‘They Know I’m on Oxygen’: The Electricity Register Ireland Will Not Put You On

A woman in her seventies rings her daughter in a bit of a panic. There is a letter on the hall table about an unpaid electricity bill, and an oxygen concentrator running in the back bedroom sixteen hours a day. “Sure they know I’m on oxygen,” she says. “They’d never cut me off.”

They would not, if she were registered. Ireland has a legal protection that makes it impossible to disconnect someone who depends on electrically powered medical equipment, and a second that makes it impossible to disconnect an older person during the winter. Both only work if you put your own name on a list, and no hospital, GP, oxygen company or public health service will put it there for you.

TL;DR

• Irish energy suppliers must keep two registers: a Priority Services Register for customers critically dependent on electrically powered equipment, who can never be disconnected for non-payment, and a Special Services Register for customers vulnerable to winter disconnection because of advancing age or a physical, sensory, intellectual or mental health reason.
• Both are self-registration only. The CRU’s Suppliers’ Handbook defines a vulnerable customer, for the purpose of the code, as “a customer who has self-registered on their supplier’s register”.
• This winter’s protected periods are 1 November 2026 to 31 March 2027 for registered vulnerable customers and 7 December 2026 to 15 January 2027 for everyone else. Suppliers must text or email every customer about the register by 4 December 2026.
• About 122,500 electricity accounts are registered. There are 891,063 people aged 65 and over in the State, and more than a quarter of that age group live alone.
• Registration also unlocks the cheapest tariff your supplier offers for your payment method, and, for the life support category, a free solar PV system worth thousands under the SEAI Solar PV Scheme for Medically Vulnerable.
• Pay-as-you-go meters are only recommended against for people who qualify for the Priority Services Register. Running out of credit is not counted as a disconnection, so it appears in no statistic.

Two registers, and the word that does all the work

The legal definition comes from S.I. No. 463 of 2011. A vulnerable customer is a household customer who is either “critically dependent on electrically powered equipment, which shall include but is not limited to life protecting devices, assistive technologies to support independent living and medical equipment”, or “particularly vulnerable to disconnection during winter months for reasons of advanced age or physical, sensory, intellectual or mental health”.

Read that first limb again, because it is broader than most people assume. It is not confined to ventilators. Assistive technologies to support independent living is in the text. An oxygen concentrator qualifies. So, on the face of it, does a powered hoist, a stairlift, a pressure-relieving mattress pump, a home dialysis machine, a nebuliser used for a chronic condition, or a CPAP machine where a clinician considers it critical.

The Commission for Regulation of Utilities (CRU) turns that definition into two separate lists, and the distinction matters enormously:

• Priority Services Register. For customers critically dependent on electrically powered equipment. Suppliers must “ensure that customers on a Priority Services Register are not disconnected or de-energised at any time for reasons of non-payment of bills”. Not during winter. At any time, in any month, regardless of the size of the debt.
• Special Services Register. For customers vulnerable to disconnection during the winter months. These customers cannot be disconnected for non-payment between 1 November and 31 March.

For the second category, the Handbook puts a number on advancing age that is worth knowing: “Advancing age is taken to be a person of pensionable age (66 years or above) living alone, with another vulnerable person or with minors.” That is not a means test. It is not conditional on illness. A person of 66 living alone meets the stated test as written.

And then comes the sentence that explains why so few people are protected. Section 7.1.2 of the Handbook: “For the purpose of this Code, a Vulnerable Customer is a customer who has self-registered on their supplier’s register.”

There is a countervailing obligation. Suppliers are also required to “take reasonable steps to identify household customers who should be included on a Priority Services or Special Services Register”. In practice, that reasonable step is an annual message telling you the register exists. The burden of identifying yourself stays with you.

What registration actually gets you

• Protection from disconnection, permanent for the Priority Services Register and from 1 November to 31 March for Special Services.
• The cheapest tariff available. Section 7.3.2 requires suppliers to ensure that all registered vulnerable customers are on the most economic tariff available for their chosen payment method and billing format, specifically so that they are not penalised by being left on a legacy tariff. This is the quiet one. Households that never switch supplier are exactly the households that drift onto expensive standard rates, and registration is a standing instruction to the supplier to stop that happening.
• Your details go to the network operator. Suppliers must forward register data to the distribution system operator for an industry register, so ESB Networks and Gas Networks Ireland know there is someone at that address who needs the power back on first.
• Accessible billing. Electric Ireland, for one, lists Braille, large print and talking bills under its Special Services category for customers with a visual impairment.
• A nominated representative. You can authorise a son, daughter, carer or friend to deal with the account on your behalf. New for this winter, the CRU requires suppliers to tell all domestic customers that this option exists.

