UK Government consultation: Reforming Consumer Protection for Home Upgrade Schemes

Consumer Scotland is the statutory body for consumers in Scotland. Established by the Consumer Scotland Act 2020[1], we are accountable to the Scottish Parliament. The Act defines consumers as individuals and small businesses that purchase, use or receive in Scotland goods or services supplied by a business, profession, not for profit enterprise, or public body.

Our purpose is to improve outcomes for current and future consumers, and our strategic objectives are:

to enhance understanding and awareness of consumer issues by strengthening the evidence base

to serve the needs and aspirations of current and future consumers by inspiring and influencing the public, private and third sectors

to enable the active participation of consumers in a fairer economy by improving access to information and support

Consumer Scotland uses data, research and analysis to inform our work on the key issues facing consumers in Scotland. In conjunction with that evidence base we seek a consumer perspective through the application of the consumer principles of access, choice, safety, information, fairness, representation, sustainability and redress.

Consumer Scotland welcomes the opportunity to respond to this consultation on proposals to reform consumer protection for home upgrade schemes. We recognise the necessity to reform  the current system in order to improve oversight, accountability and ultimately drive better consumer outcomes. 

Government schemes play a critical role in supporting the deployment of low carbon technologies and home upgrades such as batteries, heat pumps and improved insulation. These schemes are essential to make warmer, more efficient homes, tackle fuel poverty and lower consumer energy bills. However, we are aware that there have been cases of poor-quality work and installations; and complex routes to redress when things go wrong, which have had a significant impact on consumer confidence in the sector.  Stronger protections for home upgrades will help to address these issues and raise the standard of work within the sector, creating better consumer journeys. 

Our response has been informed by our ongoing work on energy efficiency and the rollout of low carbon technologies in Scotland, including the recommendations of our 2025 investigation into the green home heating market.[2] Our investigation found that maintaining consumer confidence requires the sector to uphold high standards of quality assurance and consumer protection.

We have not responded to specific questions in the consultation but have instead commented more generally on the UK Government’s proposals, particularly where they will have an impact in Scotland.  

Consumer Scotland is supportive of the proposals set out in the consultation and we would be happy to discuss these proposals further.

A centralised oversight system for government-supported retrofit schemes

Proposal 2. A new integrated consumer protection service for government-supported home upgrades, covering advice, quality assurance, case management, remediation and redress, under DESNZ oversight and potentially delegated to the Warm Homes Agency, subject to final approvals.

The introduction of a fully integrated service which covers consumer advice, quality assurance, case management, remediation and redress, for new and existing government retrofit schemes would be a welcome measure. We would welcome further detail on how the proposed service might interact with existing GB wide quality standards schemes such as the Microgeneration Certification Scheme (MCS) and Scotland specific programmes such as the Home Energy Scotland (HES) Grant and Loan scheme. Consumer Scotland would encourage close collaboration between UK and Scottish Governments to ensure that the development of the proposed service can learn from the significant experience of the Scottish Government’s Home Energy Scotland advice service which is delivered by the Energy Saving Trust. It will also help to ensure that the proposed service works effectively across GB and complement existing schemes in the devolved nations.

Proposal 3. Stronger binding agreements across the system to enforce delivery obligations and improve accountability for service quality, consumer experience and outcomes.

The introduction of stronger binding agreements across the delivery chain where these improve accountability for consumer outcomes is a welcome measure. Consumers often interact with multiple organisations throughout the retrofit journey, including advice providers, installers, certification bodies and scheme administrators. Without clear responsibilities, accountability can become fragmented, making it more difficult for consumers to understand who is responsible when problems arise. Stronger agreements can help ensure consistent standards of service delivery, quality assurance, complaints handling and remediation across the system.

It is important that these agreements focus not only on compliance with technical requirements, but also on the delivery of positive consumer outcomes. Performance expectations should include measures relating to consumer satisfaction, complaint resolution and remediation timescales, alongside appropriate support for consumers in vulnerable circumstances. Given the interaction between UK Government and devolved programmes, close collaboration with the Scottish Government and delivery partners will also be necessary to promote consistency of consumer protections and support a coherent consumer experience across Great Britain.

Proposal 4. A government-owned data system to bring together information from multiple sources, support earlier identification of systemic risks, and improve oversight, audit targeting and performance management.

