Draft Work Programme 2025-2026

Delivering change for consumers in Scotland

We are all consumers

We are all consumers – purchasers or users of goods and services – in a wide variety of services and markets.

Being a consumer is not only about when we go shopping to buy physical things. It is also when we use private and publicly provided services. Passengers, tenants, internet users, energy users, students and patients are all consumers. People may not label themselves as a consumer in these contexts. But the benefit of taking a consumer approach is that it helps to recognise that, when people use goods and services, they are in a particular kind of relationship with those who provide these to them.

For policymakers, understanding and acting on the consumer perspective is essential to a thriving society and economy. Consumer analysis tells us how well markets and services are working for those who use them. It highlights the barriers faced by those who are excluded from these markets and services. And it can identify what needs to change to meet the needs of consumers of the future.

The role of Consumer Scotland

Consumer Scotland is the statutory, independent body for consumers in Scotland, accountable to the Scottish Parliament.

Established in 2022, Consumer Scotland is now in our third full year of operation. Our purpose, as set out in our first Strategic Plan for 2023-2027, is to improve outcomes for current and future consumers in Scotland. It is our ambition that every consumer in Scotland can participate in a fair and sustainable economy, confident their needs and aspirations will be met.

Our work is underpinned by robust data, research and analysis on the issues that matter to consumers in Scotland. Using our continually evolving evidence base, we provide government, regulators, businesses and the wider consumer landscape with insight, advice and recommendations on the actions that are required from them to achieve positive outcomes for consumers.

The internationally recognised consumer principles, which set out what good consumer outcomes look like for any given market or service, provide the framework for our policy and advocacy representations on behalf of consumers.

These principles are:

• Access: Can people get the goods or services they need or want?
• Choice: Is there any?
• Safety: Are the goods or services dangerous to health or welfare?
• Information: Is it available, accurate and useful?
• Fairness: Are some or all consumers unfairly discriminated against?
• Representation: Do consumers have a say in how goods or services are provided?
• Redress: If things go wrong, is there a system for making things right?

Consumer Scotland has a remit to work across the economy, including the public, private and third sectors. We are the levy-funded advocacy body for the electricity, gas, heat network, post and water sectors in Scotland. Our Draft Work Programme sets out our plans for 2025-2026 in these particular markets, as well as within the wider economy.

Our Strategic Plan sets out three cross-cutting consumer challenges which also inform the work of our Draft Work Programme. These are:

• Improving the affordability of goods and services
• Taking action that supports consumers to mitigate and adapt to the effects of climate change
• Addressing the issues that matter most to consumers in vulnerable circumstances

As the statutory consumer body, Consumer Scotland has an important leadership role in Scotland’s consumer landscape. Our Draft Work Programme sets out how we will play this role across our range of activities, including providing grant funding for consumer advice, information and advocacy activity to other organisations. We will convene and coordinate action across the consumer landscape to promote collaboration and partnership working that delivers positive outcomes for consumers.

Our work in the past year

Over the past 12 months Consumer Scotland has developed significant momentum across the wide range of activities that we are delivering to help achieve better outcomes for consumers in Scotland.

We provide a brief overview here of some of our most significant work.

Publishing new evidence and insights

Providing evidence and insights to inform policymakers on the issues that matter to consumers is a core part of Consumer Scotland’s role.

During the past year we have published a wide range of reports, briefings and analysis across multiple markets, delivering new evidence and recommendations to help inform the decisions of governments and regulators. Our publications have covered issues including:

• The outlook for consumers in Scotland in 2024-2025
• Consumers’ perceptions of and engagement with the transition to Net Zero
• How to design energy support to benefit disabled consumers
• The causes and impact of energy debt
• The effectiveness of the National Concessionary Travel schemes
• The consumer challenges in the private and social rented housing sectors
• Water poverty and the affordability of water and sewerage charges
• Dynamic pricing in Scotland
• Consumer detriment, with a focus on housing, telecommunications and finance
• The consumer experience of Electric Vehicles
• Decarbonisation of the postal service (forthcoming)
• The consumer experience of installing heat pumps and/or solar PV technologies (forthcoming)
• The experiences of small businesses in Scotland as consumers (forthcoming)
• The experiences of disabled consumers living in rural and remote Scotland (forthcoming)

Advocating for changes to legislation

We have engaged directly with a number of pieces of proposed legislation that will have significant impacts for consumers in Scotland. We have provided written and oral evidence and published briefings to advocate for consumers’ interests in key Bills as these have passed through the legislative process. This includes:

