Reforming consumer protection for Home Upgrade Schemes - response to DESNZ consultation

From 17 June 2026 to 10 September 2026, the government consulted on reforming consumer protection for Home Upgrade Schemes. This consultation sought views on how the consumer protection system for home upgrades should be reformed to support delivery of the Warm Homes Plan.

The NHF is supportive of improving protections for consumers in a way that streamlines support and reduces fragmentation, especially in light of the National Audit Office report which found serious, systemic failings with installations under government funded schemes (with 98% of homes that received external wall insulation having major faults requiring remediation). While the report found that the Warm Homes: Social Housing Fund (WH:SHF) had significantly lower levels of non-compliance, we recognise the importance of a joined-up consumer protection scheme which improves sector performance and public confidence in retrofit.

However, the consultation has limited detail about how the consumer protection scheme would work in practice. Depending on the detailed design, this scheme may have significant implications for how housing associations manage retrofit programmes. Outstanding questions remain around the roles of different system actors, how any new requirements will influence overall workforce capacity, and more technical details including additional reporting requirements and enforcement powers. As the scheme is proposed to be phased in from 2028, consideration will also need to be given to how this aligns with existing schemes such as the WH:SHF, alongside any new low-income grant scheme post 2028.

We would urge the government to consult further on the details of this scheme once the overall scheme principles have been established. This will ensure that reforms do not create disproportionate barriers to delivery at a time where housing associations are being asked to significantly scale retrofit work.

The NHF does not hold a position on the majority of the questions in the
consultation, relating to broader consumer protection landscape. As such, this consultation response only responds to select questions that are most relevant to social housing in England.

NHF members can log in to download our repsponse.