MSE reports and consultation responses

Here are details of the MSE Campaigns team's reports and consultation responses.

We'll update this page regularly as we publish new work.


Our campaigning reports draw attention to particular consumer problems, provide new evidence about the issue, and make recommendations for change. These reports will usually be directed to the Government department or the regulator responsible for making improvements to the system. Reports are not the end of our campaigning work on an issue though, as we will then turn our attention to making sure that they lead to positive changes being made for consumers.

Explore our more recent reports below:

  • MSE commissioned a final report in a series by LSE London, funded by Martin Lewis, which puts forward costed solutions to the horror of the situation facing up to 200,000 mortgage prisoners. These are borrowers who’ve been trapped on high rates after their loans were sold by the state to 'closed book' inactive lenders after the 2008 financial crash.

    Critically, only the Government has the data and power to free mortgage prisoners, and MSE has long been campaigning for it to act.

    Here's a summary of the key points made in the report:

    • This final LSE report is for the first time able to include indicative costings the Government requested for proposed solutions in the report. 
    • In 2009, the Government acknowledged that selling these mortgages to inactive lenders had the potential to severely harm consumers, but didn't take action to prevent this.
    • The Government has since made £2.4bn from the sale of these loans – while prisoners have suffered financially, mentally, and physically for more than a decade. 
    • The LSE report has proposed solutions that would help prisoners eventually remortgage with active lenders. These include:

      • Free comprehensive financial advice for all prisoners (required for any borrower who might go on to access other solutions)
      • Interest-free equity loans to clear the unsecured element of Northern Rock's 'Together' loans
      • Government equity loans on the model of Help to Buy, interest-free for the first five years.
      • Fallback option: A Government guarantee for active lenders to offer prisoners new mortgages.
    • The LSE report estimates these solutions could cost between £50m and £347m over 10 years depending on take-up. While the overall outlay would be £370m to £2.7bn, this is reduced to £50m to £347m net, as the Government would hold some equity loans itself.

    For the full analysis and recommendations, read LSE London's full report: Releasing the mortgage prisoners: Proposed solutions and illustrative costings.

    Also see the MSE News story on the report's publication: Government made £2.4 billion from mortgage prisoner scandal - Martin Lewis says it must fix problems caused.

  • Lifetime ISAs (LISAs) are in desperate need of a radical overhaul. LISAs are savings accounts which provide a 25% uplift on up to £4,000 of savings each year, provided the saver uses the money to buy an eligible first property, or for retirement. However, the strict threshold on the price of the property being purchased risks the product becoming unusable for many in the years to come. In addition, if they can’t use their LISA to purchase an eligible property, they are hit with a penalty to access their funds  – a further blow to first-time buyers.

    Since LISAs were launched in 2017, house prices have risen by 35% (as at January 2023) but the property threshold attached to LISAs has remained at £450,000. This sharp increase means more people who began saving in a LISA in good faith may now have to buy a property over the threshold—meaning they will be forced pay a 25% penalty, which includes 6.25% of their OWN money, to access their savings, or find the money for a deposit elsewhere.

    Whilst the issue of rising house prices is most acute in London, where average prices were already over £450,000 at LISA launch, it is fast becoming an issue across England – meaning the Government must take action to future-proof this savings product for first time buyers in years to come.

    In our report, we call on the Government to make one or both of the following changes:

    • Reduce the early withdrawal fee from 25% to 20% for those purchasing homes above £450,000. This relaxing of fees was implemented on a temporary basis by the Government to help savers during the Covid-19 pandemic, which proves it can be done. It means savers lose out on the Government’s 25% bonus, but do not forfeit their own cash.
    • Uprate the LISA property price threshold in line with average property prices, and continue to do so automatically on an annual basis going forward. In January 2023, when we launched this campaign, we calculated the cap should be increased to £607,500, due to the 35% rise in prices over the last five years.

    Read the full report: Locked out by the LISA.

    Read the campaigns blog: The Lifetime ISA is in need of a radical overhaul – here's why.

    Read our news story: Martin Lewis: Outdated LISA rules COSTING first-time buyers and need a radical overhaul.