• The Housing Bill
• The Heat in Buildings Bill
• The Regulation of Legal Services Bill
• The Climate Change Targets Bill
• The Circular Economy Act
• The Digital Markets, Competition and Consumers Act

Advocating for public policy changes

We have engaged with governments, regulators and other policy makers to advocate on behalf of consumers in a wide array of policy development processes. This includes:

• Representing consumers in the development of new policy proposals and legislation that will enable the water sector in Scotland to respond more effectively to the challenges of climate change
• Producing new recommendations to inform the development of more effective systems to improve the affordability of energy bills for consumers in Scotland
• Leading stakeholders in the non-domestic water sector to create the first ever code of practice for suppliers in the market, to improve the services delivered to consumers
• Working with consumer bodies in England and Wales and in Northern Ireland to propose new solutions to government and industry which will tackle the problem of ‘post exclusion’ for consumers with no fixed address
• Advocating on behalf of consumers for improvements to be made to the complaints systems of parcel operators across the UK
• Putting forward the consumer perspective to inform regulatory decisions across a wide variety of issues, including access to cash, energy standing charges, unregulated legal services, trader recommendation platforms, digital subscriptions and media literacy

Influencing investment decisions

Governments, regulators and businesses in a number of essential consumer markets face challenging decisions in the coming years about how to sustain key infrastructure, and the extent to which consumers can be asked to meet the costs of the required investments through increased bills or changes to service specifications. We are providing evidence, insight and recommendations across a number of these decision-making processes, including:

• The Strategic Review of Water Charges for 2027-2033, for which we have agreed a Memorandum of Understanding with Scottish Water and the Water Industry Commission for Scotland to put consumer evidence at the heart of the process
• A review of the future of the universal post service
• The economic regulation of large scale new build nuclear power in Great Britain

We have entered into a new Memorandum of Understanding on cooperation with the National Electricity System Operator (NESO) aiming to create positive outcomes during the transition to an energy system to support Net Zero.

Speaking up for consumers to prevent harm

We have undertaken a number of activities that respond directly to problems that consumers are experiencing in different markets which require urgent attention. This includes:

• Launching our first Consumer Scotland investigation, which is examining consumer protections in the green home heating market. Our investigation report will be published early in 2025
• Entering into a new partnership with the Office of Product Safety Standards (OPSS) to enhance the effectiveness of the OPSS recall of goods database for consumers in Scotland
• Recommending actions by governments, regulators and telecoms providers to mitigate the risks to consumers in Scotland posed by the migration to digital landline phones (VOIP)
• Convening energy advice agencies and the regulator to press for action to reduce the serious risks to consumers in Scotland posed by the pending switch off of RTS meters, which will have particular implications for rural energy consumers
• Engaging with the Scottish Government, regulators and complaints bodies to seek resolutions to the significant challenges being experienced by former clients of McClures, a Scottish law firm which collapsed in 2021

Building our evidence base

We have worked in partnership with the Competition and Markets Authority to support the Consumer Protection Survey 2024. Our input is securing an increased number of participants in Scotland in the survey, which will improve the value and robustness of the data for stakeholders in Scotland.

We have established new framework contracts with external research partners to support our quantitative and qualitative research. These new arrangements significantly enhance our ability to commission robust, timely consumer research evidence across a range of topics.

Our Consumers in Vulnerable Circumstances Advisory Committee includes representation from charities, advice bodies, companies and academic institutions in Scotland. With their support we have put in place a number of measures to underpin our approach to building our evidence base on the experiences of consumers in vulnerable circumstances. This includes a statement of our approach, an ethical approvals process for research, and research principles for carrying out work in this area to embed the voice of lived experience in our work. 

Influencing the public sector

We have published draft guidance to public authorities in Scotland on the Consumer Duty, supporting public bodies to take account of consumers in their strategic decisions. The final version of the guidance will be published in February following a public consultation on the draft guidance. We have provided information sessions for consumer groups and small businesses on how they can use the duty to influence decision-making within the public sector.

The refreshed National Outcomes for Scotland, published in May by the Scottish Government, includes reference to consumers for the first time. Specifically, the new National Outcome for Wellbeing Economy and Fair Work includes a new focus on “supported, empowered, confident consumers”. This change follows on from previous Consumer Scotland engagement with the refresh process for the National Performance Framework.

Leading the consumer landscape

As the statutory consumer body in Scotland we regularly convene stakeholders from across the consumer landscape to consider issues of importance to consumers and identify new solutions to these challenges.

