Committee publication · Correspondence · 6 March 2026

Correspondence from Southern Water regarding debt collection practices, dated 26 January 2026

From: Environment, Food and Rural Affairs Committee

Summary

Southern Water responds to the Environment, Food and Rural Affairs Committee's inquiries about debt collection practices, providing detailed data on High Court Enforcement agent instructions (2017–2025), explaining its litigation assessment process, and outlining procedures for customers not pursued via litigation. The company states it treats litigation as a last resort and does not knowingly commence enforcement against identified vulnerable customers.

Key findings

Southern Water instructed High Court Enforcement agents 4,440 times in 2025, down from a peak of 15,707 in 2019; debts under £1,000 account for growing proportion (31% in 2025 vs 28% in 2019).
Litigation suitability assessed via UK Search scoring mechanism evaluating CCJs, residency, employment, contact details, debt age, last payment date, customer age, live disputes, and previous litigation outcomes.
Of 55,000 customers referred for High Court enforcement, 2.7% were subsequently flagged as vulnerable; vulnerable customers identified after enforcement begins are returned to UK Search's Vulnerability Team.
Customers in receipt of means-tested benefits are not automatically excluded from litigation; affordability checks consider available income and payment plans are adjusted if breached.
All third-party enforcement partners (debt collection agencies, solicitors, High Court companies) comply with Taking Control of Goods National Standards and Civil Enforcement Association Code of Practice overseen by the Enforcement Conduct Board.

Tone

Procedural

Topics

consumer-protectionutilities-regulationdebt-enforcementvulnerable-consumers

Key actors

Southern Water Services Ltd, Alistair Carmichael MP, Environment, Food and Rural Affairs Committee, UK Search, Civil Enforcement Association (CIVEA), Enforcement Conduct Board (ECB), Lawrence Gosden

Notable line

“Collecting a debt through litigation is a last resort for Southern Water …”

Key Quotes

“Collecting a debt through litigation is a last resort for Southern Water, which we only bring forward after providing extensive opportunities to rectify the debt through other options.”
— Lawrence Gosden · Explaining Southern Water's general enforcement philosophy

“Southern Water would not knowingly commence litigation against any customer where a vulnerability had been identified through this or other records we hold.”
— Lawrence Gosden · Describing protections for vulnerable customers in litigation assessment

“… of the 55k customers referred for High Court enforcement, 2.7% have since been flagged as vulnerable. Where medium or long-term vulnerability is identified, the customer's account would normally be returned to UK Search's Vulnerability Team.”
— Lawrence Gosden · Providing data on vulnerable customers identified after enforcement action commenced

“Customers in receipt of a means-tested benefit would not be excluded automatically from litigation on this factor alone, given that benefits such as Universal Credit are claimed by around 8.4 million people, including those in work.”
— Lawrence Gosden · Explaining approach to customers on means-tested benefits

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Source · parliament.uk record ↗