The Electricity and Gas (Energy Company Obligation) (Amendment) Order 2025 was made on 31st July 2025 and came into force on 1st August 2025, amending the 2022 and 2023 Orders that govern the ECO4 scheme1. It extends to England and Wales and Scotland, and was made with the agreement of the Scottish Ministers1.
The order contains a provision stating that certain amendments, those limiting insulation measures per property, apply in relation to a measure where the installation is or was completed on or after 14th November 20241. This is a retrospective application: it reaches back to installations completed before the order was made. The order does not set out in the text provided which specific paragraph of the amendments this retrospective date attaches to beyond the description of limiting insulation measures per property.
Other parts of the order apply only from the coming into force date. The change to the definition of a rural area applies where the Administrator is first notified in writing of the ECO4 project on or after 1st August 2025, or, for the 2023 Order, where the Administrator is notified of the measure on or after that date1. The new rural area definitions use the 2021 rural-urban classification of output areas published by the Office for National Statistics in March 2025 for England and Wales, and the Scottish Government Urban Renewal Classification 2022 published in December 2024 for Scotland1.
The order also changes installation standards. For insulation measures, installation is deemed to adhere to TrustMark or equivalent requirements unless the measure is referred to the Administrator for failing to meet those requirements and that referral is not withdrawn before 1st July 20261. These amendments apply where installation is completed on or after 1st August 20251. The order also substitutes PAS 2030:2023 for PAS 2030:2019 in the definition of a novel data light measure, and references PAS 2035:20231.
On smart meters, the order requires that advice on the benefits of using a smart meter includes guidance on arranging installation and an invitation to the household to make a non-binding pledge to arrange installation1. This applies where installation is completed on or after 1st August 20251.
The order adds a mechanism for reassigning ECO4 savings to the ECO4A scheme. A participant may apply to the Administrator for an amount of annual cost savings from ECO4 qualifying actions to be reassigned towards the participant's total home-heating cost reduction obligation or total low-income minimum requirement1. The conversion multiplies the amount by 1.251, and an application may not reassign an amount which, as converted, exceeds 75% of the participant's total home-heating cost reduction obligation1. Applications must be made in writing on or before 31st July 20261.
"The amendments made by paragraph (1) apply in relation to a measure where the installation is or was completed on or after 14th November 2024."
Why it matters for households
The retrospective date means that a household whose insulation was installed on or after 14th November 2024 may be affected by the per-property limits even though the order was not made until July 2025. The order text provided does not state what those limits are, so the specific number of measures permitted per property has not been reported here. Households considering insulation and glazing as a route to greater energy independence should be aware that the rules governing how many measures can be installed under ECO4 have changed, and that the change reaches back to late 2024.
The TrustMark provisions matter for quality and redress. Under the new wording, an installation is treated as compliant unless TrustMark or an equivalent body refers it to the Administrator and that referral stands beyond 1st July 20261. This shifts the default position: compliance is assumed unless a referral is made and maintained.
The smart meter provisions add a step to the advice given alongside measures, including guidance on arranging installation and an invitation to pledge, though the pledge is expressly non-binding1.
What happens next
The order came into force on 1st August 20251. Applications to reassign ECO4 savings to the ECO4A scheme must be made in writing on or before 31st July 20261. TrustMark referrals that are not withdrawn before 1st July 2026 will affect whether an installation is deemed to adhere to the relevant requirements1.
Sources1 cited
- The Electricity and Gas (Energy Company Obligation) (Amendment) Order 2025, legislation.gov.uk