Citizens Advice response to DESNZ consultation on reforming consumer protection for home upgrade schemes
We welcome the opportunity to respond to this vital consultation on reforming the consumer protection framework for home energy upgrades. These reforms are essential to rebuild trust in low-carbon technologies, and ensure that the Warm Homes Plan delivers energy upgrades that genuinely benefit consumers.
We strongly welcome the Government’s intention for more centralisation and oversight of consumer protection in this space, with the Department for Energy Security and Net Zero (DESNZ) overseeing an end-to-end consumer protection service. This is essential to address the current fragmentation of the system, which has allowed poor practice to flourish and can prevent consumers from accessing redress where needed.
The delivery model of this consumer protection service should be as streamlined as possible, with the DESNZ-run Warm Homes Agency overseeing delivery of core functions inhouse and outsourcing only where needed. This will ensure that the new consumer protection service is genuinely simplified and integrated, providing accountability for installers and clarity for consumers - rather than simply adding a layer of oversight over an existing patchwork of complexity.
We further welcome plans to boost standards among installers, with stronger technical and professional frameworks, and an installer register managed by the consumer service provider. To protect consumers in cases where things do go wrong, we strongly welcome proposals to provide a simplified route to redress with a single case management system, with access to an ombudsman as a backstop. This system should be supported by reforms to guarantees and warranties, to ensure they provide the required support to consumers.
Installers should be accountable when their work falls short, with meaningful enforcement levers supported by direct contractual relationships between installers and the consumer protection service provider, as well as robust data sharing across the system.
It is also essential that consumers have access to independent, tailored advice to ensure they can navigate installation and redress processes, in addition to high-level information. This should be delivered by advice providers outside the core consumer protection service, to ensure that consumers can trust the independence of the advice they receive and to build on the existing knowledge and expertise within the sector.
Citizens Advice has consistently argued that a reformed consumer protection framework should be mandatory across the home energy upgrades market, rather than applied only to specific government schemes. This would protect more consumers, strengthen the framework, and future-proof the system as privately funded upgrades increase.