  • In summer 2022, three out of the four major mobile networks re-introduced ‘daily’ roaming charges for customers travelling in the EU. But networks do not all share the same definition of what a ‘day’ is, and moreover, some do not communicate this definition explicitly to customers when they begin roaming.

    Key regulations to protect consumers against high roaming fees, such as an SMS on arrival in a different country, a monthly cap on roaming data charges, and protections against inadvertent roaming, have expired in UK law.

    This means that consumers are at risk of paying much more for using their mobiles abroad, and all with weaker rights.

    In this report, MSE recommends that Ofcom should immediately re-instate the fallen roaming consumer protections. In doing so, the regulator should make further changes to the rules so that:

    • Ideally, all providers should use the same definition – that a ‘day’ is a 24-hour period from first use. At a minimum, a day defined as ‘up to 11.59pm on the same day’ should be scrapped.
    • All providers should be mandated to clearly explain how they define a ‘day’ in the arrival SMS that customers receive.
    • Providers should alert customers at least an hour before the end of the ‘daily’ roaming period, so they know they will incur additional charges if they continue to use mobile services.

    Read the full report: The roaming risk: how lapsed protections could cost consumers.

  • This report calls for reform of APRs for credit cards and personal loans, and greater transparency of the credit advertising space. Using research commissioned by MSE and undertaken by YouGov, we found that the current system damages consumers' financial and emotional wellbeing. The report makes a number of recommendations, such as:

    • Replace representative APRs with typical APRs. This means at least 66% (currently 51%) of successful applicants would be offered the advertised rate – though even more is better.
    • Cap the difference between the typical and maximum APR.
    • Mandate firms to disclose the average proportion of successful applicants who don't get the advertised APR, and by how much.
    • Apply the improved APR rule to advertised 0% deal lengths for credit cards too. This would mean at least 66% of those accepted get the advertised 0% length. Currently, there isn't a rule on this. (It should also apply to other risk-based pricing models.)
    • Consider mandatory quotation searches (or 'soft' credit searches) for credit card and personal loan applications. Or at the very least, before application, firms should communicate prominently the rate range for those not accepted at the advertised rate.

    Our report was welcomed by the Chancellor, Rishi Sunak MP. In response to the report, he asked regulator the Financial Conduct Authority to investigate. For more information, read our MSE News story.

    Read the full report: It's time for a 'typical' solution to interest rate shock.

  • MSE commissioned the LSE London research group to research and write this report, which was funded by Martin Lewis. This important work highlighted the urgent need to unlock 250,000 mortgage prisoners.

    LSE London recommended eight potential solutions to free mortgage prisoners and, crucially, identified that only the Government could act to free them. The recommendations include:

    • Interest-free Government equity loans – which, similar to the Help to Buy scheme for first-time buyers, would bring down some prisoners' loan-to-value ratios so they can remortgage.
    • Remove 'Together' loans as an obstacle – by decoupling the secured and unsecured elements of this former Northern Rock product, taken out by many mortgage prisoners.
    • Mortgage rescue – which would allow those whose mortgages are financially unsustainable to remain in their homes as tenants, while the property is sold to housing associations with a buy-back option later.
    • Bringing all owners of 'closed books' within the Financial Conduct Authority's (FCA) oversight. Similar to measures in Ireland, this would bring owners of 'closed books' within the FCA's regulatory perimeter.

    For the full analysis and recommendations, read LSE London's full report: Releasing the mortgage prisoners.

    Also see the MSE News story on the report's publication: Only the Government can release the 250,000 mortgage prisoners it's failed – and coronavirus is a tipping point, so not acting now could devastate lives.

  • In 2020, in the early months of the pandemic, the MSE Campaigns team worked to understand the issues that were facing consumers, and to report these to Government, Parliament and regulators. This was to help inform the policies across larges swathes of personal finance that were being rewritten at record speed.

    Find out more about how we did this, and some of the changes that happened.

  • Following the recommendations MSE set out in its 2017 report, Sharper teeth, we conducted further research into the 8-week rule – the time a consumer often has to wait before they can take their complaint to an ombudsman.