The proposal to establish a new government-owned data system that brings together information from multiple sources to support oversight, audit targeting and performance management is a welcome measure. Where consumer harm occurs, it is often the result of issues that are repeated across multiple installations, installers or schemes[3]. A centralised data system could help identify these patterns at an earlier stage, enabling intervention before consumer detriment becomes widespread and supporting more targeted regulatory and enforcement activity.

Improved data sharing could also play an important role in tackling poor quality installations and identifying rogue traders operating across multiple schemes or geographical areas. By bringing together information from audits, complaints, quality assurance processes and redress mechanisms, the proposed system could support a more comprehensive understanding of market performance and strengthen the ability of delivery bodies to identify emerging risks.

Simplifying and improving the consumer journey for retrofit projects

Proposal 5. A simpler and more accessible consumer journey from first enquiry to installation and, where needed, remediation and redress, with the needs of vulnerable consumers guiding design.

Simplifying the retrofit journey will be critical to increasing consumer participation in home upgrade schemes and building the trust and confidence needed for the successful delivery of the Warm Homes Plan[4]. Consumers are often required to engage with multiple organisations throughout the customer journey, including advice providers, installers, certification schemes, quality assurance providers and redress bodies. This complexity can create barriers to participation, reduce consumer confidence and make it harder for consumers to understand where to go for support when problems arise.

Consumer Scotland supports this proposal. A simpler, more accessible and consumer-centred journey, supported by independent advice, clear accountability and effective redress arrangements, has the potential to increase participation, improve consumer outcomes and build the confidence required to accelerate the adoption of home energy improvements across Great Britain.

Proposal 6. Access to impartial advice and information, including stronger signposting to approved installers and retrofit professionals.

Independent and impartial advice has been an essential component of the Scottish Government’s Home Energy Scotland programme, delivered by the Energy Saving Trust. The Home Energy Scotland service provides consumers with practical advice on how to improve energy efficiency, the options for installing renewable technologies and the funding and support available to support any improvements.[5] We would encourage UK Government to engage with the Scottish Government and Energy Saving Trust, and it’s relevant delivery partners, to ensure that it can learn from the experience and delivery of this of the service already operating in Scotland. Consumer Scotland’s own qualitative research looking at the consumer experience of installing low carbon technologies found that consumers valued the information and advice available through HES and that it made the decision to install low carbon technologies much easier.[6][7] Consumer Scotland is also commissioning further qualitative research to understand consumer engagement with energy efficiency advice and we would be happy to share this with the department to support its work.[8] Consumer Scotland’s ongoing work on net zero and the energy transition has identified the key issues and considerations when consumers make decisions: confidence, clarity, cost and convenience.[9] Access to trusted information and advice is often one of the first ways that these barriers can be overcome.

Strengthening technical and professional frameworks

Consumer Scotland is generally supportive of proposals to strengthen professional responsibilities, competence requirements, certification oversight and quality expectations across the retrofit market. However, our principal interest is not the operation of professional frameworks in themselves, but whether they deliver improved consumer outcomes and stronger consumer protections. The introduction of stronger technical and professional frameworks should be accompanied by clear monitoring arrangements which focus not only on compliance but assess the extent to which these stronger arrangements are delivering positive consumer outcomes.

Proposal 7. Clearer expectations of retrofit professional responsibilities and stronger arrangements to assure competence for both individuals and organisations.

Consumers should have confidence that individuals and organisations participating in publicly supported retrofit schemes possess the necessary skills, knowledge and competencies to undertake work safely and effectively. Clear professional responsibilities can help ensure accountability throughout the retrofit process, reducing ambiguity about who is responsible when problems arise and supporting a more straightforward route to remediation and redress.

Strengthened professional frameworks form part of a broader consumer protection ecosystem that includes independent advice, effective quality assurance, strong monitoring and enforcement arrangements, accessible complaints handling and straightforward routes to remediation and redress. These components are mutually reinforcing and are most likely to build consumer confidence when operating as an integrated system.

Proposal 8. Installer certification bodies would be subject to clearer and more consistent requirements through binding agreements, ensuring technical standards are implemented consistently to strengthen how competence, compliance and performance are monitored in practice.