We convene:

• A newly-established Leadership Group, bringing together the Chief Executives from the key consumer advocacy, advice and enforcement organisations in Scotland
• The Consumer Network for Scotland, which brings together UK economic regulators, advice bodies, enforcement agencies, governments and complaints bodies in Scotland to consider cross-market issues affecting consumers and actions that can be taken to address these
• The Energy Consumers Network, which brings together frontline energy advice agencies in Scotland to examine key consumer issues in the energy market, share knowledge and learning, and identify changes required from government, regulators or suppliers

We also represent consumers in Scotland on a wide range of externally-run working groups, forums and networks. These include the UK Consumer Protection Partnership, the BSI Consumer Forum, the Scottish Government’s Regulatory Review Group and the First Minister’s Scottish Energy Advisory Board.

During this year we have been leading the development of Scotland’s new consumer advocacy and advice system for heat networks, in preparation for new regulations commencing in this market. We are working with Advice Direct Scotland and Citizens Advice Scotland on establishing the advice aspects of the new system.

The outlook for consumers in Scotland

Overview

Recent years have presented many challenges for consumers in Scotland.

As we enter 2025, inflation has fallen from its highs of 2022 and 2023, but it leaves a legacy of higher prices and concerns about consumer debt. In many markets consumers have a high degree of choice but they can be exposed to risks, including poor quality goods and services and a lack of transparency around prices and terms. New products and technologies are creating new opportunities to deliver good consumer outcomes – but these changes also bring risks for consumers when policy, legislation, regulation, information, advice and redress lag behind market development.

The big challenges facing consumers

In September 2024 Consumer Scotland published our Consumer Outlook report in which we set out the big issues facing consumers in Scotland today and in the future. We considered the scale and significance of those issues, and identified the consumer-related policy questions that these issues give rise to.

In our Outlook report, we highlighted a broad range of issues that currently affect the wellbeing of consumers in Scotland and their experience of engaging with different markets and services. These include:

• Price changes during the cost-of-living crisis have driven changes in patterns of consumer spending and consumption, particularly in relation to essential goods and services. People are now spending more on some essentials but are getting less in return. Spending on food and drink across UK consumers for example, increased 17% between the first quarter of 2021 and the first quarter of 2024, but consumption fell by 10%.
• A troubling impact of price inflation during the cost-of-living crisis has been a rise in the number of consumers falling into arrears to their utilities providers. The average amount of arrears for indebted GB household gas accounts almost doubled between 2021 and 2024 for example, whilst around 9% of Scottish households were in energy debt in winter 2024.
• Around ten percent of Scottish households are in ‘water poverty’ in 2024-2025. This is slightly below typical historic rates, as a result of below inflationary increases in the water charge during the cost of living period. But there is a consequence in terms of lower revenues and potentially lower investment in water and sewerage infrastructure – which means that difficult decisions about prices will now have to be taken in the coming years.
• Consumer detriment – problems associated with buying or using goods and services which cause consumers stress, cost them money and take up their time – is widespread in Scotland. The majority (72%) of consumers in Scotland experienced at least one incidence of detriment between April 2020 and April 2021. Detriment incidents problems resulted in a ‘net monetised cost’ to consumers in Scotland of £4.7 billion.
• Poor customer service and complaints handling can create and exacerbate detriment. For example, consumers’ dissatisfaction with how complaints are handled is common in telecoms services. In financial services, consumers have found that being unable to reach their provider is the biggest ongoing cause of detriment.
• Consumers are more likely to experience detriment when purchasing goods, services and subscriptions online. Practices such as drip-pricing, dynamic-pricing, subscription traps and fake reviews risk causing detriment to consumers.
• Governments’ commitments to reach Net Zero have major implications for consumers. The Committee on Climate Change (CCC) has estimated that over 60% of the required emissions reductions to meet Net Zero will be “predicated on some kind of individual or societal behavioural change”.
• The majority of consumers (around three quarters) in Scotland are concerned about climate change. However, they are often unsure what they can do to support the transition to Net Zero. They would like to see more leadership from governments, regulators and business, who they regard as having the greatest responsibility for reducing emissions.
• Policy aspirations to decarbonise homes and transition away from petrol and diesel cars in favour of electric vehicles have the potential to bring benefits to consumers and wider society, but also bring significant risks and potential costs for consumers. For example, home charging for electric vehicles is associated with cheaper costs and higher convenience, but around half of all households in Scotland live in circumstances where charging at home is not likely to be an option. This situation risks seriously curtailing the uptake and use of EVs, and creating inequalities in the use of this technology, unless substantial enhancements to the public charging network are made.

These challenges are faced to varying extents by all consumers. But some consumers are at greater risk of harm than others. Consumers in vulnerable circumstances[1] are more exposed to the impacts of price changes and are at greater risk of experiencing detriment, partly as a result of less choice and reduced accessibility.

