Citizens Advice published its response to the consultation on the fuel poverty strategy for England on 4 April 2025. The charity said it supports keeping the 2030 target and wants additional long-term targets set beyond it1.
The response backs the existing goal of bringing as many fuel-poor homes as reasonably practicable to an Energy Performance Certificate (EPC) rating of C1. Citizens Advice said fuel poverty levels remain persistent and that uncertainty in energy prices presents significant challenges, but described the target as crucial for driving policy this decade1. It called on the government to set further targets beyond 2030 so that fuel-poor households are not left behind in the wider net zero transition1.
On measurement, Citizens Advice said the Low Income, Low Energy Efficiency (LILEE) metric is valuable for guiding policies aimed at improving home energy efficiency, but that it does not provide the full picture of households' experiences of fuel poverty1. It pointed to a growing gap between the number of households classified as fuel-poor under LILEE and those spending more than 10% of their income after housing costs on heating their homes adequately1. It supports introducing an energy affordability indicator to sit alongside LILEE1.
"This indicator, used alongside LILEE, would offer a more comprehensive and nuanced understanding of fuel poverty."
The response adds a consumer-friendly principle to the four guiding principles of worst-first, cost-effectiveness, vulnerability and sustainability1. Citizens Advice said meeting the 2030 target depends on widespread consumer involvement in retrofit, and that the strategy must tackle barriers to participation through fully funded upgrades for low-income households, well-designed energy efficiency schemes and a robust consumer protection framework1.
For the private rented sector, Citizens Advice said regulatory changes to the Minimum Energy Efficiency Standards (MEES) must be accompanied by support for landlords and strong enforcement measures, to ensure compliance and avoid undue burden on tenants1. It also backed targeted bill support, saying it would complement efficiency upgrades by helping households manage high energy prices and bridging the gap to long-term affordability, and would matter in homes that may not reach sufficient efficiency levels1.
Why it matters for households
The consultation concerns how England defines and measures fuel poverty, which shapes who qualifies for support and which homes are prioritised for upgrade schemes. The fuel poverty policy definitions differ across the UK nations, and the LILEE metric used in England counts households on low incomes in homes with poor energy efficiency. Citizens Advice argues that measure alone misses households whose bills are unaffordable for other reasons, which is the gap the proposed affordability indicator would address1.
For a household, the practical link is between the standard a home must reach and the help available to get there. The EPC C target applies to fuel-poor homes under the strategy, while MEES set the minimum standard for privately rented property. Citizens Advice's position is that enforcement of MEES without landlord support risks costs falling on tenants1. Its call for fully funded upgrades for low-income households and targeted bill support sets out where it sees the funding gap. Households in England seeking existing support routes can find them through help for low-income households in England, and renters can read how standards and rights interact in the Renters' Rights Act and home energy. Complaints and redress routes sit with energy complaints and redress, and the role of the advice bodies is set out under energy consumer bodies.
What happens next
The response is dated 4 April 2025. No date for the government's final strategy, or for any decision on the energy affordability indicator, has been reported1.