but not able to access all of the systems that need to be there. So, we do all of the things that we possibly can, which is be available online, on the phone, have offices open so that we can set up appointments. But I say that—with every service right now in the cost-of-living crisis, there are pressures in those services, and that, sometimes, means that people have to wait.

I'll bring Bethan in—you wanted to come in on this point—and then, we'll move to questions from Joel James.

Yes, just quickly, like I started with, the hydro scheme, for example, in Ynni Ogwen, pays for the energy support providers; they have energy wardens, and that person, then, can go out into the community and give the advice that's needed. We met with the young gentleman today, Iago, who does that work, and he said that he started by knocking doors, and that just was not the best way to do it—by cold-calling. So, what they do is embed themselves into the communities—like many of you know, as politicians—not saying that it's there to give them energy, but that, if they happen to be holding an event in the local community, or if they are putting on warm meals in the evening, then have somebody or some people there ready to give advice, so it doesn't have to be somehow making them feel that they're asking for help. I think that's the way you have to sometimes do things, so that it's not branded as if they're going and saying that they're desperate, because that doesn't come over very well either. So that, I think, is something that we all need to work on, but I would say that we need more advice services and more support for those advice services here in Wales, because they're doing a sterling job.

We'll move on to questions from Joel James.

Thank you, Chair. And thanks ever so much for coming in today. I just wanted to ask a very generalised question, really, in the sense of the impacts that you're aware of, of those most vulnerable, then. What sort of impact is this having on them? Do you have specific examples you could cite then, really—so, in terms of young people, or maybe those with disabilities, or even the elderly, really, just examples that we could look more into, I suppose? Thank you.

Who would like to go into that? Ben? If we start with Ben.

Well, I think that, at the very outset, it's important to recognise, as the Chair's mentioned already, that energy is an essential service, so it isn't, ultimately, about the consumption of kilowatt hours, it's about keeping warm, and having light, and cooking food, and using everyday appliances—it's about our everyday comfort, and warmth, and well-being, and security. And so, the absence of energy, when you have to self-ration and reduce the amount that you're using of necessity because you simply cannot afford to feed the meter to pay for it, and, ultimately, to the point where you then go without supply, is grave and severe. So, people who are—. Because I'm not sure what we thought would happen, if you're struggling in the cost-of-living crisis with exceptionally high energy prices, and you're falling behind and into debt because you cannot afford to keep up with your bills, if you then move somebody on to a prepayment meter, where they then have to pay slightly higher prices for the same level of energy, and something towards the debt that they owe, what did we think would happen?

And so, then you go without supply, to the great detriment of your health and well-being. We know that people are rationing their usage to the detriment of their health, we know that people are going without cooked food, or skipping meals, in order to feed their children. We've got record numbers of people in arrears with their supplier, we've got record numbers of people seeking emergency assistance and help, and we have record numbers of people in fuel poverty. Back in April of 2022, the Welsh Government estimated that up to 45 per cent of all households in Wales were currently in fuel poverty. That includes 98 per cent of all our lower income households—so, virtually, all our lower income households. Over four in 10 of those lower income households were actually estimated to be in deep, severe fuel poverty, having to pay huge portions of their income, or needing to pay huge portions of their income, just to try and keep warm. And we have as many people likely today in severe fuel poverty as we did in fuel poverty in its entirety back in 2018, when the previous estimates were published. So, the situation is very, very worrying. And that, by the way, was when prices were an average of £2,000 a year; today, they stand at an average of £2,500 a year, as protected by the energy price guarantee.

Now, thankfully, that isn't going to increase come April—that will be maintained at that level, although we will actually see our prices increase somewhat still, because the universal £400 payment through the energy bill support scheme that's, essentially, taking about £66, £67 a month off our bills will come to an end, so there's a cliff edge in support and the situation may get worse, despite the fact that wholesale prices are beginning to fall. And they're here to stay—high prices are here to stay. We know from Cornwall Insight and others that estimates currently—that, throughout the rest of this year, prices are still likely to be at an average of about £2,300, £2,400 a year. And of course, if you live on a very low income, that is, essentially, unaffordable. It's unobtainable. It's far too high. It's more than double what it was this time last year and—. Yes, I think it's very, very worrying indeed.

Thanks ever so much for that, and I suppose the other question, then, I had—it might be best for you, Ben; you might be able to answer—it's something I read about years ago, and I just wanted to see if it's still a practice that is done now in terms of landlords, in terms of the energy meters and everything. I can't remember what it was called, but it was a process where they would have something attached to the energy meter, which meant that, when you paid, the landlord would get a percentage of that money as well. Is that something you're aware of? Is that something that's still common practice?

It's not particularly cases that have come across my desk or the desk of colleagues, as far as I'm aware. I understand there are regulations about if the landlord becomes involved in the resale of gas or electricity; there are strict rules as to what he or she must do in order to follow that. Essentially, they have to charge the tenant what it costs, so the cost of the units that you use, and you can add on, obviously, the 5 per cent VAT, just like the gas and electricity companies do, but you shouldn't be making any additional money on top of that. But we do know that levels of prepayment meters are much higher in the private rented sector compared to the owner occupied sector. So, I think under the Welsh housing condition survey in 2018, with respect to electricity prepayment meters, as an example, something like 5 per cent of all owner occupied homes had a prepayment meter compared to something like 23 per cent of all accommodation in the private rented sector, compared to 46 per cent in social housing. So, it also varies significantly by tenure too.