The public policy response

A proactive set of policy responses to these issues is required in Scotland. Governments, regulators, businesses and other policy makers need to create and maintain a framework to support consumers in Scotland to navigate complex markets, tackle and reduce the risks of consumer harm and unfair outcomes, and boost consumer confidence.

Particular policy challenges, which require action in Scotland in the year ahead, include:

• Designing tariff structures – and targeted affordability support – for essential services and markets in order that the substantial investment requirements to sustain or grow those services and markets is shared fairly across consumers
• Enhancing – often at pace – regulation and enforcement in relation to new products, platforms and services to protect consumers from the risks of new harms as they emerge
• Ensuring consumers have access to high quality information and advice to enable them to engage confidently in markets
• Playing a more proactive leadership role in enabling consumers to be able to play an active part in the transition to a Net Zero society, through a mixture of advice and information, financial incentives, market stimulation, protection against harm and access to redress

These are vital challenges for the wellbeing of Scotland’s economy and society. How policy makers identify the most appropriate responses to these issues is important. These matters often require difficult choices and trade-offs about where to prioritise investment and which groups of consumers to support. It is essential that the voice of consumers is central to finding the answers.

Consumer Scotland is looking forward to playing our part to contribute to this vital work. Our Draft Work Programme sets out where we will concentrate our efforts to do so during 2025-2026.

Our overarching outcomes

Consumer Scotland’s work in 2025-2026 will focus on four overarching outcomes for consumers:

• Fair and Affordable Markets: markets are fair and affordable for all consumers, including those in vulnerable circumstances
• Investing for the Future: investment decisions to develop or renew essential markets or infrastructure are based on consumers’ priorities and needs
• Trustworthy, High Quality Products and Services: the services that consumers use can be trusted to deliver what consumers value and expect and, protect them from harm
• Consumers at the Heart of Scotland’s Economy and Society: consumers are recognised as being central to achieving a flourishing Scotland, through increased wellbeing and sustainable and inclusive economic growth

Under each of these overarching outcomes we will deliver a series of workstreams, each with their own specific outcome. A summary of each overarching outcome and its associated workstreams is set out below:

1. Fair and Affordable Markets

Markets are fair and affordable for all consumers, including those in vulnerable circumstances.

Specific workstreams we will deliver in this area in 2025-2026 are as follows:

• A new approach to energy affordability
• A future energy retail market designed for consumers
• Fair and affordable water charges
• A fairer housing rental market
• Markets that deliver for small businesses
• Securing a universal postal service that delivers for consumers in Scotland
• Equitable postal services for Scotland’s islands

2. Investing for the Future

Investment decisions to develop or renew essential markets or infrastructure are based on consumers priorities and needs.

Specific workstreams we will deliver in this area in 2025-2026 are as follows:

• Electric Vehicle infrastructure that works for all consumers
• A strategic water investment programme shaped by consumers
• Consumers at the centre of a climate resilient water sector
• A circular economy for consumers
• Postal Service 2040: Designing a consumer-centred future service
• A heat network market that works for consumers

3. Trustworthy, High Quality Products and Services

The services that consumers use can be trusted to deliver what consumers value and expect and protect them from harm

Specific workstreams we will deliver in this area in 2025-2026 are as follows:

• An energy efficiency system that delivers for consumers
• An improved system for preventing and dealing with water debt
• A water market that works for non-domestic consumers
• Decarbonised postal markets that deliver for consumers
• Public transport options that consumers want to choose
• Improved protection for consumers from product harm

4. Consumers at the Heart of Scotland's Economy and Society

Consumers are recognised as being central to achieving a flourishing Scotland, through increased wellbeing and sustainable and inclusive economic growth.

Specific workstreams we will deliver in this area in 2025-2026 are as follows:

• Public bodies delivering for consumers
• Consumer insights driving decision-making
• A cross-market approach to delivering more affordable essential services

Our strategic approach to change

Consumer Scotland’s Performance Framework includes our Strategic Theory of Change, which describes our approach to delivering improved consumer outcomes.

For each of the workstreams in our Draft Work Programme we have set out a specific theory of change, based an abbreviated version of on our strategic model. For each of these workstreams we describe:

• The problem or opportunity we are seeking to address
• What we will do and who we will work with
• What we want to be done differently as a result
• The impact this would have for consumers

As an advocacy organisation, the outcomes that Consumer Scotland is pursuing on behalf of consumers will require positive responses by governments, regulators, businesses and service providers if progress is to be achieved. Many areas will require substantial responses and ambitious, long-term action to deliver positive, sustainable improvements for consumers.

