The Scottish Government's Warmer Homes Scotland programme began using revised eligibility criteria in April 2023, according to a Scottish Government periodic report on tackling fuel poverty1. Applications to the first phase of the scheme closed on 31 March 2023, at which point all households were required to meet all six of the high-level qualifying criteria2. Referrals were paused from Friday 31 March 2023 and were due to restart in October 20233.
The six criteria in force at the close of the first phase were: being a homeowner or tenant of a private sector landlord; living in the home as a main residence; having lived at the property for more than twelve months, unless in receipt of a DS1500 or BASRiS certificate; living in a property with a SAP of 72 or lower which is under 230m2 in floor size; living in a home that meets the tolerable living standard set out in the Housing (Scotland) Act 2006; and not having received support for energy efficiency measures through Warmer Homes Scotland funding in the last five years2. As well as the six high-level criteria, customers had to be 16 or over and in receipt of certain benefits, with an exception for those aged 75 or over with no working heating system2.
Between the scheme starting in September 2015 and referrals for the first phase stopping on 31 March 2023, 22,817 customer requests either did not proceed to a referral to Warmworks or were found not to be eligible once referred, while more than 35,000 customers were supported in the same period2. The most common reasons for an application not qualifying are set out below2.
| Reason given | Number of households |
|---|---|
| Household does not meet age, children in home (under 16) or benefits criteria | 10,168 |
| SAP rating too high | 3,953 |
| No suitable measures available under Warmer Homes Scotland | 3,032 |
| Has not lived in the property for sufficient time | 1,336 |
| Customer not private tenant or owner occupier | 1,144 |
The Scottish Government's engagement report records that the widened eligibility criteria introduced in 2023 have been welcomed, with stakeholders identifying that households who were formerly on the margins of eligibility are now eligible for support1.
"the widened eligibility criteria introduced in 2023 have been welcomed, with stakeholders identifying that households who were formerly on the margins of eligibility are now eligible for support"
Where an application did not progress beyond the initial phase, the customer was directed to contact Home Energy Scotland to find out what other support could be available, including Area Based Schemes, the Energy Company Obligation and the Home Energy Scotland Grant and Loan2. That grant and loan scheme is open to all domestic owner occupied households in Scotland and provides grant funding for zero direct emissions heating up to £7,500, and for energy efficiency improvements up to 75% of the combined cost and up to a maximum grant of £7,5002.
Why it matters for households
Eligibility rules decide whether a household can get measures such as central heating, loft and wall insulation, draught-proofing and renewable systems at no cost through the scheme3. The published figures show that the benefits criteria, covering age, children in the home and benefit receipt, accounted for the largest single group of households that did not qualify in the first phase, at 10,168, followed by homes with a SAP rating above the threshold at 3,9532. For a household near those boundaries, the April 2023 change is the difference between being inside or outside the scheme.
The wider context is a rising fuel poverty rate. Energy Action Scotland told the Scottish Government that the benchmark figure for 2019 was 24% of households and that in 2024 it is now 31 to 33% of households, with rates across Scotland likely to range from around 1 in 2 to 1 in 5 depending on geography and demographics1. The same response states that fuel poverty now affects between 800,000 and 900,000 households1. Households whose energy is unregulated because it is LPG, oil, solid fuel or supplied through heat networks are also noted as a group outside the standard framework1.
What happens next
The engagement report records that in February 2023 the Scottish Government agreed in principle to publish three-year Area Based Schemes funding assumptions, but that this has not come to fruition, and that in 2024 programme budgets were not confirmed until September1. The consultation on proposals for a Heat in Buildings Bill was published in November 2023, significantly later than anticipated, and the consultation analysis is yet to be published1.