In the early days of the internet, accessibility was only just beginning to take shape as a formal discipline. Early guidance, such as the original Web (Content) Accessibility Guidelines published by the W3C in 1999 (now known as WCAG 1.0), largely focused on supporting blind users who couldn’t see on‑screen content. Organisations responded by adding alternate text to images on their websites. This undoubtedly made a difference to blind service users, but accessibility was often seen as a niche or additional requirement rather than a core design consideration.
This shift in thinking is relevant to the Priority Services Register (PSR). On one level, the PSR does exactly what it says on the tin: it’s a register of people who, due to their circumstances, need prioritised support from utilities services. However, its value is being limited because of the way this data is sought, captured and used. The challenge for utilities is clear: how can the PSR evolve to deliver better customer experiences and more equitable outcomes for all?
How data is sought and captured implies narrow relevance
For many pensioners, people with disabilities, or those with hearing or visual impairments the PSR is a lifeline. It ensures access to essential adjustments such as bills in braille, and provides priority support during supply disruptions. In a sector where customers cannot opt out of service or switch providers, particularly when it comes to water, the ability to identify and proactively support vulnerable groups is not a nice-to-have, it is a fundamental responsibility.
The definition of the PSR is theoretically broad enough to capture circumstances that may lead to suboptimal service outcomes, including temporary health‑related situations such as pregnancy or recovery from surgery, and situational factors like bereavement or caring responsibilities. In practice, however, the implied definition is often narrower, focused on disabilities, health conditions, and very young or old age. By routing sign‑up through outage‑focused networks, the PSR is implicitly framed around emergency needs, reinforcing a narrow interpretation of vulnerability despite a much broader, year‑round definition aligned to service outcomes.
While recent initiatives have made progress in reducing the burden on customers to register for the PSR, for instance the 2024 data‑sharing agreement between energy and water companies, more is needed. To truly strengthen consumer protection, the sector must proactively seek to understand a broader range of customers’ vulnerabilities and, critically, the impact of these on customer outcomes, whilst enabling deeper, more integrated data sharing between utilities and other essential services. Only then can the PSR reflect the complexity of people’s lives and the many priorities for improving service outcomes.
Using PSR data for universal design
With the idea that PSR reform should recognise vulnerability as something that is year‑round, fluid and circumstance-dependent, utilities require a more holistic view of customers’ needs to deliver equitable outcome. To do this effectively, providers need digital systems that support regular updates, reviews, and more sophisticated assessments of customer needs. This means moving beyond relying on basic tick-box forms.
As we’ve established, the eligibility criteria for the PSR are already broader than commonly applied: the limitation isn’t the policy, it’s in how organisations interpret and operationalise it. The emphasis should revolve around “how can we design services that work for the majority of customers’ circumstances, all the time?”. For example, during an outage someone with mutism may need support if reconnection needs to be discussed, but not emergency supplies like bottled water or batteries. Yet outside emergencies, they could face poorer service if agents are unfamiliar with Relay UK or webchat is blocked by rigid automation.
We can call this approach “PSR 2.0”. At its core, this would adopt a broader and more dynamic definition of vulnerability, and help customers share the impact of their circumstances across the whole customer experience. Secondly, a single disclosure would be shared securely across multiple service providers (utilities, emergency services, banks and primary healthcare providers, for example), with omni-channel access and reminders for customers to keep their record updated. This would arm providers with the insight they need to bake this support into ‘normal service design’.
Existing challenges can be solved today
While a truly transformative model such as PSR 2.0 may still be several years away, there are practical steps utility providers can take today to improve outcomes for vulnerable customers. The challenge is many providers lack the data to identify vulnerability early or deliver the right support consistently.
There are three key reasons for this. Firstly, many customers are often not motivated to disclose their circumstances due to not believing they are eligible for support. Secondly, without clear guidance, individuals may not recognise their own support needs, or they may struggle to communicate them within the limitations of a PSR disclosure. Thirdly, even when disclosures are made, providers may not consider the relevance of this to the whole customer experience.
To deliver equitable outcomes, utilities need to understand not just who is vulnerable, but how vulnerability translates into potential harm. Inclusively designed digital triage tools can help vulnerable customers to communicate the support they need. They guide customers with empathetic, straightforward language to reassure customers as they understand what support is available and share what their needs are. Operational teams receive accurate, standardised data from their customers and design teams can analysis trends and segments of support needs.
Expanding PSR can be a catalyst for change
Ultimately, the priority must be ensuring vulnerable people are properly supported, and that essential services don’t limit equality to emergencies. A unified approach to data and broader applied definitions of vulnerability are the most effective way to fuel universal design of utilities services. If we can get this right for services that people can’t opt-out of, this could be a catalyst for a more equitable society.