Consumer Scotland published its response on 11 September 2026 to the UK Government consultation on reforming consumer protection for home upgrade schemes, which is intended to support delivery of the Warm Homes Plan1. The body, which describes itself as the statutory body for consumers in Scotland and is accountable to the Scottish Parliament under the Consumer Scotland Act 2020, said it is supportive of the proposals set out in the consultation1.
The response does not answer the consultation's specific questions. Instead it comments generally on the UK Government's proposals, particularly where they will have an impact in Scotland1. Consumer Scotland said its response was informed by its ongoing work on energy efficiency and the rollout of low carbon technologies in Scotland, including the recommendations of its 2025 investigation into the green home heating market1.
On the proposal for a new integrated consumer protection service for government-supported home upgrades, covering advice, quality assurance, case management, remediation and redress, Consumer Scotland said such a service would be a welcome measure. It said the service would sit under DESNZ oversight and could potentially be delegated to the Warm Homes Agency, subject to final approvals1. It asked for further detail on how the proposed service might interact with existing Great Britain-wide quality standards schemes such as the Microgeneration Certification Scheme, and with Scotland-specific programmes such as the Home Energy Scotland Grant and Loan scheme1. It encouraged close collaboration between the UK and Scottish governments so the new service can learn from the Scottish Government's Home Energy Scotland advice service, which is delivered by the Energy Saving Trust1.
"The introduction of a fully integrated service which covers consumer advice, quality assurance, case management, remediation and redress, for new and existing government retrofit schemes would be a welcome measure."
The response also addresses proposals on binding agreements across the delivery chain, a government-owned data system, a simpler consumer journey, impartial advice, professional competence and installer certification. On the proposal that access to DESNZ-supported schemes would be conditional on installers, retrofit professionals and their oversight bodies, including certification bodies, meeting higher system-wide expectations for quality and performance, Consumer Scotland said this could act as an important consumer protection mechanism1. It added that qualifications, standards and certification arrangements should not be viewed as consumer protections in their own right, and that their effectiveness should be measured by whether they reduce installation failures, prevent consumer detriment, strengthen accountability and improve access to remediation and redress1.
The response cites evidence from Citizens Advice that consumers continue to experience significant detriment when low-carbon home upgrades go wrong, including financial losses, stress and prolonged disputes1. Consumer Scotland said its own work on net zero and the energy transition has identified confidence, clarity, cost and convenience as the key considerations when consumers make decisions1.
Why it matters for households
Home upgrade schemes are the route by which many households access insulation, heat pumps and batteries, often with public funding attached. The consultation concerns what happens when that work goes wrong: who is accountable, how complaints are handled and how disputes reach a remedy. Consumer Scotland's response describes a system in which consumers deal with advice providers, installers, certification bodies and scheme administrators, and says that without clear responsibilities accountability can become fragmented, making it harder for consumers to know who is responsible when problems arise1. For a household weighing up a retrofit, the practical questions are whether the installer is competent, whether the work is covered if it fails, and where a complaint goes. The response states that stronger agreements should cover consumer satisfaction, complaint resolution and remediation timescales, alongside support for consumers in vulnerable circumstances1. It also notes that consumer harm often results from issues repeated across multiple installations, installers or schemes, which a centralised data system could identify earlier1.
What happens next
Consumer Scotland said it would be happy to discuss the proposals further1. It is commissioning further qualitative research on consumer engagement with energy efficiency advice, and said research is expected to be published in 20271. No timetable for the UK Government's decisions on the consultation has been reported.