The dates that matter this winter

On 12 October 2026 the CRU published its decision on Additional Customer Protection Measures for 2026/27 (reference CRU2026163). The dates it sets are:

• 1 November 2026 to 31 March 2027: no disconnections for non-payment for registered vulnerable customers on the Special Services Register. Priority Services customers are protected year round.
• 7 December 2026 to 15 January 2027: the general moratorium covering every domestic customer, registered or not. Six weeks, the same length as last winter.
• By 4 December 2026: suppliers must send every domestic customer an email or text, even where that is not the customer’s preferred contact method, setting out who is eligible for the register, how to apply and what the protections are. They must also publicise it on their websites and social media.

That 4 December message is the one to watch for in a parent’s inbox, and the one most likely to be deleted unread. You do not need to wait for it.

The same decision requires repayment plans to reflect what a customer can actually afford, treats upfront lump sums as optional rather than mandatory, and allows at least 18 months to clear a debt.

The arithmetic

Here is where the self-registration rule shows up in the data. The CRU’s own chart of registered vulnerable customers runs from October 2022, when there were 48,464 electricity registrations and 15,544 gas. By February 2025 the electricity figure had reached 101,605 and gas 30,693. The most recent point on the chart published in October 2026 shows 122,501 electricity accounts and 38,821 gas accounts.

That is real growth, and the CRU is entitled to call its annual promotion campaign a success. Registrations have more than doubled in four years.

Now set it beside the population. CSO population estimates for April 2026 put 891,063 people aged 65 and over in the State. Census 2022 found that more than a quarter of people aged 65 and over live alone, a proportion that rises to 44% of those aged over 85. Apply that quarter to the current population and you get well over 200,000 people who, living alone and past pensionable age, satisfy the Handbook’s own description of advancing age before any question of illness arises.

The entire electricity register, both categories combined, across every age group and every medical condition in the country, holds fewer accounts than that.

It is also worth noting what the published figures do not tell us. The CRU reports the register as a single combined number for electricity and a single combined number for gas. There is no published breakdown of how many of those 122,501 accounts are Priority Services, with permanent protection, and how many are Special Services, with five months of it. Nobody outside the industry can say how many households in Ireland have declared that someone inside depends on electricity to stay well.

The backdrop is worsening. In the year to May 2026 the value of domestic electricity arrears rose 20% and gas 17%, and the average debt held by an electricity customer in arrears went from €467 to €515. By June 2026 a standard electricity tariff was 83% dearer than in January 2021, and gas 107% dearer.

The oxygen problem

Nowhere is the gap starker than for people on long-term oxygen.

The HSE’s own patient page on home oxygen therapy is clear and useful on the clinical side. It explains the five device types, notes that large backup cylinders are provided “in case there are problems connecting to the electricity supply”, and confirms that the therapy is free of charge if you have a medical card. It says nothing about what the concentrator does to the electricity bill, does not mention the vulnerable customer register, and does not suggest telling your supplier. The one time electricity appears, it is as a hazard to plan around, not a cost to budget for.

The Irish Lung Fibrosis Association put figures on this in its pre-budget submission of 31 July 2025. In a 2024 letter to the Oireachtas Joint Committee on Health, the HSE stated it provided home oxygen to approximately 4,200 patients across all lung diseases, with 420 to 630 more going private. ILFA records that during the oxygen contract changeover the HSE discovered this had been “grossly underestimated”, the oxygen companies reporting roughly twice that figure, and puts current estimates at over 8,000 patients nationally.

ILFA estimates the average annual electricity increase from a single oxygen concentrator at about €1,210, with anecdotal reports of monthly bill increases of up to €500 and households running more than one machine. An Irish Thoracic Society patient survey in October 2023 found that over 40% of patients were rationing their oxygen because of utility costs and delivery delays, and over 80% were worried about rising utility bills.

Rationing prescribed oxygen to keep a bill down is a clinical event dressed as a household budgeting decision, and it does not show up in any health statistic.

There is a further asymmetry. People on home dialysis can claim a Revenue rebate towards the electricity their machine uses, worth thousands a year, as we covered in our guide to kidney failure after 70. There is no equivalent for oxygen. The relief is written by condition rather than by the thing the two groups have in common, which is a machine plugged into the wall keeping someone alive.

Registration does not fix the bill. What it does is guarantee that the supply cannot be switched off while the bill is being argued about, and it puts the household on the cheapest tariff the supplier has.

The pay-as-you-go hole

On prepayment meters, the Handbook says: “It is recommended that PAYG meters are not offered to customers who are eligible to register on the Priority Services Register.” Recommended. The guidance elsewhere repeats that prepayment meters and budget controllers are “not suitable” for those customers, “most particularly those who are critically dependent on electrically powered equipment”.

