AgilityEco responds to Warm Homes Fund Call for Evidence
14 May 2026
The UK Government’s Warm Homes Fund: Call for Evidence is one of the most strategically important consultations the UK retrofit and decarbonisation sector has seen in recent years. Marking a clear shift in direction, it recognises that the scale of investment needed to deliver the ambitions of the Warm Homes Plan can’t be achieved through traditional grant funding alone.
Instead, the government is actively exploring how private capital, innovative finance models, energy market participants and long-term system value can speed the transition to warmer, lower-carbon homes.
At AgilityEco we strongly welcome this direction and are preparing a full response to submit by the consultation deadline on 1st June. As part of this response, we’ve also developed a detailed proposal outlining what we believe is required if the Warm Homes Fund is to succeed for vulnerable and low-income households.
An opportunity for market innovation
There is a major opportunity to unlock significant private sector investment into the able-to-pay market – through long-term policy certainty, scalable delivery models and the right market frameworks.
We expect to see increasing innovation across consumer finance, subscription models, energy-as-a-service propositions, local authority partnerships and blended investment structures as the market matures.
However, the consultation also rightly recognises that not all households can be served through conventional finance mechanisms. In fact, there are two areas where differentiated intervention and policy thinking will be critical.
A separate approach for low-income households
Firstly, the proposed £600m allocation for low-income and clinically vulnerable households is one of the most important aspects of the consultation. In our view, it requires a differentiated approach within the overall Warm Homes Fund structure.
DESNZ explicitly acknowledges within the consultation that traditional consumer debt models are unlikely to be suitable for many households in fuel poverty. Even low or zero-interest lending models can create barriers to uptake for vulnerable households already struggling to pay.
As part of our response, we’ve developed a detailed proposal based on a fully protected consumer model with no upfront cost, no household debt and programme-level Financial Transactions compliance, recognising the specific barriers faced by households in fuel poverty.
A strong economic and fiscal argument
Based on our modelling, deploying the full £600m allocation into vulnerable households could deliver £76-£104 million per year in total societal benefits:
- £10.2 million in energy bill savings through guaranteed £300 annual bill savings per household for 34,000 homes
- £26-34 million reduction in NHS costs incurred by the clinically vulnerable, low-income cohort living in excessively cold homes
- £40-60 million in wider social benefits, through lower care and support pressures, plus improved wellbeing outcome
Over the life of the measures, this could equate to a societal return of approximately 3 to 5 times the original public investment.
The role of Energy Market Participants and DNOs
Secondly, we see significant long-term potential in the roles of Energy Market Participants and network operators within future delivery models.
As the sector moves towards ED3 (Electricity Distribution 3) and a more decentralised energy system, we increasingly need to view domestic retrofit and low carbon technologies not simply as consumer upgrades, but as part of wider energy system infrastructure.
The interaction between homes, flexibility, vulnerability, local networks and demand-side response is likely to become one of the defining strategic questions of the next decade.
Shaping the future
At AgilityEco we’re engaging with government and industry stakeholders as we prepare to submit our full response to this consultation. We remain fully committed to helping shape the future structure of the Warm Homes Plan and wider retrofit market.
