Green Deal Finance Mis-Selling: The Closed Scheme and Householder Claims

The central fact that drives most of these complaints is that a Green Deal plan is a type of unsecured loan, and it is attached to the property rather than to the person who took it out. If a homeowner sells, the loan passes to the new owner, and if you move into a property that has a Green Deal loan, it is your responsibility to repay it¹. That single design choice is why mis-selling claims surface years later, often at the point of sale of a house, when a buyer's solicitor finds the charge on the title.

This page sets out what the closed scheme means for a claim, the patterns households report, where a complaint can go now that the Renewable Energy Consumer Code has stopped taking new complaints, what the Competition and Markets Authority's green claims guidance says, what the Ofgem investigation into A Shade Greener did and did not deliver, and the evidence a claim needs.

The Green Deal scheme is closed: what that means for a household with a claim

Closure affects who can apply, not who can complain. The scheme is closed to new applicants, and the government stopped funding it in July 2015¹. The Green Deal sat in a line of schemes that were later withdrawn, alongside the Green Homes Grant, which closed in March 2022, and the Home Upgrade Grant¹. The Green Homes Grant voucher scheme itself ran between September 2020 and March 2021 for domestic properties in England⁸.

For a household already carrying a Green Deal charge, none of that removes the obligation. The loan is repaid over time with interest through energy bills, and it can be paid off early, though there may be extra costs³. The charge is collected by the electricity supplier and sits on the property, so it survives a change of occupant and a change of supplier.

The practical consequence is that a mis-selling complaint is now a retrospective exercise. The scheme's own consumer-protection architecture required Green Deal providers to be authorised by the Green Deal Oversight and Registration Body, to be part of the Ombudsman Services scheme and to obey a Green Deal Code of practice, and improvements had to be carried out by kite-marked installers³. Where a household's experience departed from that, the complaint is about what happened at the point of sale, not about a scheme that still exists to correct it.

How Green Deal finance was mis-sold: the patterns households report

The recurring pattern is not a single dishonest act but a gap between how the scheme was designed and how households actually decide. Citizens Advice found that the design of past schemes, notably Green Deal and ECO, failed to adequately reflect consumer decision making¹⁰. That is an independent finding about scheme design, and it explains why so many complaints turn on what a household understood rather than on what a document said.

The second pattern is the nature of the product. A green deal plan is a type of unsecured loan, a point the legislation requires to be made clear³. Where a household believed they were receiving a grant, a subsidy or a free improvement, and instead acquired a loan repaid through the electricity bill, the complaint is about the disclosure of that fact. The charge then follows the property, which means the person who feels misled may not be the person now paying.

The third pattern is the wider record of schemes that did not deliver what households expected. The Resolution Foundation described repeated failed government initiatives, from the Green Deal to the Green Homes Grant, that have not delivered¹¹. In Wales, the Nest scheme referred or signposted over 20,000 households to third parties for purposes including money and debt advice, which shows how often energy efficiency work sits alongside financial difficulty¹².

For a household's energy independence, the Green Deal's legacy is mixed. It financed fabric improvements that reduce reliance on bought energy, but it did so through a debt instrument attached to the home and collected by a supplier, so the household remained dependent on the grid, on a billing arrangement and on a charge it did not choose. The scheme went live at the beginning of 2013 and was withdrawn two years later¹³.

Where a claim can go now that RECC has stopped taking new complaints

The complaint landscape changed on 20 January 2026. From that date, new complaints about RECC members go to Green Homes Dispute Resolution, while complaints registered before that date continue to be handled by RECC⁵. That matters because RECC was for years the consumer code route for renewable and energy efficiency installations, and its dispute resolution process had referred over 70 disputes to adjudication¹⁴.

For a Green Deal complaint specifically, the routes are set out in government guidance. If a complaint is not resolved within eight weeks of contacting the provider, it can go to either the Financial Ombudsman Service or the Energy Ombudsman, depending on what the complaint is about². The Energy Ombudsman can review disputes with Green Deal providers if they are unable or unwilling to help when something goes wrong with a Green Deal plan¹⁵. Where the complaint is about being mis-sold the Green Deal itself, the government points to the Financial Ombudsman Service².

For installation quality, workmanship or the behaviour of an installer, the route starts with the installer, then the installer's consumer code such as HIES or RECC, or MCS installation quality complaints¹⁶. MCS lists mis-selling among the issues its complaints handling covers¹⁷.

