Ofgem puts outcomes front and centre

On 23rd June, Ofgem published its Consumer Outcomes Strategic Direction, setting out plans to move energy regulation away from prescriptive rules and towards an outcomes-based approach.  

There is some striking similarity with the FCA's Consumer Duty, even down to the language Ofgem uses about 'good outcomes for consumers'. Where the FCA settled on four outcomes, Ofgem has landed on seven. They include two that are heavily related to customer understanding.    

Plain Numbers supports an outcomes focussed approach to regulation, so we welcome the direction of travel from Ofgem, and hope that it will become more ambitious in future.  

This is what should be on every comms team's radar 

Outcome 2 says "Consumers receive accurate, timely, accessible and understandable energy bills." Outcome 5 says "Consumers get clear, accurate, and timely information to help them make informed choices."  

The key thing for firms to know is that customer understanding will be front and centre in the regulator's mind. Including the fifth outcome shows that it’s not just about bills.

The bar isn’t as high as the FCA’s Consumer Duty - “clear, accurate and timely information” sounds a bit more like the FCA’s Principle 7 than Consumer Duty. That being said, firms in the energy sector should be left in no doubt that understandable communication is becoming more important.  

In the detail of outcome 5 there is a line worth pulling out: information should be "easy to understand, making use of simple language and numbers." Numbers named alongside words, not as an afterthought, is a meaningful detail. For anyone drafting customer communications, that's the line to build around. 

Energy isn't the first sector to make this shift  

Financial services went through the same move with the FCA's Consumer Duty, which asks firms to evidence that customers actually understand the information they're given, not just that it was presented clearly.  

Ofgem's outcomes aren’t the same, but its Strategic Direction reads like a natural step in that direction, and it's a fair bet that customer understanding is heading up in the priority list. Being clear and being able to prove understanding are two different things. Providers that get ahead of that distinction now will be in a stronger position whichever way Ofgem moves next. 

What the evidence shows 

Working with Cadent Gas, one of the UK's largest gas distribution networks, and research specialists Thinks Insight, we ran a Randomised Controlled Trial (RCT) with over 1,000 participants on Cadent's connections quote for new customers. This kind of communication is a good example of where understanding matters beyond billing, and the document will need to meet the criteria of the fifth outcome.  

Half of the participants saw the original communication, while the other half saw a version using the Plain Numbers Method. Both were tested using five comprehension questions, not just whether people said it felt clear. 

The difference was significant: 

• The proportion of people who answered at least four of five comprehension questions correctly nearly tripled, from 20% to 56%.  

• The impact was greatest for people with lower number confidence, where comprehension jumped from 10% to 38%. 

The most telling finding wasn't the uplift itself, it was the gap between perceived and actual understanding it exposed. Between 79% and 83% of people rated both versions as clear, fair and easy to understand. Perceived clarity barely moved. Real understanding did.  

Firms should be aware of this common result when thinking about the new Ofgem outcomes: a provider can satisfy 'clear and understandable' on paper, while customers may not be able to understand what matters most to them.  

The version that drove better understanding also produced more satisfied customers and a more positive view of the company. Better understanding isn't just better for the customer or a simple compliance outcome, it's a commercial outcome too. 

What's next?  

Whatever happens next with Ofgem's implementation consultation on billing specifically (closing on 22nd July, 2026), the research with Cadent Gas shows something energy providers can begin acting on: relying on whether customers feel a communication is clear is not the same as being able to demonstrate real understanding.  If outcomes 2 and 5 are going to mean anything in practice, testing comprehension, not just asking whether something feels clear, is the only way to know. 

That's something any energy provider can check now, regardless of what Ofgem ultimately requires, and the business case looks stronger than ever before following this shift from the regulator.