Perfect. Thank you.

Bethan.

Sorry, I have to go soon, because I have to get a train back from Bangor to south Wales, so I just wanted to finish, really, and I'm sure that others can continue with this session. Just to say we do need to have a reform of the energy market. As far as we are concerned, we also need to look at Ofgem and how they regulate. We're seeing how this UK Government are treating people with regards to their energy usage, and it's unhealthy and it's scandalous. If the committee can relay this to the Welsh Government and to the UK Government too, we would be very grateful, but also to try and perhaps accrue some of those powers to Wales so that we can be the masters of our own destiny. I think that's what we would say as well. We have a wealth of natural resource in Wales—let's use it. And thank you for committing to this inquiry, and I look forward to hearing what more you do. Diolch yn fawr iawn.

Diolch, Bethan. Thank you for that, and we understand that you have to leave. We've got some more questions to Ben and to Luke. Just to say, we will be inviting Ofgem and energy suppliers into committee, and we hope they take it as seriously as we certainly do. On that note, though, thank you for coming, Bethan, and we'll certainly be in touch. I'll move to Rhys ab Owen.

Excellent, Chair. Well, you've just heard a passionate argument there by Bethan Sayed of the need to reform, but how would you reform it? What would you replace the current system with?

So, in respect of prepayment meters.

Yes.

So, I think one thing that's important to be aware of is that there are existing rules that suppliers operate under under their supplier licence conditions that were actually designed to protect some of the instances that we've seen reached through The Times investigation, and the work by Dean Kirby at The i paper, for example. But, clearly, they weren't being followed. So, now there is a temporary suspension in the forced installations of prepayment meters. That was due to end at the end of this month. We understand that that's now been extended indefinitely until all suppliers can prove that they are operating under a new code of practice that Ofgem are working on and developing.

That is very welcome and that is necessary, but we need, ultimately, much stronger rules and sharper enforcement with the greatest protections in place for those that are vulnerable. So, I think there is an immediate need to ensure that that enforcement action is strong and robust, not just for the suppliers, but also to right the wrong that some households have experienced and suffered—so, that might mean reversing wrongful installs, it might mean compensating those households, as an example—and then we need to strengthen those protections and licence conditions that are in place. Those protections heed to be clear and prescriptive, or more prescriptive, I suspect, especially if they were already largely in place but then not being followed, and some suppliers interpreted them in particular ways, which perhaps may account for why some suppliers have only installed a handful of prepayment meters, judging by the evidence that was shared earlier by Luke and the Chair, and others have been to the tune of 25,000 in the last year. And quite simply, some households should never have a forced prepayment meter fitted, be that a traditional prepayment meter or a smart prepayment meter—there’s just too much risk, they're too high risk, whether that’s those who are dependent on medical equipment or a warm home because of a health need, as an example, or whether that’s because you’ve got very young children, or you’re elderly, or you have a physical or mental disability that would prevent you from being able to top it up.

And we also need parity, so those rules need to be the same for those that are on a smart meter that is interoperable between credit and prepay, to protect those being remotely switched from one to the other without their consent. And I don’t think we should be installing legacy or traditional prepayment meters at all now. In fact, we shouldn’t have been anyway, under something called the new and replacement obligation. But, clearly, that has been being done, so we need to ensure enforcement action is strong, and we need to strengthen the licence conditions, and then, beyond that, we need a root-and-branch review of prepayment anyway. We need to reduce the number of traditional prepayment meters that are in use in Wales. We have disproportionately more in use in Wales than in England, and it varies by tenure, as I described earlier.

Thanks very much, Ben. I think we all welcome that they say that they’re not going to do it indefinitely. What concerns me is the people who have been forced onto it. What happens to them? Because we’re saying, 'Well, you can’t do this from now on', but, in the meantime, thousands of people have been forced onto this unjust system and will be carrying on on that system. What happens to them? Because words like 'reviewing' or 'plans to compensate' sound very long term to me. What happens to that household that is struggling right now, or don’t know how to warm the house, or to feed their children today, tonight, tomorrow? What effective support can they receive now?

Well, I didn’t mean to give the impression that the review and the compensation and enforcement action that needs to be sharp and strong should take a long time. I think it is urgent.

I know you weren’t suggesting it should take a long time, I wasn't suggesting that at all, but my concern is that these things can take a long time, and even a few weeks is too long—or days is too long. What immediate action can be given to support these households?

