The Department for Energy Security and Net Zero (DESNZ) consulted in September 2025 on continuing the Warm Home Discount scheme beyond 31 March 2026, with three options for Scotland for the 2026/27 scheme period1. Consumer Scotland, the independent consumer body, published its response to that consultation on 21 November 2025, supporting continuation of the scheme and recommending changes to how it is delivered in Scotland1.
Consumer Scotland said 16% of Scottish households currently find it difficult to keep up with their energy bills, equivalent to 393,000 households, and 15% are in debt or arrears, up from 9% in 20241. It said the discount has risen from £120 to £150 since its introduction in 2011, an increase of 25%, while typical annual bills have risen from £1,118 to £1,755, an increase of 57%1. It also cited the impact assessment for the proposed scheme, which expects it to reach only 45% of fuel poor households from scheme year 2025/26 onwards1.
The three options for Scotland concern the Broader Group, which supports working-age consumers. From 2022 to 2025 the application-based design of the Broader Group in Scotland created additional access barriers compared with England and Wales, Consumer Scotland said1. It prefers Option 2 or Option 3, both of which involve automatic data matching, and called for further impact analysis before a decision is taken1.
"Consumer Scotland recommends that a future WHD scheme in Scotland adopts automatic data matching to improve consumer access to the scheme"
Consumer Scotland also recommended payments be delivered between November and January, a centralised WHD helpline for partially data matched Scottish consumers, and that changes be communicated effectively to affected consumers1. It said the scheme is a cliff edge, with no link between the level of the discount and consumption, and no indexation1. It noted that under current proposals the WHD is due to increase to an average cost of £37 per year for a typical dual fuel billpayer1.
| Measure | Figure |
|---|---|
| Discount at introduction (2011) | £120 |
| Discount now | £150 |
| Typical annual bill at introduction | £1,118 |
| Typical annual bill now | £1,755 |
| Scottish households finding bills difficult | 16% |
| Scottish households in energy debt | 15% |
Why it matters for households
The Warm Home Discount is a one-off reduction applied to electricity bills for eligible households, so its continuation determines whether that support exists at all after March 2026. For a household in Scotland, the choice between the options decides whether eligibility is assessed automatically through data matching or requires an application, which affects how many eligible homes actually receive the payment. Consumer Scotland's figures indicate the discount has not kept pace with bills, so its real value to a household has fallen since 2011. The scheme is funded through a levy on bills, so its cost is spread across billpayers, including those who do not receive it.
What happens next
The consultation ran in September 2025 and Consumer Scotland responded on 21 November 20251. Consumer Scotland recommended that governments publish detailed impact analysis of Options 2 and 3 before any decision is taken, and that the UK Government, Scottish Government and regulator commit to periodic reviews of the WHD every 12 to 18 months1. No decision on the next scheme period has been reported.