    We commissioned YouGov to conduct primary online research, on a nationally-representative basis, to ask for consumers' views on how long they should have to wait before escalating their complaint. From this research, we recommended that:

    • The eight-week rule must be reduced to ideally two weeks, but no more than four weeks.
    • Consumers in crisis must be able to involve the ombudsman immediately.
    • The Department for Business, Energy and Industrial Strategy (BEIS) should include reform of the eight-week rule in its announced Consumer White Paper.

    Read the full report: Justice delayed: the case for shortening the ombudsman eight-week rule.

    In October 2021, the Government broadly supported our proposal to reform the eight-week rule as part of BEIS's consultation on reforming competition and consumer policy. We're still awaiting for the outcome of the consultation to see what action the Government intends to take. Read more in our MSE News story.

  • Co-authored with the Russell Group of universities, this report called on the Government to scrap the current student loan statement. The report analysed the results of a survey of 5,796 people – made up of students, graduates and parents – who considered MSE and the Russell Group's proposed redesign of the student loan statement. Overall, the survey found that 90% of 2,680 respondents said that the proposed redesign helped them understand the system.

    The report also set out a number of recommendations for the Government to take forward, including:

    • The Government and the Student Loans Company (SLC) should use the proposed 'Graduate Contribution Statement' as a basis for redesigning the current statement for Plan 1 and Plan 2 graduates as soon as possible.
    • The Government should encourage the Office for National Statistics to devise a more accurate model to estimate future graduate wage growth.
    • The statements of UK graduates working overseas need to be considered further.
    • The SLC should provide more information to students and graduates online.

    Read the full report: Moving towards a Graduate Contribution Statement.

  • Our report, Sharper teeth: the consumer need for ombudsman reform, was written for the All-Party Parliamentary Group on Consumer Protection. We made four key recommendations for reform of the ombudsman sector, urging the Government to make ombudsmen the gold standard in dispute resolution:

    1. All ombudsmen need a statutory basis as a foundation.
    2. Oversight of ombudsmen must be boosted.
    3. The eight-week rule should be shortened and needs vital exceptions.
    4. (Aspiration) Comprehensive ombudsman membership in consumer sectors.
  • MSE has been raising awareness of the SMI council tax discount since 2016. In 2017, MSE published a report bringing together its research into the issue with a number of recommendations to improve awareness and uptake of the discount. These included:

    • Central and devolved Governments to conduct an urgent review of local authority procedures regarding the council tax SMI discount.
    • A standardised application procedure to be introduced across all councils, resulting in a clear and simple process for people to claim the SMI discount and rebates.
    • Frontline council staff to be adequately trained with a full working knowledge of the discount and how to claim it.
    • All councils to allow backdated claims and rebates, alongside implementing a clear policy.

    For the full set of recommendations, read the report: The disregarded discount.

    Since the report's publication, the Welsh Government and all 22 Welsh local authorities have made every change called for in the report. For more information, see our MSE News story.

Consultation responses

What is a consultation and why does MSE respond?

Consultations are used by policymakers to collect opinions on a new area of policy before it's brought into force. MSE responds to consultations, usually those published by the Government or regulators (like Ofgem or the Financial Conduct Authority), to give our views on how a particular policy may affect consumers.

To make sure we're representing consumers' interests fairly and accurately, we'll sometimes ask you to respond to a survey or ask for your experiences of a particular area. We'll use this insight to point out where policymakers should rethink their plans, or where we think a policy may be particularly helpful. Take a look below at some of our more recent consultation responses.

  • The energy regulator Ofgem is currently carrying out a review of its operating costs. As part of this, it has the opportunity to look at how standing charges – the fixed daily cost you pay for energy – work.

    MSE told Ofgem how the steep standing charges are a moral hazard which means low users aren’t rewarded for cutting their bills, as everyone has a minimum cost they can’t go below. This means people are currently – and crucially, unavoidably – spending a few hundred pounds a year just for the facility of having gas and electricity, before having actually used any.

