Telecom providers must have policies for treating vulnerable customers fairly and appropriately; support should respond to the person’s actual needs.
Ofcom’s General Conditions require providers to establish and follow policies for vulnerable customers. Vulnerability can be permanent, temporary or situational and may relate to disability, age, financial difficulty, bereavement, abuse, serious illness or other circumstances.
Support is not limited to putting a label on the account. The provider should consider accessible communication, practical adjustments and risks created by service changes or debt collection.
Key points
- Tell the provider what support you need rather than only disclosing a condition.
- Ask it to record communication preferences and reasonable support.
- Vulnerability can matter to collections, disconnection, digital landline migration and complaint handling.
- Keep evidence if agreed adjustments are repeatedly ignored.
Examples of practical support
- Alternative contact channel
- Authorised representative
- Priority or accessible communications
- Additional time or explanation
- Special handling in bereavement or financial difficulty
- Safeguards around essential/telecare services
Vulnerability can change
A customer may become vulnerable because of a temporary event. Providers should have processes that can identify and respond rather than requiring the customer to fit a permanent category.
Failure to follow an agreed adjustment can be part of the complaint
If you have asked for written communication and the provider repeatedly calls, or it ignores an authorised representative, record each incident. Explain the practical disadvantage caused.
In practice
- State the adjustment in functional terms: “Please communicate by email because…”
- Ask for confirmation that the preference has been recorded.
- If the support relates to safety or essential services, make urgency explicit.
What to do
A practical next-step plan
- Tell the provider about the relevant need.
- Request a specific adjustment/support measure.
- Get confirmation.
- Record failures or resulting harm.
- Use the formal complaint process.
- Escalate to ADR and report systemic concerns to Ofcom where appropriate.
Common traps
Things that often confuse the issue
- Do not assume disclosure alone tells the provider what adjustment you need.
- Vulnerability status should not be used as a substitute for fixing the underlying problem.
- Urgent safety issues may need faster routes than ordinary complaints.
Evidence worth keeping
Do not let “vulnerability” replace the underlying complaint.
Support needs and the substantive dispute are separate. A provider might accommodate communication correctly but still get the bill wrong; or resolve the bill while mishandling an accessibility need. Ask for both to be answered.
Useful wording.
“I am asking for [specific support/adjustment] because [functional barrier]. Please confirm whether you can provide it and record the arrangement. This is separate from, and should not delay, my underlying complaint about [issue].”
Record what you disclosed and what the provider agreed to do.
Ask the provider to confirm any vulnerability marker, communication preference or adjustment on the account, subject to your wishes and data-protection considerations. If a promised measure is repeatedly ignored, include the dates and consequences in the complaint.
Ask for a concrete adjustment or support measure.
| Problem | Possible request |
|---|---|
| Telephone communication causes a barrier | Written/email contact, relay service or nominated contact where available. |
| Difficulty managing bills | Accessible format, bill support, payment-plan discussion or third-party bill management. |
| Risk from loss of landline/emergency access | Explain the genuine need and ask what resilience/protection the provider offers. |
| Complex complaint process | Single complaint owner, written updates, extra time or accessible channel. |
The exact measure must fit the person and the service; a provider does not have to agree every requested method, but it should meaningfully consider the need.
“Vulnerability” is about circumstances and support needs, not a single permanent label.
Ofcom’s General Condition C5 requires communications providers to give sufficient consideration to the needs of people whose circumstances may make them vulnerable and to disabled end-users. A need can arise from disability, illness, bereavement, financial difficulty, communication barriers or other circumstances. Tell the provider what practical barrier exists and what support would reduce it.
Vulnerability is situational, not a badge you must permanently prove
Ofcom’s approach recognises that circumstances can make a person vulnerable temporarily or permanently. The practical question is what need the provider knows, or reasonably should know, and what fair support is appropriate in the circumstances.
You do not need to turn the entire complaint into a medical history. Explain only what is necessary to show the communication, accessibility, financial or service need and the adjustment/support you are asking for.
Ask for a concrete support measure
| Barrier | Possible practical request |
|---|---|
| Phone calls are difficult | Email/webchat contact, written summaries or an authorised representative route. |
| Repeated retelling causes distress | Persistent account note and a named case/contact route where available. |
| Disability affects use of voice services | Ask about Ofcom-mandated accessibility services relevant to the need. |
| Reliance on landline for safety/telecare | Flag the critical service dependency before faults or digital-line migration. |
| Financial difficulty | Affordable payment discussion, debt support and suitable tariff/social-tariff information where available. |
Not every provider must offer every example in exactly the same way, but the request gives the complaint something concrete to assess.
Record disclosure and agreed support
If you tell the provider about a relevant need, note when, how and what it agreed to do. If an adviser says “we have added a note that you should be contacted only by email”, ask for confirmation. A later failure can then be assessed against the agreed support rather than becoming a dispute about what was said.
Do not let the vulnerability issue swallow the underlying telecom issue
Keep two tracks if necessary: the substantive problem (wrong bill, outage, default, failed switch) and the way the provider should handle you. A provider can be sympathetic yet still fail to correct the bill; equally, correcting the bill does not necessarily answer a serious failure to follow agreed support arrangements.
Customers in debt or struggling to pay
Ofcom’s vulnerability framework specifically addresses fair treatment of customers in debt or financial difficulty. If collections or disconnection are threatened, engage early, explain the position and ask what support/payment options are available. Where a debt itself is disputed, make that clear separately: financial vulnerability does not mean accepting an inaccurate balance.
Critical landline and digital-voice dependencies
Where a person relies on telecare, alarms or other equipment connected to a landline, tell the provider before a migration or fault if possible. Ask what compatibility and continuity steps apply. Do not assume every analogue device will work identically over a router-powered digital voice service, particularly during a power cut.
Common responses, and what to ask next
| Provider says | Ask next |
|---|---|
| “We have noted vulnerability.” | What practical support/action has actually been recorded? |
| “You must call us.” | What accessible alternative channel is available given the stated need? |
| “The debt process is automatic.” | How has the provider’s vulnerable-customer/debt policy been applied to this account? |
| “The bill is correct, so vulnerability is irrelevant.” | Billing merits and fair treatment are separate issues; address both. |
What to write
Explain the barrier, the requested support and the underlying problem separately.
“I have told you that [brief need/barrier]. To enable me to manage this complaint, please [specific support]. Separately, the substantive issue remains [billing/fault/etc]. Please confirm the support note on my account and answer the underlying complaint on its merits.”
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Related telecom guidance
Official sources
Check the rules behind this guide
- Treating vulnerable customers fairly - Ofcom
- Telecom ADR and complaints - Ofcom
- Ofcom: General Conditions: C5 ↗
- Treating vulnerable customers fairly - Ofcom
- Rules for providers - Ofcom
These are official or primary sources for this topic. Rules, scheme terms and deadlines can change, so check the live source before relying on a formal time limit or procedure.