Well, I think if households are currently struggling, as we know that they are, then the key thing is that they don’t suffer in silence, as we were alluding to earlier. Sadly, many do, and it’s very, very difficult, when you’re in arrears with your supplier, and they’re in a position, essentially, of power, if you owe them money, for you to contact your supplier and then try to negotiate your way off it [Correction: 'through it']. So, that highlights, if nothing else, the essential importance of the advice services that are there to support them, whether that’s across Wales through Citizens Advice or Warm Wales or Care and Repair Cymru or whoever it may be, or whether it’s through your local or regional advice organisation, and we play a big role in supporting all of those organisations to train and upskill their staff. But it’s about getting the word out there that help and support is available, and I think in the short term that also highlights the importance of the Welsh Government and other UK Government emergency support that’s been made available through things like the national fuel voucher scheme, the winter fuel support scheme that ran last winter and the winter just gone, and others. Because, as you say, if you simply are on a meter that restricts you from having access to energy unless you can top it up first, and you do not have the money in your pocket to feed the meter, you will go without otherwise.

Yes. Thanks very much.

I want to bring Joel in now. We’ve got about five minutes left of this session. Ben, I'm going to ask you the same question I asked Bethan. In the late 1990s the water industry was legislated to reform. Do you think we’re at a similar time now, where we need to legislate to protect the most vulnerable customers with regard to energy?

I think, in many ways, yes. So, I think that energy is an essential service, as I explained earlier, just like water is, and the greatest protections need to be in place for those who are vulnerable. There are some households, as mentioned previously, that should never be faced with being forcibly fitted with a prepayment meter. Some people—other people—do prefer the choice and like the element of control or help towards budgeting that they may bring. They should only ever be smart, they should be interoperable between credit and prepay, and the rules need to be very, very clear that, if you are to have one, these are the benefits, these are the potential disadvantages, but is it safe and is it reasonably practicable for you to be on one? If the answer to that question is 'no', then you should not have one installed.

It's interesting—. I will bring Joel in now, but it's interesting, the point you raised on prepayment meters in general. I think it was in 1995 that the First Minister wrote a report on token meters, and we're nearly 30 years on still having this conversation, and that's a UK Government fault. Joel James.

Thank you, Chair, but I think Ben just answered my question. I wanted to know, really, if there was a place for prepayment meters, and you touched upon it there.

Thank you, Joel. Luke, I'll turn to you. There are three minutes and 30 seconds left. I'm conscious that we're inviting Ofgem to a future session. We'll be inviting suppliers to that session. What do you think the committee should ask them?

Just to add on to the points that Ben raised earlier around reform, I think suppliers currently work on the basis that you have to prove vulnerability within a household. I think asking them for a commitment that they will assume that there's vulnerability until proven otherwise might help turn the system on its head a bit. It could end up that that needs to be put into law or into regulation, but I think that trying to get a commitment out of them around that space is worth doing.

I also think that some firm challenge would be useful and helpful on why they spent months meeting with Ministers and what was their thinking in doing so, because it's my opinion that it was to run down the clock on winter. We already knew that forced prepayment meters were spiking, in terms of our data; that was out there in the public towards August/September time. Voices such as yourselves were also speaking out throughout autumn. The change only really happened at the end of January/beginning of February, when energy companies and Ofgem were shamed into it by a The Times investigation.

So, I think some scrutiny, really, on, 'Was everything that you were saying at the time all public relations bluster, because vulnerable people were being moved onto prepayment meters? You had power to take action but did you do it?' I think those questions would be really useful.

I think those will certainly be some questions in there. Ben, do you have any comment?

Yes, a couple of things, actually. I agree entirely with Luke about moving the burden of proof onto suppliers, so that you should be assumed to be vulnerable and that it may not be safe and reasonably practicable to have a prepayment meter, or a smart meter in prepay mode, unless proven otherwise.

One thing to note is that the new code of practice that Ofgem are working on will not be legally enforceable; it will need to become a licence condition. So, it may be a practical step to take to get it done now, coming back to your point, Rhys, but the new code of practice that all suppliers need to abide by will be a temporary thing, as I understand it, for it to become part of the licence and to be legally enforceable later in the year, but it's worth noting that.

The third point here is that we've touched on, I think, advice services and the importance of those. In respect of the Welsh Government, I think the other key role that the Welsh Government can have is that there's an urgent need to accelerate the improvement of energy efficiency in fuel-poor homes as well. Of course, if you live in a very old and leaky, inefficient house, you need to use more energy in order to keep warm. The likelihood, especially if you're on a prepayment meter, or you're on a low income and you're vulnerable, is you're just going to spend less time with an adequately warm home.

So, any steps that we can take through the next iteration of the Warm Homes programme—we understand that the new demand-led scheme is due to be procured and operational by the end of this year—to not just provide independent, holistic energy advice around all of these issues, but also to insulate and make people's homes much warmer, greener, healthier places to live, will support all of this very welcome work that this committee is involved in today too.

Thank you, Ben—thanks to Luke as well. That does bring us very nicely to the close of this session. Before we move on, just to say there will be a publication of the transcript; for factual accuracy, please check that and update it if necessary. We may have some further questions as we go through this inquiry, but I'm sure we'll be in touch. And, likewise, if there are things you think you could have said, please feel free to get in touch. We'll move on to item 3 now. So, at that point, I will thank again Bethan, Luke and Ben for your time today and for the important information in the evidence session that we've had with you. Diolch yn fawr.