    Because of this, those who are desperate and trying to cut back their energy usage gain little benefit from it, and our evidence shows that many are already facing significant challenges as a result. Not only this, but the current set-up disincentives low use in general, which doesn’t support energy efficiency and low carbon targets.

    When we asked MSE users how they feel about the way standing charges work, nine in ten – an overwhelming majority – said they think they should be lowered or scrapped entirely, showing there’s a clear appetite for change.

    MSE wants to see some of the burden in the Energy Price Cap shifted away from the standing charges to the unit rate. Importantly, this should come with proper protections for vulnerable high energy users. This includes those with additional needs, such as physical or mental health conditions which lead to greater energy usage.

    Read our full consultation response (opens as a PDF)

    See Martin’s blog: Why are energy standing charges so high? What can be done?

  • Back in February 2021, the Government announced that it would regulate BNPL firms – a move we have long called for.

    BNPL can be – and regularly is – a useful tool for consumers when making spending decisions. But the continuing lack of protection through regulation is a huge concern, so we’re pleased to see plans to finally address this – though progress so far has been much too slow.

    In January 2022, MSE responded to the Treasury’s first consultation on the regulation of BNPL. We made a series of recommendations around the government’s approach to regulation, including the following:

    • Advertising and promotion of BNPL must make it clear that this is debt.
    • Pre-contractual information given to consumers before they use BNPL must make it clear what the consequences are if they can’t keep up with repayments.
    • BNPL payment journeys must be designed in a way that gives consumers enough information, in an effective way, to enable them to make informed spending, or borrowing, decisions.
    • Like when using a credit card, section 75 of the Consumer Credit Act (CCA) must also apply to BNPL transactions.
    • Internal complaints processes need to be improved, and BNPL users must also have access to redress via the Financial Ombudsman Service (FOS).

    Since then, we’ve been happy to see our key asks – those involving section 75; FOS access; increased protections around advertising, promotion and pre-contractual information; plus, measures to protect customers in financial difficulty – look to have largely been considered and provisionally ‘met.’ But importantly, these changes must be very carefully implemented and supervised to ensure regulation is a success.

    The Treasury recently published a second consultation on BNPL regulation, this time looking at the draft legislation and regulatory rules. MSE responded to this in April 2023 – we were largely supportive of the proposals, though we cautioned the Treasury and the Financial Conduct Authority to be wary of potential regulatory loopholes and unintended consequences.

    The BNPL market is growing at speed, and more people are now using these services as a direct result of the cost of living crisis. We need to see this legislation go through Parliament as soon as possible, alongside other regulatory action.

    Read our full response to the January 2022 consultation (opens as a PDF)

    Read our full response to the April 2023 consultation (opens as a PDF)

    Read the campaigns blog: Why MSE is campaigning for buy now, pay later to be regulated.

  • The Treasury recently announced plans to reform the Consumer Credit Act (CCA), a landmark piece of legislation which has been in place since 1974 and protects people taking out consumer credit. Given the scale and complexity of making changes to a system which has been in place for decades, this process of reform is likely to take several years.

    MSE responded to the government’s first consultation on CCA reform in March 2023. We made it clear that the CCA has played a vital role in safeguarding consumers participating in the consumer credit market since its creation. It’s crucial that any reforms to the consumer credit framework do not remove or weaken existing consumer protections.

    We warned the Treasury that it must be vigilant and carefully consider potential unintended negative consequences for consumers in all the decisions it takes.

    Read our full consultation response (opens as a PDF)


  • In December 2022, MSE responded to the Payment System Regulator’s (PSR) consultation on making reimbursement for APP scams mandatory – meaning victims should be more likely to get their money back. This type of scam happens when a person or business is tricked into sending money to a fraudster posing as a genuine payee. See our guide on 30+ ways to stop scams for tips on how to spot scammers’ (ever more sophisticated) tactics.

    We welcomed the PSR’s direction of travel on tackling this crime and supported mandatory reimbursement for victims. We feel that – properly overseen – it should lead to stronger, more consistent protection for consumers. We stressed that prevention is better than cure – and so welcomed planned work to improve data sharing between banks to stop this fraud happening in the first place.