The complex nature of these issues means that many of the outcomes that we have set out in this Draft Work Programme are likely to take a number of years to achieve. Our Draft Work Programme describes the activities that Consumer Scotland will undertake to help deliver progress towards the desired outcomes during 2025-2026.

These activities will include:

• the ongoing development of our high quality evidence base;
• rigorous analysis;
• the application of market and policy expertise;
• the provision of clear, tangible recommendations;
• and leadership and coordination across the consumer landscape.

In undertaking these activities we recognise that delivering improved consumer outcomes requires input from many different stakeholders. Building on the significant stakeholder engagement we have undertaken since we were established, we will continue to work with national and local governments, regulators, other public bodies, businesses, service providers, enforcement bodies, advice agencies, representative bodies and charities to deliver good outcomes for consumers.

In delivering our plan we will remain alert to emerging issues that impact on the wellbeing of consumers during the next year. In some cases, we may need to adapt our plans to respond appropriately to these issues. We will use our prioritisation process to help support us in taking such decisions.

Alongside the priority workstreams described above, Consumer Scotland will also undertake a range of supporting work in 2025-2026 to represent the interests of consumers across markets and services.

The world that consumers engage in can change and evolve rapidly. We have identified a number of areas that we anticipate giving attention in future years due to their importance to consumers. We will also spend time in 2025-2026 scoping a small number of these potential areas of activity further.

Details of our supporting and scoping work for 2025-2026 are provided below.

Supporting Work

Market area: Cross-Market

Project title: Consumers and Net Zero

Project description: We will continue to use the findings from our research to advocate for the needs and priorities of consumers in the transition to Net Zero. We will seek to ensure that the upcoming Climate Change Plan fully considers both current and future consumers.

Project title: Fairer markets

Project description: We will publish a report on the experiences of disabled consumers in rural areas following the conclusion of our 2024-2025 research on this issue and undertake dissemination and advocacy activity to support this work. We will explore potential research gaps across topics affecting consumers in vulnerable circumstances.

Project title: Regulations that deliver positive consumer outcomes

Project description: We will engage with issues outside of priority workstreams that are ad hoc, require rapid response, or provide opportunities for us to use the existing  evidence base to advocate for consumers. This may include work on issues previously explored. It also includes delivering input on development of regulatory measures and engaging with stakeholders both bilaterally and through working groups, including the Regulatory Review Group, Consumer Protection Partnership, and Communications Consumer Panel stakeholder and advocacy hubs.

Project title: A consumer-centred system for legal services

Project description: We will continue our advocacy activity on the Regulation of Legal Services Bill as it progresses through Parliament, representing consumers’ interests in the design of this legislation. We will continue our membership of the Scottish Legal Complaints Commission Consumer Panel and seek opportunities to use our existing research and stakeholder knowledge to advocate for better consumer outcomes, including input into any implementation work arising from the Bill.

Market area: Energy

Project title: Energy tracker survey

Project description: We record and analyse consumer experience of energy markets through our energy tracker, with a controlled sample representative of the population of Scotland. We will continue to run the tracker annually to add to our understanding of changing consumer experience over time.

Project title: Stakeholder engagement

Project description: We will contribute to a wide range of both regular and ad hoc meetings and delivery groups with Scottish and UK Governments, the regulator, consumer advice stakeholders and industry partners, to represent consumer interests. We will continue to participate in key stakeholder forums.

Project title: Responsive retail market engagement

Project description: We will contribute evidence and insights to key consultations and calls for information in the energy retail market, from government, parliament and the regulator, as these emerge during the year.

Project title: Metering

Project description: Ahead of the Radio Teleswitch Service (RTS) switch-off in June 2025, we will continue to play a role in facilitating action and disseminating information across key stakeholders in the sector, including through our participation in the Ofgem RTS working group.

Project title: Markets and systems

Project description: We will engage with a range of processes to represent consumers’ interests in proposed changes to energy markets and systems.

This will include ongoing engagement with the Review of Electricity Market Arrangements (REMA); gas and electricity network price controls; and working with the NESO in strategic partnership.

Market area: Post

Project title: Tackling post exclusion

Project description: We will continue to work with Royal Mail, Post Office Ltd, UK Government and other consumer bodies to identify and implement solutions to post exclusion for those consumers with no fixed address.

Project title: Post Offices

Project description: We will monitor the data provided to us by Post Office Ltd on the post office network, including location, type of branch and business mix. We will publish a report with our analysis of the audited Post Office data and our assessment of its implications for consumers.
We will also engage with the expected UK Government Green Paper on the future of the post office network.

