DESNZ Consultation on Expanding the Warm Home Discount Scheme for winter 2025/26

Response submitted: 24 March 2025

Summary of response:

• We strongly support this consultation's proposed broadening of the Warm Home Discount to include communal electricity consumers.

• Many domestic consumers who receive their heating and hot water communally via heat networks also receive their electricity communally via their landlord, with both arrangements classed as commercial energy supplies.

• Like heat network consumers, communal electricity consumers have been disproportionately impacted by the energy crisis through their exposure to volatile commercial energy prices and inability to benefit from Ofgem's domestic price cap.

• We're concerned that no additional budget is proposed to support this extension of the Warm Home Discount scheme, which risks the scheme being unable to achieve its aim of supporting consumers at greatest risk of fuel poverty.

• We also urge government to ensure that consumers with communal electricity are able in practice to exercise their existing legal right to switch to a domestic electricity supplier of their choice, where they wish to do so.

Read our full response here.

DESNZ Consultation on Review of the Fuel Poverty Strategy

Response submitted: 10/02/25

Summary of response:

• We support this review and the intention that the government's fuel poverty metrics should aim to capture all households that are unable to heat their homes.

• We'd like to see explicit assurance that this review, including any energy affordability metrics and proposals for energy bill support, include heat network consumers.

• It's essential that this review is joined up with Ofgem's work on energy debt and consumer vulnerability.

Read our full response here.

DESNZ and Ofgem Consultation on Implementing Heat Network Consumer Protections

Response submitted: 30/01/25

Summary of response:

• We welcome this important consultation, having long advocated for statutory regulation of heat networks.

• We’re delighted to see alignment between the proposed regulations and Heat Trust’s rules, which are based on Ofgem’s own standards of conduct for gas and electricity suppliers.

• We fundamentally agree that heat network regulations should deliver equivalent protections to those already enjoyed by gas and electricity consumers, which was the founding principle of our own scheme.

• We provide comments on areas where the proposed protections don’t go as far as our own rules, or where the detail of the proposals doesn’t appear to deliver the stated policy intention.

• We strongly disagree with the proposal that some social housing residents shouldn’t receive compensation for heat network supply outages when their private housing neighbours should, creating an unjustified inequity of treatment.

• We believe that the proposals around price protections are inadequate and unlikely to deliver improved consumer outcomes in their current form.

• We argue that the proposed protections around disconnections in winter should go further and mirror our own rules (and note that the proposals as drafted could perversely make it easier for heat suppliers to disconnect consumers than to move them to pre-payment arrangements).

Read our full response here.

Ofgem Consultation on Heat Networks Authorisation and Regulatory Oversight

Response submitted: 30/01/25

Summary of response:

• We’ll continue to operate our voluntary scheme until all Ofgem protections are in place and enforced, so that consumers on our registered heat networks don’t lose any of their current protections during Ofgem’s initial phasing in of its regulations.

• We’re committed to working with Ofgem to complete a smooth handover of our scheme monitoring and compliance activities.

• We share our experience of regulating heat networks over the last nine years, and our insight from our wider consumer champion work, where we believe this can inform Ofgem’s development of its own regulatory oversight and assurance processes.

• We highlight the key elements of Ofgem’s proposed processes that will require co-ordination with Heat Trust activities during the initial phasing in of Ofgem’s regulations, on which we welcome further discussion and collaboration.

Read our full response here.

DESNZ Review of Ofgem: Call for Evidence

Response submitted: 30/01/25

Summary of response:

• We offer our views on how Ofgem’s new role as the heat networks regulator fits within its existing governance and within this consultation’s proposals for strengthening Ofgem’s duties, powers and accountability.

• We outline our core concern that Ofgem’s work as the heat networks regulator must be integrated into its wider energy work and mustn’t be siloed from its initiatives to improve consumer standards in the gas and electricity sectors.

• We highlight that DESNZ’s and Ofgem’s current proposals about supply outage compensation for heat network consumers contradicts the government’s manifesto commitment to ensure that energy consumers receive automatic compensation for service failure.

Read our full response here.

Ofgem Consultation on its Forward Work Programme 2025/26

Response submitted: 30/01/25

Summary of response:

• We’re disappointed that heat networks only receive passing mention in the FWP, since the start of Ofgem’s role as heat networks regulator falls within the period covered.

• We’re concerned that the development of Ofgem’s role as the heat networks regulator already appears to be siloed from other gas and electricity consumer-protection initiatives set out in the FWP that are equally applicable to heat network consumers.

Read our full response here.

Ofgem Consultations on Resetting the Energy Debt Landscape and Improving Debt Standards

Response submitted: 30/01/25

Summary of response:

• We’re concerned that the ‘energy’ initiatives set out in these consultations don’t appear to include heat network consumers.

• We highlight that domestic heat network consumers have at least an equal need to gas and electricity consumers for support with vulnerabilities and debt – and arguably have greater need, since they’re not protected by the Ofgem price cap and have been disproportionately impacted by the energy crisis.

• We believe it would be inequitable to provide relief to gas and electricity consumers for debt built up during the energy crisis but not to provide heat network consumers with equivalent relief.

Read our full response here.

Citizens Advice Consultation on its Forward Workplan 2025/26

Response submitted: 30/01/25

Summary of response:

• We’re delighted that Citizens Advice will become the statutory advocate and advice body for heat network consumers in England and Wales from 1 April 2025, giving consumers a clear route to access advice.

• We support the overall approach and priorities set out in the draft workplan and look forward to seeing how the planned research adds insight to the shaping of government’s heat network regulations.

• We offer some specific suggestions on priority research areas for heat networks, particularly around the use of pre-payment in the sector and the associated risk of consumers self-disconnecting from their heat supply.

Read our full response here.

Consumer Scotland Consultation on its Work Programme 2025/26

Response submitted: 30/01/25

Summary of response:

• We’re delighted that Consumer Scotland will become the statutory advocate for heat network consumers in Scotland from 1 April 2025, with Advice Direct Scotland and Citizens Advice Scotland providing Tier 1 and Tier 2 consumer advice respectively.

• We support the overall approach and priorities set out in the draft work programme, especially the planned scoping of research on heat network consumers’ experience of pre-payment in the sector.

• We suggest that additional priority research areas could be consumers’ experience of heat network reliability and the interaction of Scottish housing legislation with proposed heat network regulations.

Read our full response here.