    Some of the key points we made are below:

    • MSE supported the proposal that a customer needs to have shown a very significant amount of carelessness to not get their money back. We feel this will set a higher bar and drive better outcomes for consumers than under the current system.
    • We agreed with the PSR’s proposal for vulnerable consumers to be reimbursed even if they’ve acted with ‘gross negligence’ – as they may be more at risk of being taken in by scammers’ tactics.
    • MSE raised some concerns that a minimum claim threshold of up to £100 – being considered by the PSR – could potentially lead to some negative consequences, such as the under-reporting of scams under this amount.
    • We broadly welcomed the 50:50 allocation of reimbursement costs between sending and receiving banks – as under the current system, the bank which receives money through APP scams contributes very little to reimbursements costs. In our view, this new approach should help prompt better consumer outcomes by placing stronger incentives on banks to make faster progress to detect and prevent scams.

    More broadly, we made the point that scams are also being enabled by other industries – so collaboration across different sectors is needed to tackle the full life cycle of scams.

    Read our full consultation response (opens as a PDF).

  • The Welsh Government recently published a consultation looking at proposed reforms to council tax in Wales. Our Campaigns team responded specifically on what’s known as the 'severely mentally impaired' (SMI) council tax discount – a key campaigning area for MSE. For more info, see our guide on how to claim the SMI discount.

    We’ve been pleased that the Welsh Gov has so far led the way in improving communications, claiming procedures and forms around this discount – as per our 2017 report’s recommendations. Overall, we welcomed continued efforts to improve the consistency of comms and boost uptake of this important discount. But there are still areas to consider – some of our key points are below:

    • In some cases, there’s a lack of clarity for medical professionals about the legal definition of SMI, forcing some to seek a second opinion – so we welcomed further measures to improve knowledge for those who can certify an SMI.

    The Welsh Gov also asked whether it should change the titles and descriptions of any discount, specifically calling out the term ‘severely mentally impaired’.

    • We described some anecdotal feedback we’ve had from our users telling us how their loved ones find the term stigmatising and have been put off applying as a result. We said the flexibility to change the title could potentially have a positive impact on uptake.
    • Yet we told the Welsh Gov that we’d ideally like to see a uniform approach to language and descriptions across all GB nations, encouraging them to work with relevant stakeholders to achieve this.
    • Ultimately, we argued that more analysis into the likely impact of such a name change is needed and we’d welcome the Welsh Gov’s efforts in this area.

    Read our full consultation response (opens as a PDF)

  • Following on from its previous consultation in this area in 2020, the Government recently sought views on the scope of its Online Advertising Programme. MSE focused our response on only the elements related to consumer harm caused by scam ads.

    Overall, we welcomed many aspects of the consultation. But we urged the Government to go further in some areas to ensure that all scam ads across the online landscape would be captured by the proposals.

    Some of our key recommendations included:

    • Replacing the current self-regulating landscape of online scam ads with a full statutory approach. This would require each actor in the advertising supply chain to take responsibility for preventing fake ads from being shown to consumers and would provide better redress for those who have been affected by such scams.
    • The development of a new reporting tool so users can quickly and easily report scam ads when they come across them online. This should have consistent language and symbols across all platforms, so the reporting process can be easily learnt and used when needed.
    • Widening the scope of the consultation to include scam advertisements sent by email, which are not currently covered by the Government's proposals.

    Read our full consultation response (opens a PDF).

  • This consultation asked for views on the technicalities of how the planned £200 Energy Bills Support Scheme, which would automatically be given to every household and then repaid over five years, would work in practice.

    In our initial comments, we urged the Government to make the scheme voluntary, or better still, non-repayable.