Two procedural traps are worth knowing. If you withdraw a complaint to DESNZ, you might not be able to complain again to DESNZ, and if you accept the final offer, that is the final say on your case, with no reopening or appeal¹⁸. Where a final notice letter has been issued, there are 28 days from the date on that letter to lodge an appeal¹⁸.

The CMA's green claims guidance and what it says about supply-chain selling

The Competition and Markets Authority published consumer law compliance advice for businesses marketing green heating and insulation on 17 July 2024¹⁹. Its stated purpose is to help businesses understand and comply with their existing obligations under consumer protection law when marketing green heating and insulation products, in relation to providing headline price information and making product claims in marketing²⁰. It was produced as part of the CMA's work looking at consumer protection in the green heating and insulation sector²⁰.

The guidance is a standard, not a remedy. The CMA states that while the compliance advice is designed to help businesses, it is not legal advice, and responsibility for complying with the law remains with businesses themselves²⁰. RECC welcomed the CMA's advice on marketing green heating and insulation²¹. The CMA's wider work has focused on business practices, in particular misleading and greenwashing claims made by businesses about their products, following a report setting out findings from its call for information on consumer protection in the green heating and insulation sector²².

Which? has pressed the CMA to keep a close eye on the claims made by firms about their products and services and not to hesitate to take action if companies are not accurately representing their green credentials²³. The CMA has also published guidance on getting environmental claims right across the supply chain, dated 22 January 2026²⁴.

For a household, the guidance is useful in framing what a claim should have looked like. It addresses headline price information and product claims, which are precisely the areas where Green Deal complaints cluster. It does not create a compensation route, and it does not decide an individual case. It sets out what the law already required, which is the benchmark a complaint can be measured against.

The A Shade Greener investigation: what Ofgem closing it tells households

Ofgem finished its investigation into potential breaches of the Consumer Protection from Unfair Trading Regulations 2008 on 4 June 2026, with A Shade Greener committing to voluntary measures⁶. The outcome is a set of voluntary commitments rather than a redress fund, and that distinction matters to any household hoping an enforcement action will produce a payment.

Ofgem has used stronger tools elsewhere. It has previously used its enforcement powers for smart meters to require one energy supplier, OVO Energy, to contribute more than £1 million to a redress fund, and it is considering more severe financial penalties²⁵. The contrast between a voluntary-measures outcome and a redress fund is the practical lesson: an investigation closing does not automatically mean money for affected households.

The Energy Ombudsman's remit covers consumer complaints about energy bills, mis-selling, problems with energy supply and problems with switching supplier²⁶. It supports Ofgem's work to improve customer service and trust in the energy retail sector through the Consumer Confidence Programme²⁷. Where a company ceases trading, the Ombudsman cannot open any new cases for dispute with the closed company, though prior disputes are sometimes upheld by the new nominated supplier²⁸.

For a household, the A Shade Greener outcome is a reminder to keep the complaint in the redress system rather than waiting on an enforcement outcome. The Energy Ombudsman route, the Financial Ombudsman Service route and the DESNZ route are the ones that can produce a decision on an individual case.

What evidence a Green Deal mis-selling claim needs

Evidence in these cases is documentary and dated. The Energy Ombudsman expects a complainant to have already complained to the supplier and to have received a deadlock letter or waited eight weeks, and to have sufficient evidence to support the case, including the date the complaint was raised²⁹. That makes the complaint date itself a piece of evidence, not a formality.

The documents that matter are the ones the scheme required. Green Deal providers had to be authorised by the Green Deal Oversight and Registration Body, be part of the Ombudsman Services scheme and obey a Green Deal Code of practice, and improvements had to be carried out by kite-marked installers³. The assessment, the plan documents, the quote and the correspondence are the record of what was disclosed. The legislation defines green deal information by reference to a schedule of required fields, which is the framework the paperwork should have followed³⁰.

Two timing rules shape what can be recovered. A complaint not resolved within eight weeks of contacting the provider can be escalated². Where DESNZ has issued a final notice letter, there are 28 days from the date on that letter to appeal¹⁸. RECC's own process allowed a three-week period for a consumer to submit evidence requested in the acknowledgement email, after which the complaint could be closed³¹.

On cancellation, a separate rule applies to any new contract: if the contract was signed 14 days ago and you are not happy, the contract can be cancelled with the new supplier³². That is a general consumer right, not a Green Deal remedy.