Market area: Research and Analysis

Project title: Strengthening the evidence base

Project description: We will continue to work to improve the quality and quantity of evidence available to Consumer Scotland and stakeholders. This includes our ongoing participation in the ScotStat Board, the operation of our framework agreements which support Consumer Scotland’s survey research and research with consumers in vulnerable circumstances, and working with partners to access and understand their data to ensure a holistic picture of the consumer experience is available.

Market area: Water

Project title: High-Level Group and Strategy Group

Project description: We will continue to represent consumers’ interests in key strategic groups in Scotland’s water sector, including the High-Level Group and the Strategy Group.

Project title: Future Investment Group

Project description: We will work with key water sector stakeholders to provide advice to the Scottish Government that will help shape the Ministerial Objectives for 2027-33.

Project title: Future Charging Group

Project description: We will work with key water sector stakeholders to provide advice to the Scottish Government that will help shape the Principles of Charging for 2027-33.

Project title: Private Water Supplies connections project

Project description: We will support the Scottish Government to test connection of communities on private supplies to the water mains and how this may be achieved.

Project title: Understanding the consumer experience

Project description: Building on our work on consumer complaints in 2024-2025, we will continue to develop our approach to mapping data and evidence on the consumer experience of Scotland’s water sector. We will continue to examine existing data to identify key issues, gaps and emerging trends across the range of issues that matter to consumers. We will engage with key water stakeholders to help identify actions emerging from this work that can help to drive consumer improvements.

Scoping Projects

Market area: Cross-Market

Project title: Improving pathways to redress

Project description: We will undertake scoping work to identify and assess the key issues affecting consumers in Scotland who seek to resolve issues with goods and services. This may include analysis of advice data, mapping of consumer journeys, and stakeholder workshops. We may consider more informal routes to redress such as signposting and advice, support from trade bodies and ADR providers as well as more formal legal routes such as the use of simple procedure.

Market area: Consumer Markets

Project title: Current issues affecting consumers of financial services

Project description: We will conduct scoping work examining the experiences of consumers in Scotland who access financial services, disaggregating findings from the wider UK experience where possible. This will inform future areas of work and allow us to advocate for improved outcomes for consumers in Scotland.

Market area: Energy

Project title: Reducing household electricity costs through technology

Project description: There is emerging evidence that combinations of solar PV, domestic storage batteries and ‘time and type of use’ tariffs can reduce electricity costs for consumers but further data is required on full potential and impact of these. During 2025-2026 Consumer Scotland will consider opportunities to undertake exploratory work and analysis to consider scenarios for different household types and electricity use patterns. 

Project title: Local energy strategic planning

Project description: We will develop a programme of work to build understanding of, and support for, the role of local strategic energy planning in supporting communities to engage with an benefit from the transition to an energy system to support Net Zero. In 2025-2026 we will review local area energy planning and policy in Scotland, and compare the experience in Scotland with the approaches taken in other GB nations and regions.

Market area: Heat Networks

Project title: Understanding consumer experiences of pre-payment meters (PPM) for heat networks

Project description: We will carry out research exploring heat network consumers’ experiences of pre-payment meters. This will build on our understanding of PPMs from the gas and electricity market. This research will help us to understand what consumers think about PPMs, which are increasingly being installed by default on heat networks. This will help us to develop a set of clear recommendations on the use of PPM for heat networks which will support us to advocate effectively on this issue as the rollout for heat networks ramps up.

As the statutory consumer body, an important aspect of Consumer Scotland’s role is to provide leadership across Scotland’s consumer landscape.

We work in close partnership with other consumer organisations in Scotland to fulfil this role, recognising the unique roles, contributions and strengths that each organisation has to play.

Convening the consumer landscape

We will continue our work in 2025-2026 to convene the consumer landscape in Scotland through shared forums and networks, to develop joined up approaches and deliver outputs and activities that help to improve outcomes for consumers.

Our work will include activity on scams prevention and awareness and we will work with partners to advance this issue during 2025-26. 
As described above, the key groups that Consumer Scotland will continue to lead in 2025-2026 will include:

• The Chief Executives Consumer Leadership Group
• The Consumer Network for Scotland
• The Energy Consumers Network, which also serves as a Strategic Leadership Group of the First Minister’s Scottish Energy Advisory Board

Investigations to reduce harms and build consumer confidence

Through our landscape partners, we gain critical evidence and insights into the factors that damage consumer confidence or negatively impact their interests. Over the next year, we will focus on deepening these collaborative relationships, expanding our evidence base, and launching targeted investigations into the sectors or practices that cause the greatest harm to consumers in Scotland.

