MCS published its response on 13 June 2025 to a two-part consultation issued by the Department for Energy Security and Net Zero (DESNZ) in April 20251. The consultation closed on 11 June 20251. Part one proposed changes to the Boiler Upgrade Scheme (BUS) intended to stimulate further demand and enhance consumer protections; part two sought views on proposals to mandate MCS as the sole certification scheme for all DESNZ clean heat schemes1.
On new technologies, MCS said it has updated the heat pump product standard (MCS 007) to cover air to air heat pump products, and is updating other standards and tools including the system performance estimate and the design and installation standards1. It is also developing a new installation standard for Thermal Energy Storage Systems (TESS) to include heat batteries1. MCS called for careful consideration of the success of the current BUS, part of which it attributes to its relative simplicity, and said incentives for new technologies must be presented to consumers in the right way to ensure continued market growth1.
On third-party ownership, MCS said it had shared concerns with allowing such agreements within the BUS, citing consumer understanding, contract fairness, long-term affordability and route of redress, and said there needs to be particular emphasis on ensuring payment methods and contractual terms do not lead to consumer detriment1. On consumer protections, MCS welcomed the proposal to include the MCS Customer Commitment as an eligible code of practice for the BUS, and said it will monitor each installer's compliance by contacting every consumer who has received an MCS certified installation, enforced through the MCS Installer Agreement1. It said an installer's ability to trade as MCS certified, and therefore participate in the BUS, can be withdrawn based directly on their delivery of the consumer experience1.
On the proposal to automatically discount BUS grant funding from the upfront cost of an installation, MCS said it understands the reasoning, describing it as important for protecting consumers in the unlikely event that the installer ceases to trade before the installation is complete, but said this must be balanced with installers' cashflow and that prompt, reliable payments will be critical to maintaining installer participation and confidence1.
"MCS is well-placed to take on the responsibility of being the sole certification scheme for clean heat installations under government clean heat schemes."
MCS said it is concerned that "equivalency" could lead to a race to the bottom at the cost of quality and consumer protection, and that an installer could lose certification with one scheme and move to another to keep access to government grants1. It said its standards are developed with over 200 experts, including installers, manufacturers, consumer protection experts and academics, under governance requiring public consultation on new or changed standards1. It said that as it deploys the redeveloped MCS during 2025 and 2026, there is not and will not be an equivalent scheme offering design and installation standards across the spectrum of technologies, the same level of consumer protections, or its existing working relationship with Ofgem in delivering the BUS1.
Why it matters for households
The BUS is the main grant route for replacing a fossil fuel heating system with a heat pump in England and Wales, and the certification scheme attached to it determines who may install a grant-funded system and what standards apply. MCS's response sets out how it would police installer conduct if its Customer Commitment becomes an eligible code of practice: every household receiving an MCS certified installation would be contacted, and an installer's access to the BUS could be withdrawn on the basis of that feedback1. For a household, that is a route of accountability that does not depend on the installer's own complaints process, and it sits alongside existing consumer rights when installation work is faulty and the Renewable Energy Consumer Code.
The third-party ownership question bears directly on who owns the equipment on a home and who carries the long-term cost. MCS has raised concerns about consumer understanding, contract fairness, long-term affordability and route of redress in such models, but has not said what safeguards it wants1. The proposal to discount the grant from the upfront cost would reduce the sum a household needs to find at the point of installation, though MCS notes the trade-off with installer cashflow1. Whether DESNZ accepts any of these positions has not been reported.
What happens next
DESNZ has not published its response to the consultation, and no date for that response appears in the material published by MCS1. MCS said it will deploy the redeveloped MCS during 2025 and 20261.