It will be important that any strengthened framework operates effectively across devolved areas. Some installers, certification bodies and consumer protection mechanisms operate across national boundaries, and consumers may engage with a mixture of UK-wide and devolved programmes. The Warm Homes Agency should therefore work closely with relevant Scottish organisations and delivery partners to promote consistency of standards, intelligence sharing and consumer protections wherever possible.

The home energy retrofit market requires consumers to make complex and often significant financial decisions involving products, services and technologies with which they may have limited familiarity. Consumer confidence is fundamental to the success of the Warm Homes Plan and wider decarbonisation objectives.

Proposal 9. Access to DESNZ‑supported schemes would be conditional on installers, retrofit professionals and their respective oversight bodies (including certification bodies) meeting higher system‑wide expectations for quality and performance.

The proposal to make access to DESNZ-supported schemes conditional on meeting higher expectations for quality and performance could also act as an important consumer protection mechanism. Publicly funded schemes should be associated with high standards of delivery, and consumers should be able to participate with confidence that organisations operating within these schemes are subject to robust quality assurance requirements.

However, qualifications, standards and certification arrangements should not be viewed as consumer protections in their own right. The effectiveness of these proposals should be measured by whether they improve outcomes for consumers, including reducing installation failures, preventing consumer detriment, strengthening accountability and improving access to remediation and redress when problems occur. Evidence from Citizens Advice indicates that consumers continue to experience significant detriment when low-carbon home upgrades go wrong, including financial losses, stress and prolonged disputes.[10]

Proposals 7-9 have the potential to create a more accountable and transparent market by establishing clearer professional responsibilities, strengthening assurance of competence, improving oversight of certification bodies and linking access to government-supported schemes to demonstrable quality and performance standards. From a consumer perspective, these outcomes are welcome if they lead to higher quality installations, fewer consumer complaints and stronger safeguards when things go wrong.

Earlier detection and stronger enforcement processes

Proposal 10. A stronger intelligence-led, risk-based approach to audit and inspection, targeting assurance where risks are highest.

An intelligence-led and risk-based approach to audit and inspection will help to improve oversight and accountability. Targeting oversight and assurance activity towards areas of greatest risk has the potential to identify consumer harm earlier, improve the effectiveness of monitoring arrangements and ensure that resources are used efficiently. Drawing on intelligence from complaints, audits, quality assurance processes, remediation activity and redress mechanisms should help identify emerging issues and patterns of poor performance before they result in widespread consumer detriment.

However, we would welcome further clarity on how this approach will operate alongside non-DESNZ schemes, including those delivered by the Scottish Government and other devolved administrations. Poor quality installations and rogue traders may operate across multiple schemes and jurisdictions, and risks identified within one programme may be relevant to others. Consideration should therefore be given to how intelligence, audit findings and consumer protection data can be shared appropriately across schemes to support a more comprehensive understanding of risk and enable earlier intervention. Effective collaboration between UK Government, devolved administrations and delivery partners will be important to ensure that consumers benefit from consistent protections regardless of the route through which they access support.

Proposal 11. Introduction of a clearer, graduated escalation model with a range of interventions from guidance and mandatory training, temporary or permanent suspension from DESNZ‑supported work, to referral to statutory regulators such as the single construction regulator and Trading Standards.

Consumer Scotland welcomes the introduction of a framework to address poor performance and non-compliance within government-supported home upgrade schemes. A proportionate approach, combining guidance and support with progressively stronger interventions where necessary, can help drive improvements in standards while protecting consumers from poor quality installations and service failures. Clear escalation processes can also provide greater transparency and accountability for organisations participating in publicly funded schemes, helping to maintain consumer confidence in the sector.

We consider it important that enforcement action is timely, consistent and informed by a wide range of intelligence, including complaints, audit findings and remediation outcomes. We would welcome further clarity on how the proposed escalation model will operate where installers and other organisations participate in both DESNZ-supported and devolved schemes. Effective information sharing between UK Government, devolved administrations, regulators and delivery partners will be important to ensure that concerns identified in one scheme can be appropriately considered across others. This will help prevent poor performers from moving between schemes and support more consistent consumer protections regardless of how households access support.

Swift remediation and redress

Proposal 12. A single complaints and case-management function to oversee remediation processes and outcomes, with an independent ombudsman as a final safeguard for unresolved disputes.

