RECC and HIES Compared: Two Consumer Codes for Energy Installations

Two consumer codes appear on quotes for solar panels, heat pumps, battery storage and insulation in the UK: the Renewable Energy Consumer Code (RECC) and the HIES scheme. Both are approved by the Chartered Trading Standards Institute, and both exist to put a layer of protection between a householder and an installer. Membership of one of them is not optional decoration. A condition of MCS certification is membership of HIES or RECC, and installers working with consumers must be MCS certified and members of a consumer code approved by the Secretary of State¹.

The two codes are relevant to the Boiler Upgrade Scheme, and Ofgem's property owner guidance names them as the two consumer codes that apply². Installers who have not yet transitioned to the MCS Redeveloped Installer Scheme must still hold consumer code membership with one of the other two approved codes of practice, HIES and RECC³. For a household, the practical question is what each code actually obliges an installer to do, and what happens when something goes wrong.

The differences that matter are in three places: how much money can be taken up front, what backs the workmanship guarantee if the installer fails, and how a dispute is escalated. RECC caps advance payment at 25% of the contract price and requires an insurance backed workmanship warranty valid for at least 2 years⁴. HIES operates as a TrustMark Scheme Provider with ongoing compliance monitoring and alternative dispute resolution⁵.

Solar Power Scotland Ltd has ceased trading: what it means for its customers

A company failure is the sharpest test of any consumer code, because it is the moment the paperwork either works or does not. Consumer Energy Solutions (CES) ceased trading, and the Welsh Government issued a written statement on support for householders affected by the closure under the Energy Company Obligation scheme⁹. The pattern is familiar: a firm stops trading, householders are left holding guarantees, deposits and unfinished work, and the question becomes who honours the promise.

The same has happened in the supply side of the market. Npower Business has ceased trading, and the Energy Ombudsman's own dispute page records that status¹⁰. Where a business has ceased trading, a code membership is not a substitute for the company still existing. What a code can do is require, in advance, that the money and the guarantee are structured so that a failure does not leave the household with nothing.

That is why the RECC rules on insolvency are drafted so widely. The code treats a member as having become insolvent or ceased to trade where it is deemed unable to pay its debts within the meaning of section 123 of the Insolvency Act 1986, where it commences negotiations with creditors to reschedule debts, where a winding up petition is filed or a resolution passed, where an application is made for the appointment of an administrator, where a qualifying floating charge holder appoints an administrative receiver, where a receiver is appointed over assets, where a creditor attaches assets and the process is not discharged within 10 days, and where the member suspends or ceases, or threatens to suspend or cease, a substantial part of its business¹¹. For an individual member, bankruptcy, death or incapacity also triggers the provisions¹¹.

The practical consequence for a household is that the guarantee has to be insurance backed rather than a promise from the installer's own balance sheet. RECC requires members to have made arrangements so that the full term of the guarantee will be honoured if the Code Member becomes insolvent or ceases to trade¹¹. Where a company has already failed, the code cannot retroactively create that cover, which is why the check matters before signing rather than after.

RECC and HIES: two CTSI-approved consumer codes compared

Both codes carry the same approval body. HIES accredited installers operate under a CTSI approved consumer code, and the scheme describes itself as approved by the Chartered Trading Standards Institute⁵. RECC is a CTSI-approved consumer code, with the Code Administrator assessed against core criteria established by CTSI¹¹. The approval is not a one-off stamp: the Code Administrator assesses how effective the code is in delivering high consumer protection standards¹¹.

The two codes also share a data-handling framework. Under the informal information sharing protocol between them, consumer information will only be shared with the consumer's express consent, unless ordered by a court or where a formally notified statutory power applies⁷. Each party is responsible for compliance with the Data Protection Act 1998 for information shared under the protocol⁷. That matters because a household that complains to one code may find the other holds relevant membership history.

