AgilityEco responds to Home Upgrade Consumer Protection consultation
22 September 2026
We’ve submitted our response to the UK Government consultation which proposes stronger consumer protection for home energy upgrades under the Warm Homes Plan.
We agree that reform is necessary. Having a trusted framework for programme delivery is crucial for building customers’ confidence and increasing their participation, as well as supporting long-term growth in the retrofit market.
Our experience means we know that consumer protection depends on robust national standards paired with effective, locally attuned delivery. In our view, the following principles should underpin the new consumer protection framework.
Preventing problems before they arise
We believe that stronger governance and accountability across the delivery chain will ensure consistent quality assurance and risk management, preventing failures rather than simply improving how complaints are handled.
A clear division of roles
While we agree that the proposed Consumer Protection Service should be the single point of contact for consumers, we believe that the interpretation of technical standards should sit separately, under a single authoritative technical body within the framework, to ensure consistent compliance decisions.
Delivering capability AND competence
The Government should recognise that organisational capability is just as important as individual technical competence.
Organisations delivering publicly funded retrofit should demonstrate robust governance, quality management, consumer protection processes and financial resilience alongside technical compliance. This will strengthen confidence that they can consistently deliver positive consumer outcomes.
For these reasons we encourage DESNZ to require that organisational capability and technical compliance are audited independently, as a condition of participating in publicly funded retrofit schemes.
