Consumer Scotland, the statutory consumer body for Scotland, published its response to the Department for Energy Security and Net Zero (DESNZ) consultation on expanding the Warm Home Discount (WHD) scheme for 2025-26 on 24 March 2025. The body said it supports broadening the Park Homes WHD Scheme to cover other households that do not pay bills directly to an energy supplier, and called for a Great Britain-wide scheme with automatic payments.
The response warns that funding the expansion from the existing Industry Initiatives budget would cut money for energy advice and crisis support, including fuel vouchers for prepayment meter users. It says the expansion should be paid for from additional funding instead.
"We support the proposed expansion of the Park Homes WHD Scheme to include other consumers who do not pay bills directly to energy suppliers, but stress the need for additional funding rather than redistributing resources from vital Industry Initiatives."
The Warm Home Discount differs between Scotland and England and Wales. When the scheme was reformed in 2022, Consumer Scotland says the changes in England and Wales could not be replicated in Scotland because Valuation Office Agency data, used to identify homes meeting a "high cost to heat threshold" under Core Group 2, does not apply in Scotland and the Scottish Assessors do not collect equivalent data. Scotland kept the earlier structure of a Core Group, a Broader Group and Industry Initiatives1.
The Broader Group in Scotland is mainly aimed at working-age consumers on means-tested benefits such as Universal Credit and Income-Related Job Seekers Allowance, and rebates are allocated first come, first served, with suppliers opening and closing application windows as they reach their funding caps. Consumer Scotland describes this as a "lottery problem" in which eligible consumers miss out because their supplier is oversubscribed1.
The consultation proposes removing the high cost to heat threshold in England and Wales, which Consumer Scotland calls the primary barrier to a uniform GB-wide scheme. It recommends DESNZ extend the same structure to Scotland, with automatic payments rather than applications. It also notes that the Warm Home Discount Regulations require non-core spending to be determined and communicated to suppliers by 14 March 2025, and urges DESNZ to work with suppliers on whether a transition this winter is feasible1.
Consumer Scotland also recommends better targeting, based on low income combined with high essential energy spending. It names groups it has previously identified as at particular risk of energy affordability and debt problems: disabled people, particularly those limited a lot by disability; those on low income; those with children under 5; those on prepayment meters; and those using traditional electric-only heating or heating oil. It suggests opening eligibility to disabled consumers receiving disability benefits, as was the case before 2022, or using child benefit data to reach households with young children1.
Why it matters for households
For a household in Scotland, the practical difference is how the rebate arrives. In England and Wales, eligible homes in the Core Group receive an automatic deduction. In Scotland, many households must apply through a supplier's Broader Group and can miss out once that supplier's allocation is used up, even where they meet the eligibility rules. A GB-wide scheme with automatic payments would remove the application step and the timing risk that comes with it.
The funding question matters too. Industry Initiatives pay for advice and for crisis support such as fuel vouchers that help prepayment meter users avoid self-disconnection. If the Park Homes expansion is paid for by moving money within that budget rather than adding to it, that support is reduced. Households that do not pay a supplier directly, including park home residents and Gypsy/Traveller communities, are the group the expansion is intended to reach.
What happens next
The consultation proposes retaining the Broader Group in Scotland for the time being while increasing suppliers' non-core obligations in Scotland in proportion to any expansion in England and Wales. Consumer Scotland says that if the high cost to heat threshold is kept in England and Wales in current or recalculated form, it supports extending the existing Broader Group structure, but wants both governments to commit to fixing the data-matching gap. It also asks for equality and distributional analysis if the schemes are not aligned. No decision by DESNZ on the 2025-26 scheme has been reported.