A single complaints and case-management function has the potential to significantly simplify this landscape. Consumers should not be expected to understand complex governance arrangements or determine which organisation is responsible for resolving their issue. Instead, there should be a clear and accessible route through which complaints can be managed, triaged and monitored, with responsibility placed on the system rather than the consumer to coordinate resolution.

While strong standards and quality assurance arrangements are necessary, some installations will inevitably experience problems. The measure of an effective consumer protection framework is therefore how quickly and effectively issues are resolved when they occur. Consumers should be able to access timely remediation without becoming trapped in lengthy disputes between installers, certification bodies or scheme administrators.

A dedicated case-management function could help ensure that consumers are actively supported throughout the remediation process, reducing the administrative burden on households and preventing consumers from being passed between multiple organisations. This may be especially important for consumers in vulnerable circumstances, who may find complex complaints processes difficult to navigate and may be disproportionately affected by poor outcomes.

We also support the inclusion of an independent ombudsman as a final safeguard for unresolved disputes. Independent dispute resolution is an important element of consumer protection, providing consumers with confidence that complaints can be reviewed impartially when resolution cannot be achieved through earlier processes. The presence of an independent ombudsman can help strengthen accountability across the system and encourage earlier resolution of disputes. However, the effectiveness of the proposed arrangements will depend on more than the existence of an ombudsman alone. Consumers should not routinely need to escalate complaints to the final stage in order to secure a satisfactory outcome. The primary objective should be to resolve issues as quickly as possible through effective case handling, supported remediation and clear accountability for delivery bodies and installers.

Complaints data can provide valuable insight into emerging risks, recurring installation issues, underperforming providers and gaps in consumer protection arrangements. The proposed arrangements should therefore be closely integrated with the wider oversight framework, enabling systemic issues to be identified and addressed before they result in widespread consumer detriment.

It will be essential that the Warm Homes Agency establishes effective interfaces with consumer advice, advocacy and redress organisations operating across GB. Consumers may interact with GB-wide and devolved services throughout their retrofit journey and should experience seamless referral pathways regardless of how they initially access support. Clear arrangements between the Warm Homes Agency and consumer bodies, the ombudsman and other relevant bodies will help reduce consumer confusion and support a more coherent consumer experience across Great Britain.

Proposal 13. Reform of financial protection arrangements for DESNZ supported upgrades, including more consistent requirements and stronger consumer information on guarantees and protections.

Consumer Scotland strongly supports the proposal to reform financial protection arrangements across DESNZ-supported home upgrade schemes and to establish more consistent requirements for guarantees and consumer protections. Robust financial protection arrangements are a fundamental component of an effective consumer protection framework and an important contributor to consumer trust and confidence in the retrofit market.[11] We would also encourage DESNZ to consider financial protections as part of a wider remediation and redress framework. Financial protection arrangements should operate alongside effective quality assurance, complaints handling and remediation processes rather than functioning as standalone mechanisms.

Consumer Scotland's investigation into the home heating market identified that concerns about financial risk can act as a significant barrier to consumer participation. Home energy upgrades often involve substantial financial commitments and can require consumers to place considerable trust in installers, manufacturers and scheme administrators. Consumers need confidence that appropriate protections are in place should there be issues with the installation, supplier or the quality of work delivered. This has the potential to increase consumer confidence in scheme participation and reduce the risk of consumers facing different levels of protection depending on the route through which they access support.

Next Steps

Consumer Scotland is supportive of the proposals set out in the consultation. As further work on the proposals is developed by government we would welcome further clarity on several important issues, particularly where reforms will interact with similar services and schemes already in place in Scotland. We would particularly welcome further clarity on:

• How the proposed consumer protection framework could interact with existing or future schemes funded by the Scottish Government?
• Detail on how the Warm Homes Agency will interact with Scottish Government-funded schemes and services to avoid creating additional complexity across the consumer landscape. While simplification is a welcome objective of these reforms, there is a risk of unintended consequences or the creation of additional complexity for existing schemes and services in Scotland if this connection is not fully worked through.
• How will intelligence, complaints and performance data be shared across schemes and jurisdictions? Effective information sharing will be important to identify emerging risks, address poor performance and support consistent consumer protections across Great Britain.

We would be happy to discuss the content of our submission to this consultation in more detail. Looking forward, we would welcome further engagement with the department to support and contribute to its work on reforming consumer protection for home upgrade schemes as this continues to develop.