Putting consumers at the centre of Scotland’s approach to climate change

A focus on the role of consumers in climate change adaptation and mitigation is one of Consumer Scotland’s strategic priorities for 2023-2027. During the past two years we have produced a wide ranging body of evidence on this issue, across several consumer markets. From this work, we have built a clear set of principles to inform future legislative, regulatory and policy interventions, providing an overarching framework for such interventions to respond to consumer priorities and needs. We will continue our work in 2025-2026 to build a clear, public consumer narrative on this issue, working with stakeholders from across the consumer landscape, government, regulators and industry.

Strategic funding partnerships

Consumer Scotland will engage in a number of strategic partnerships in 2025-2026 to support the delivery of a range of activities that will deliver benefits to consumers in Scotland.

Details of these partnerships are provided below.

2025-2026 Strategic funding partnerships

Activity Area: Consumer Advocacy 

Name of partnership organisation: Citizens Advice Scotland

Partnership description: Consumer Scotland will administer the Citizens Advice Scotland consumer advocacy grant in 2025-2026. This funding relationship allows us to set the strategic direction for CAS’ operational delivery and ensure that the work of both organisations is streamlined and value for money.

Name of partnership organisation: Citizens Advice (England and Wales)

Partnership description: Consumer Scotland will administer the Scottish element of GB-wide consumer advocacy activity in gas, electricity and postal sectors that is delivered by Citizens Advice. We will work in close partnership with Citizens Advice to achieve effective alignment, complementarity and value for money in the delivery of this work.

Activity Area: Consumer Advice

Name of partnership organisation: Advice Direct Scotland

Partnership description: Consumer Scotland will administer the Consumeradvice.scot grant to Advice Direct Scotland in 2025-2026. This partnership will allow us to better align our strategic advocacy with the delivery of advice services 

Activity Area: Big Energy Savings Network and Worried this Winter Campaign

Name of partnership organisation: Citizens Advice Scotland

Partnership description: We will continue to work in partnership with Citizens Advice Scotland to enable the delivery of the Big Energy Savings Network (BESN) project and the Worried This Winter campaign. Both programmes are delivered in communities across Scotland by Citizens Advice Bureaux and other third-sector partners. Advisers funded through the project provide group sessions and one to one energy advice to consumers. They also provide group sessions to frontline workers so they can give direct help and advice to consumers to help them stay warm and lower their energy bills while maximising their incomes.  

The Worried This Winter campaign raises awareness of the support available to anyone worried about the rising cost of energy and keeping their homes warm during the coldest months of the year.

Activity Area: Heat Networks - Tier 1 Advice

Name of partnership organisation: Advice Direct Scotland 

Partnership description: Consumer Scotland will enter into a partnership agreement with Advice Direct Scotland for ADS to deliver Tier 1 consumer advice on heat networks in Scotland from 2025-2026.

Activity Area: Heat Networks - Tier 2 Advice

Name of partnership organisation: Citizens Advice Scotland (Extra Help Unit)

Partnership description: Consumer Scotland will enter into a partnership agreement with Citizens Advice Scotland for the EHU to deliver Tier 2 consumer advice on heat networks in Scotland from 2025-2026.

Governance

Consumer Scotland is a Non-Ministerial Office. We are independent of government, and we are directly accountable to the Scottish Parliament.

We lay our forward Work Programme and our Annual Report in Parliament and we give evidence on our performance at the Economy and Fair Work Committee. Our research reports and other outputs are provided to Parliamentary Committees, the Scottish Parliament Information Centre and the House of Commons Library.

Our relationship with the Scottish Government is governed through our Framework Agreement, setting out our respective roles and responsibilities. This is published on our website.

We have a five-person Board who govern the organisation and work with the Chief Executive and Accountable Office to provide scrutiny, challenge, advice and strategic direction. Our Audit and Risk Committee advises the Board and Accountable Officer on risk, control and governance and the annual report and accounts. Our Advisory Committee on Consumers in Vulnerable Circumstances, which is chaired by a Board member, provides advice to our senior team on our work in relation to consumers in vulnerable circumstances. The minutes from our Board and Committee meetings are published on our website.

Managing and Measuring our Performance

Managing our work and developing our team

Across our work programme we aim to dedicate the right mix of skills, resources and powers at our disposal to each of our areas of activity. We work in a multi-disciplinary way, drawing in appropriate expertise from across the organisation. As a relatively young organisation, we are continually exploring new approaches to share learning across our team and to help build our skills and expertise in order to help secure positive outcomes for consumers.

Working across multiple consumer markets gives us a unique perspective on consumer issues. We seek to draw on this cross-market learning and experience to strengthen our work, delivering greater value and impact for consumers.

