Which? published its response to the Department for Energy Security and Net Zero (DESNZ) consultation on the Boiler Upgrade Scheme and certification requirements for clean heat schemes on 11 June 20251. The consumer body set out recommendations on consumer information, third party agreements, a possible low interest loan and certification1. Citizens Advice published its own response to the same consultation on the same day2.
Which? said progress towards the Climate Change Committee's target for half of UK households to have a heat pump by 2040 depends on the schemes supporting a broader range of consumers1. It said the options in the consultation "illustrate the increasing complexity of this market", and that consumers will need good quality independent assessments, information and advice to choose technology and finance1. It also suggested requirements for financial products to link to independent advice, key information sheets to support comparison, and regulation of comparison sites or brokers to improve transparency about market coverage and commissions1.
On third party ownership, Which? said allowing it to be eligible for the BUS creates the opportunity for new hire agreements and Heat as a Service agreements to enter the market1. It warned that the long term nature of these agreements, the bundling of services and the complex consumer protection landscape create risks that should be fully addressed before they become eligible for funding1. Citizens Advice said it had included interim findings from forthcoming research on consumers' understanding of third party ownership models, and that without the right protections, access to independent advice and products that deliver value, "the reputation of these products, and low-carbon home upgrades more broadly, will be at risk"2.
Both organisations backed MCS as the sole certification scheme. Which? said:
"we support a sole provider model as there is a risk that competition will lead to lower standards as schemes compete for business by reducing costs and making concessions to installers"
Citizens Advice said it agreed with the proposal to mandate MCS as the sole certification scheme for DESNZ clean heat schemes, "with appropriate oversight"2. Which? encouraged the government to consider mechanisms to ensure MCS maintains high standards and provides an efficient and cost effective service for installers1.
Which? also noted that the consultation records the government is considering the development of a low interest loan, which it said may be a more attractive option for some consumers1. It added that improving awareness of heat pumps, addressing concerns about running costs and making consumers aware of new and existing financial products would also help uptake1. Citizens Advice said it set out views on the wider reforms needed to create a robust consumer protections framework under the BUS and across the low-carbon home upgrades market2.
Why it matters for households
The BUS pays a grant towards the cost of installing a heat pump or biomass boiler, so the rules on who can receive it and who may install it shape what a household can actually claim. Allowing third party ownership would mean a home could get a heat pump without buying it outright, through a hire agreement or a Heat as a Service arrangement, but both consumer bodies say the protections around such long term agreements need to be settled first1. Certification decides who is allowed to do the work: a single scheme, MCS, would mean one set of standards rather than several competing ones, which Which? argues protects quality1. The consultation also raises the prospect of a low interest loan alongside the grant, which would change how the upfront cost of a heat pump is met1. None of these changes has been decided; both responses are submissions to a consultation, not outcomes.
What happens next
DESNZ has not published a response to the consultation, and no date for one has been reported1. Which? has published its full response as a PDF1, and Citizens Advice has published its response as a PDF2.
Sources2 cited
- DESNZ consultation on Boiler Upgrade Scheme and certification requirements for clean heat schemes - Which? response - Which?, which.co.uk
- Citizens Advice response to DESNZ’s consultation on the Boiler Upgrade Scheme and certification requirements for clean heat schemes - Citizens Advice, citizensadvice.org.uk