1. Consultation Response
Question 1
Do you agree with the Committee’s initial view that MOD032 would better facilitate the achievement of the Scheme Objectives and should be approved? Please give your reasons below. You can find the Heat Trust Scheme Objectives on the final page of this form.
Yes.
Consumer Scotland supported the Modification at Committee and it remains our position that the Modification will better facilitate the achievement of the Scheme Objectives, if approved.
The continuation of the Heat Trust Scheme until 26 January 2027 is necessary to mitigate the risks of gaps in consumer protections, given that Ofgem is still developing the exact detail and timings of its rules and activities that will apply during 2026. The Modification provides the operational flexibility for the Heat Trust to manage this uncertainty and to provide continuity to Registered Participants during the transitional period.
We also agree, as referenced in the Modification proposal, that the Heat Trust Scheme provides strong foundations upon which regulation will be built, and therefore that the extension of the Scheme to January 2027 will help Scheme participants be ‘regulation ready’.
The overall transitional arrangements as set out in the Modification represent clear benefits to consumers of Registered Participants, both in terms of ensuring the continuity of standards in the transitional period, and in creating the conditions for a smooth to transition to regulation.
For the same reasons, Consumer Scotland would support a mechanism which enables further extensions to the Scheme, in the event that Ofgem extends the authorisation window, or for delays to regulation for any other reason.
Question 2
Do you agree that the draft legal text delivers the intention of MOD032? Please give your reasons below. Please answer this question even if you don’t support MOD032, as it could still be approved.
Yes, we are satisfied that the draft legal text delivers the intention of the Modification.
Question 3
Do you agree with the proposed implementation date for the legal drafting of two working days after Board approval of MOD032 (so 19 September 2025 if approved at the 17 September Board meeting)? Please give your reasons below. Please answer this question even if you don’t support MOD032, as it could still be approved.
Yes, we agree with the implementation date as proposed.
Question 4
Do you have any other comments about MOD032?
No.