The workstreams set out in our Draft Work Programme represent activities that vary in nature, in terms of their capacity, complexity and timescales. We seek to resource each activity appropriately, and we will make choices during the year about how to prioritise our work most effectively in order to maximise impact for consumers.

We will remain alert to issues affecting consumers that emerge or grow in importance during the year. We will respond to these issues where possible and appropriate, adapting our pre-planned work as required to deliver this work.

Measuring our impact

Our Performance Framework, published in 2023, sets out how we track our impact and performance. The Framework includes Organisational Activity Indicators; Outcome progress monitoring across our workstreams; a Recommendations Register; and Impact Reviews.

As an advocacy organisation, we understand that impact is generally not linear and involves the involvement of a range of stakeholders. We use contribution analysis to assess our role in helping to achieve positive change for consumers, reflecting the complexity of the markets and sectors in which we operate.

We report on our impact through our Annual Report and Accounts, which we lay before the Scottish Parliament, and which are subject to independent audit. In 2025-2026 Consumer Scotland will commission an independent review of our performance, which will consider our first three years of operation.

Our work contributes to the achievement of the National Outcomes in Scotland’s National Performance Framework. The active engagement of consumers in the economy and society helps to deliver each of the National Outcomes, which are further enhanced when policymakers put the interests of consumers at the centre of their decisions. We are pleased that the refreshed National Outcome on the Wellbeing Economy and Fair Work includes reference to consumers for the first time, following our work on this issue.

Our Communications

Communicating the evidence and our recommendations widely is a core part of our work. Our Communications Strategy sets out the objectives of our communications approach:

• Improve outcomes for consumers by extending the reach and impact of Consumer Scotland’s research, analysis and policy recommendations with key decision-makers
• Raise awareness of the key issues of importance to consumers in Scotland
• Increase awareness and understanding of Consumer Scotland and its remit
• Increase Consumer Scotland’s influence and demonstrate our positive impact on the lives of consumers across the range of markets we cover
• Strengthen relationships with stakeholders and develop collaborative working to maximise impact
• Raise awareness of where consumers can get access to the information they need
• Raise awareness of the consumer duty and how the relevant public bodies can meet the duty
• We keep stakeholders and consumers informed about our work, including our research and recommendations, through our website, social media, mailing list and mainstream media. In 2024 we launched the Consumer Scotland newsletter, which we will continue in 2025-2026. We will also continue this year to develop our communications approach, to continually extend our reach, recognition and reputation. This work strengthens our advocacy and ultimately helping to secure better outcomes for consumers. 

Public Service Reform

Consumer Scotland is committed to the public service reform agenda. We work closely with other public bodies across Scotland to maximise the efficiency of our operations and the effectiveness of our work.

We currently share premises in Edinburgh with Environmental Standards Scotland (ESS), based at the headquarters of the Scottish Legal Aid Board. In Glasgow, we share premises with the Registers of Scotland. Our co-location with ESS was a new arrangement in 2024-2025 and we aim to use this arrangement to identify efficiency savings in future years, and to support increased learning and sharing of expertise across the two organisations.

We continue to participate as active members of the Scottish Delivery Bodies Group, where we work with other public bodies to share experiences and work collaboratively on public sector reform opportunities.

Funding

Consumer Scotland receives general funding from the Scottish Government’s annual budget, which is approved by the Scottish Parliament. For 2025-2026 our proposed general resource funding is £3.525 million, which includes £950,000 to support the Citizens Advice Scotland Consumer Advocacy work plan. 

We also receive funding for research and advocacy activity in electricity, gas, heat networks, post and water sectors. This funding is provided via levies, which are derived from consumers’ bills and which are administered by the UK and Scottish Governments.

Our levy funding requirements for 2025-2026 are set out in the table below. This also includes funding for:

• Big Energy Savings (Worried this Winter), which is delivered by Citizens Advice Scotland
• The Scottish element of GB-wide consumer advocacy activity in gas, electricity and postal sectors, which is delivered by Citizens Advice

Consumer Scotland is committed to working effectively and efficiently to maximise the value of the investment in our work for consumers.

During 2025-2026 we will continue to build strong relationships with and work closely with stakeholders from across the consumer landscape in Scotland, England and Wales and Northern Ireland, to achieve positive outcomes for consumers, share learning and avoid duplication.

We operate in line with the Public Finance and Accountability (Scotland) Act 2000 and we follow the best practice guidance in the Scottish Public Finance Manual. Our accounts are externally audited, and this audit is commissioned by Audit Scotland. Our Annual Report and Accounts are laid before the Scottish Parliament.