The codes differ in emphasis rather than in kind. RECC's published rules are explicit about money: the deposit cap, the protection of advance payments, and the insurance backed warranty term. HIES emphasises the registration step, stating that a household will need to make sure the installation is registered by the installer with HIES for the protection to be in place⁵. That is a condition a household can verify, and it is worth verifying, because an unregistered installation sits outside the cover regardless of the installer's membership.

What each code covers: technologies, sales conduct and contracts

RECC's scope is set out in its own code document. It covers renewable energy sources, low carbon small-scale heat and power generators and fuel cells¹¹. The code's reach extends across the whole transaction rather than just the installation: marketing, pre-contractual information, quotations, deposits, contracts, guarantees and after-sales service⁸. That breadth is the point. Most disputes in this market begin before a spanner is lifted, in the quotation and the sales conversation.

On sales conduct, the rule is direct. Sales staff must not use selling techniques designed to pressurise you into making an immediate decision⁴. RECC also advises getting at least 3 quotes before deciding to contract with a business⁴. The code dovetails with the MCS, so the technical certification and the consumer protection sit alongside each other rather than duplicating⁸.

The legal backdrop is statutory as well as contractual. RECC's legal basis includes the Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013, the Consumer Rights Act 2015, the Alternative Dispute Resolution for Consumer Disputes (Competent Authorities and Information) Regulations 2015 and the Digital Markets, Competition and Consumers Act 2024¹¹. Where a service does not conform to the contract, the consumer has the right to require repeat performance and the right to a price reduction¹³. For digital content, the consumer has the right to repair or replacement and the right to a price reduction¹⁴.

One limit is worth stating plainly. Neither the Code Sponsor nor the Code Administrator is a party to any contract covered by the code¹¹. RECC is a regulator of conduct, not a guarantor of the work. If an installer breaches the code, the remedy runs through the disciplinary procedure, not through RECC paying for a replacement installation.

Deposits and workmanship guarantees: how your money is protected

The deposit rules are the most concrete protection either code offers. RECC guidance states that a household should never pay more than 25% of the contract price up front, and that members must protect the money paid in advance of an installation, including the deposit⁴. Those are two separate obligations: a ceiling on what can be asked for, and a requirement about how the money held is safeguarded.

The workmanship side is where the codes earn their keep over time. RECC requires an insurance backed workmanship warranty, valid for at least 2 years⁴. The code rules go further, requiring members to have made arrangements so that the full term of the guarantee will be honoured if the Code Member becomes insolvent or ceases to trade¹¹. An insurance backed guarantee is what converts a promise into something that survives the company that made it.

HIES approaches the same problem through registration. The scheme states that a household will need to make sure the installation is registered by the installer with HIES for the protection to be in place⁵. HIES also describes verified qualifications and certifications and ongoing compliance monitoring for its accredited installers⁵. The registration requirement is the weak link a household can actually close: ask for the registration reference and keep it with the contract.

For a household's energy independence, the deposit and guarantee rules matter because they determine whether a failed installation is a financial loss or a recoverable problem. A solar array or heat pump that is not covered after the installer disappears leaves the household paying twice for the same outcome, which is the opposite of self-sufficiency.

Dispute resolution: complaints, arbitration and what consumers recovered

The escalation route for an installation complaint is set out in official guidance. If a complaint relates to installation quality, workmanship, or the behaviour of an installer, it should be raised with the installer in the first instance, then with the installer's consumer code, HIES or RECC, or through MCS installation quality complaints¹⁵. That ordering matters: the code is a second stage, not a first port of call.

RECC's own complaints volume gives a sense of scale. The approved consumer code receives over 100 complaints each month⁷. RECC intends to continue to use its own complaints form, available online⁷. For feed-in tariff disputes, Ofgem's guidance directs householders to give the installer a week to respond before escalating¹⁶.