    We then focused on some specific concerns with the plans as they stood for traditional prepayment meter customers. These included:

    • The proposed expiry date for vouchers of 31 March 2023 does not necessarily offer all traditional prepayment meter customers enough time to make use of them. We therefore recommended a longer expiry date for vouchers issued to customers with traditional prepayment meters, at the very least in exceptional circumstances.
    • A possibility that vouchers could be misplaced by customers if they are provided with five separate vouchers at the same time. We recommended that vouchers should be trackable and a system created so that any misplaced vouchers can easily be cancelled and replaced if necessary.
    • Customers in receipt of vouchers may mistakenly believe that they will not have to pay back any voucher amount that they do not redeem. We recommended that communications, including the delivery of vouchers and on the vouchers themselves, should make it clear that there is no gain to be made from not making use of them.

    Update: Since MSE's submission to the consultation, the Chancellor announced significant changes to the Energy Bills Support Scheme on 26 May 2022, including that the £200 'loan-not-loan' will now be a £400 non-repayable grant for every household's energy bills.

    Read our full consultation response.

  • Our response to the wide-ranging LLE consultation gave some initial comments on specific elements of the proposals. It also highlighted areas that were not in this consultation, but that we felt should be considered by the department at this stage of the LLE's development.

    We recommended that:

    • Government communications should be clearer about the full impact of the LLE proposals.
    • The proposed account portal needs to contain information about loan repayments.
    • Any means-tested element of student loans should be determined by an independent evaluation process.
    • A re-evaluation of whose income is included in means-testing to take account of current family landscapes where parents split up and start new relationships.
    • The Government should retain its policy position of introducing a Sharia compliant student finance system.

    We also asked for additional information on:

    • The loan repayment terms.
    • What, if any, impact on Welsh learners is expected.
    • How the Government intends to communicate these changes to learners.
    • The method for determining maintenance loan allowance.

    Read our full consultation response.

  • In early 2022, MSE submitted a response to the Financial Conduct Authority's (FCA) consultation about its proposed new consumer duty. We broadly welcomed the proposals, and concluded that the change was positive in theory, but had a lot to deliver in practice. We outlined that negative consequences may still arise as a result of the change, and these must be mitigated against. We also thought that effective FCA supervision and enforcement were clearly key to the success of the new consumer duty, but we wanted to hear more detail on these points.

    We are waiting to hear the outcome of this consultation.

    Read our full consultation response.

  • At the end of 2021, Ofgem consulted on its plans to allow it to make changes to the price cap outside of the normal six-monthly adjustment period, in exceptional circumstances. In our response, we expressed concerns that its proposal would not adequately address underlying issues in the market, and would have an unfair impact on consumers. We recommended instead that Ofgem should reduce the current six-monthly assessment period to a shorter period.

    Read our full consultation response.

    On 4 February 2022, Ofgem announced it would give itself powers to change the price cap in 'exceptional circumstances' as a result of the consultation. It also published a further consultation on plans to reduce the current six-monthly assessment to a quarterly assessment. It plans to implement any proposed changes from October 2022. For more information, read our MSE News story on Ofgem's decision.

  • Our response to the Financial Conduct Authority's (FCA) proposed plans to help mortgage prisoners was informed by a self-selecting survey of mortgage prisoners, who told MSE about their experiences. Overall, we concluded that the FCA's proposals were welcome, but hugely insufficient as they would only help some. In our response, we set out that a comprehensive solution is urgently needed, and that these proposals would only be a small part of the solution. We said who we thought would not be helped by the proposals, and that HM Treasury has a responsibility to act to help those left behind.

    Read our full consultation response.

    To read more about how MSE and Martin Lewis have been campaigning on this issue, read our blog. Also see our Mortgage prisoners guide for more information.

  • Our response to this call for evidence focused on improvements that could be made to the Plan 2 student loans repayment system (the most current at the time), and was based on our five principle areas of focus:

    • Student loans are misnamed and misframed as a debt.
    • Students do not have enough money to live off while at university.
    • The Government must be honest about the parental contribution.
    • Student loan statements are misleading and damaging.
    • There should be a guarantee of no negative retrospective changes.

    Read our full response.

    The Government-commissioned Augar report, which used the input from this call for evidence, contained some proposals which were specifically based on our recommendations, and/or attributed to MSE or Martin Lewis. These included renaming the loan as a 'student contribution system' and making the parental contribution explicit. Read more in our MSE News story.

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