Recommended is not prohibited. A household can have a concentrator in the back bedroom and a prepayment meter in the hall, and nothing in the rules makes that combination impossible.

It matters because of how the protections are built. The disconnection moratorium protects you from your supplier switching you off. It does nothing when the credit on the meter runs out at eleven o’clock on a Sunday night. That is self-disconnection, and in regulatory terms it is not a disconnection at all. It is counted in no disconnection statistic, it triggers no supplier obligation, and it generates no letter.

The CRU is plainly conscious of this. Its 2025/26 paper recorded 242,000 electricity customers and 76,000 gas customers on pay-as-you-go by lifestyle choice, and said it was “important that customers are aware that there is an alternative option to avoid self-disconnection”. For this winter, the measures do several practical things:

• Emergency credit on prepayment meters stays at €20, doubled from the old €10.
• No more than 15% of any top-up can be taken to recover legacy debt. That rate was 25% before the protection measures began and was cut to 10% for the 2024/25 winter, so 15% is a partial step back.
• The €200 charge for moving from a gas prepayment meter to a credit meter remains suspended.
• Suppliers must tell prepayment customers in debt about alternative payment options, and must place customers on financial hardship meters on their lowest-cost tariff.

If someone in the house depends on electrically powered equipment, the prepayment meter is the wrong meter. Registering on the Priority Services Register and asking to move to a credit account is the single most useful call that household can make this month.

The free solar panels nobody mentions

The SEAI runs a Solar PV Scheme for Medically Vulnerable, for people who depend on life-protecting electrical medical equipment and technology, with a dialysis machine or a respirator given as the examples. Successful households get solar panels of up to 4kWp and a battery system of up to 5kWh, installed free.

The qualifying conditions are short. You, or a member of your household, must be registered with your electricity supplier in the life support category of the Priority Services Register. Your house must have been built and occupied before 1 January 2021.

And the mechanism is the point: if you are on that register and your supplier is participating in the scheme, your supplier contacts you to ask whether you are interested. If you are not on the register, nobody contacts anybody. An entitlement to a free solar array and battery sits behind a list that you have to know exists in order to join.

How to actually get on the register

It takes one phone call or one form. The CRU is explicit that registering must be free and easy to do.

1. Ring the supplier whose name is on the bill, for both electricity and gas if they are different companies. Every supplier has a vulnerable customer registration form, online and on paper. Electric Ireland, for example, takes an online form or a freepost paper form and will post one out if you ring 1800 372 372.
2. Say which category you are applying for. Priority Services if anyone in the house is critically dependent on electrically powered equipment. Special Services if the reason is advancing age, or a physical, sensory, intellectual or mental health reason. If both apply, say so.
3. Be ready for a request for medical confirmation. The Handbook allows a supplier to ask a customer to demonstrate eligibility, including by requesting medical confirmation of vulnerability. A GP or consultant letter naming the equipment and the dependency is usually enough. The oxygen or equipment supplier can often confirm what is installed.
4. Ask two follow-up questions while you have them on the phone. First: am I now on your most economic tariff for this payment method, as section 7.3.2 requires? Second: can you add a nominated representative to this account?
5. Ask about the solar scheme if the registration is in the life support category, and ask whether that supplier participates.

Two small corrections worth carrying into that phone call. Citizens Information’s page on paying electricity bills currently tells readers they are a priority service customer “if you register with the CRU”. You do not register with the CRU. You register with your supplier, who maintains the register and passes it to the network operator. And suppliers must make at least four attempts to contact a customer before disconnecting, so a single unopened letter is not the end of the road.

If you are the family member

Most of the people who should be on these registers will not read an article about energy regulation. The adult children, nieces, nephews and neighbours who help with the paperwork are the ones who can close this gap, which is what the nominated representative mechanism is for. A reasonable winter checklist for a parent’s house: register them in the right category, add a nominated representative, check what tariff they are actually on, check whether there is a prepayment meter and whether it should still be there, and, if there is powered medical equipment in the house, ask the supplier about the solar scheme. While you are at it, our guides to cold homes and winter grants and carbon monoxide safety cover the rest of the heating season.

At Críonna Health we keep running into the same shape of problem. The entitlement exists, it is well drafted, it is genuinely protective, and it is switched off by default. A register that depends on self-registration will always be fullest among the people who read regulatory decisions and emptiest among the people the regulation was written for. Until that changes, the protection is only as good as the phone call somebody makes on a person’s behalf.

The woman with the oxygen concentrator was right that she should never be cut off. She was wrong about who had to say so.

This article is general information, not individual medical, legal or financial advice. Scheme rules and dates change: confirm current details with your energy supplier, the CRU at cru.ie, or Citizens Information.

📷 Photo by Stefan Szankowski on Unsplash