HIES describes its dispute route as Alternative Dispute Resolution, resolving disputes quickly and fairly without going to court⁵. The statutory framework behind that sits in the Alternative Dispute Resolution regulations referenced in RECC's legal basis¹¹. Where a complaint concerns a participating energy supplier, energy broker or heat network, the Energy Ombudsman's facilitated complaints resolution applies, and the participating supplier, broker or heat network is notified through the case management system¹⁷.

What consumers actually recover depends on the nature of the failure. Where the service does not conform to the contract, the statutory remedy is repeat performance or a price reduction¹³. Where the installer has ceased trading, the recovery route shifts to the insurance backed guarantee and to any deposit protection arrangements. The codes do not publish a compensation pot; they publish procedures, and the outcome turns on the evidence a household kept.

Membership, monitoring and enforcement in practice

Enforcement is where the two codes diverge most visibly in their published material. RECC sets out a graduated disciplinary procedure with a defined set of available actions: taking steps to promote consumer protection, communicating with the Code Member, auditing the Code Member, which may be at the Code Member's cost, consent orders, convening a hearing of the Non-Compliance Panel, termination of code membership following a Non-Compliance Panel determination, and termination of code membership by RECC without reference to the Non-Compliance Panel¹².

The process has defined steps. RECC will write to the Code Member to confirm where it has invoked the disciplinary procedure¹². A Code Member has a right of appeal against a determination of the Non-Compliance Panel in accordance with clause 11 of the Bye-Laws¹². Clause 14 of the Bye-Laws sets out the circumstances where RECC may terminate code membership with immediate effect without reference to the Non-Compliance Panel¹². The end of the disciplinary process varies case by case: it could be when conditions imposed by the Non-Compliance Panel have been met, when a consent order has been complied with, or once RECC is satisfied with the member's compliance¹².

Monitoring runs alongside enforcement. The code is monitored and updated regularly to reflect appropriate business practice, and the Code Administrator publishes the results of that monitoring in an annual report made available to Code Members, to CTSI and on the website¹¹. HIES describes ongoing compliance monitoring and verified qualifications and certifications for its accredited installers⁵.

For a household, the enforcement record is a signal about how seriously a code treats breaches. A code that can audit at the member's cost, convene a panel and terminate membership has real levers. A code that only records complaints has fewer. Both codes publish their procedures, and both are assessed against CTSI core criteria¹¹.

Which code applies to your installer, and how to check

The rule is straightforward. Installers working with consumers must be MCS certified and members of a consumer code approved by the Secretary of State². Membership of HIES or RECC is a condition of MCS certification¹. Installers who have not transitioned to the MCS Redeveloped Installer Scheme must still hold consumer code membership with one of the other two approved codes of practice, HIES and RECC³. Under the Boiler Upgrade Scheme, installers must continue to hold membership with one of the two approved consumer codes, RECC or HIES, to be able to deliver work under the scheme¹⁸.

The same requirement appears in the renewable heat incentive context. Before registering, an investor must be a member of the Renewable Energy Consumer Code or the Home Insulation and Energy Systems Quality Assured Contractors Scheme, both CTSI approved consumer protection codes¹⁹. Ofgem's property owner guidance for the Boiler Upgrade Scheme was updated with content and contact information concerning consumer codes, including MCS, HIES and RECC²¹.

Checking is a matter of asking for the membership and then verifying it. RECC can be contacted on +44 (0)207 981 0850²². HIES states that the installation must be registered by the installer with HIES for the protection to be in place, so the registration reference is the document to request⁵. Where a household is dealing with a Scottish scheme, the Home Energy Scotland Loan and Cashback Scheme followed a consumer-led model where the funding is applied for by the applicant directly, the applicant sources an installer, and funding is paid to them once works are complete²³. That model puts the checking burden squarely on the household.

The dependence that remains is worth naming. A code membership does not make an installer independent of the grid, of a manufacturer, or of the company's own solvency. It changes what happens when the relationship fails. For a household pursuing energy independence, the code is the mechanism that keeps a failed installation from becoming a permanent cost, and it only works if the membership, the registration and the insurance backed guarantee are all in place before the work starts.