Building trust: improving the reliability of installers in sustainable home heating

Executive Summary

Over the next two decades, households across the UK will have to make significant changes to the way that they heat their homes. 

These changes will require some costly and complex decisions often involving technologies that consumers have limited experience of, including new heating systems, insulation measures, and solar panels. The result will be warmer and more comfortable homes, lower energy costs and a significant contribution to cutting the UK’s carbon emissions. These are all things that many consumers will support, however getting from where we are now to where we need to be will be challenging.

A critical part of the process will be ensuring consumers have access to qualified and reliable tradespeople that can install these products in their homes. Currently there is a major shortfall in the number of qualified installers available and this will need to be addressed by giving companies the confidence to invest in training and having the right apprenticeships and courses available. However numbers are not the only issue, consumers will also need to be assured that installers have the appropriate qualifications and skills, and the right consumer protections are in place covering every aspect of the journey from marketing, to contracting, to after-sales support, and including resolving any complaints or disputes that arise.

Which? research in the wider home improvements sector shows that consumers often struggle to identify tradespeople that they trust to get work done in their home. Which? research [1] found that 42% of consumers find it hard to know what experience or qualifications to look for or check when looking for a trader in the home improvements sector, and 55% of consumers say they find it hard to trust trader information, including traders' own claims and customer reviews.  As a result the process of choosing a tradesperson can cause significant anxiety and in some cases cause householders to delay important work. This problem may be particularly acute in the green heating and insulation sectors where press stories about poor work and rogue traders have left consumers concerned about the risks of poorly installed insulation, problems caused by damp and mould, difficulties when trying to sell their property or simply being ripped off by fraudsters.

Since 2020 the government has taken action to ensure that assurances are in place when households have work done that is funded by either the Energy Company Obligation scheme [2] or a government funded scheme. In these cases insulation installers must belong to the TrustMark certification scheme, and installers of clean heating and micro generation must belong to the Microgeneration Certification Scheme (MCS). Both schemes require their members to have the relevant technical qualifications and abide by a consumer code. Whilst more can be done to ensure these schemes are working effectively, there is a structure in place and work is underway to deliver improvements and address problems where these have been identified.

In contrast, householders that are self funding work to their homes do not have the same protections. These consumers have very little guidance as to which installers they can trust to do work in their homes. In these circumstances, Which? research shows that many consumers who are getting more traditional jobs done, such as fitting a new kitchen or bathroom, resort to tried and tested methods such as asking friends and family for recommendations, however in a new market this tactic may not be as useful as fewer households are likely to have had experience of this sort of work. 

Alternatively householders may choose installers on the basis of third party accreditation, however this can require lengthy research. Currently, a consumer that is looking to get insulation or a new heating system installed, and is looking for some form of third party assurance, is faced with a bewildering variety of different certification schemes, accreditation schemes, certification bodies, review sites, consumer codes, trade associations and directories. In many cases, installers will belong to several schemes or organisations, some of which will relate specifically to insulation or low carbon heating, and others which may be more general.

In a recent report, the Competition and Markets Authority expressed a concern about the ‘emerging gap in consumer protections for Able to Pay households’ and called on the government to conduct a review of the current landscape and consider the introduction of mandatory Alternative Dispute Resolution (ADR). ADR is a process provided by a third party that enables traders and consumers to resolve a dispute without having to go to court.

Addressing these gaps in consumer protection is not only necessary to protect consumers from the immediate harm caused by poor work, but also to address a barrier that will prevent the UK upgrading its homes with all the health, comfort and environmental benefits that will deliver. 

In order to ensure consumers are effectively protected, the government should:

• Set a date by which all tradespeople that install low carbon heating, micro generation and insulation are certified by MCS (for low carbon heating and micro generation) or TrustMark (for insulation) and ensure that these schemes are focused on delivering good consumer outcomes and abide by the CMA’s Good Practice Principles for Standards Bodies.
  We have recommended MCS and TrustMark as the government currently endorses these schemes for work that is supported by the ECO scheme or government funding. This is a pragmatic approach that will avoid the creation of new structures and systems that would delay the impact of reform at a time when rapid progress is needed to meet government targets for more sustainable home heating.
• In advance of this date the government should clearly recommend that consumers use installers that are members of these schemes. This should be supported by marketing and working with other businesses and organisations (including manufacturers, banks, energy companies and One Stop Shops) to raise consumer awareness of the schemes.
• The government should be responsible for the oversight of both schemes in order to maintain standards and ensure the costs of certification are reasonable and don’t create a barrier to companies entering the market.
• Consumers may choose to use online platforms to find installers, but they should look for installers with MCS and TrustMark certification, and the platforms should ensure tradespeople offering this work are certified.
• The government should conduct a fundamental review of Trading Standards Services to ensure the appropriate balance of resources and skills at central, regional and local levels to effectively tackle rogue traders, including necessary consumer awareness campaigns, intelligence-sharing and effective regulatory powers.

Introduction

In order to support the transition to net zero and improve energy security, the UK and Scottish governments have made a number of commitments that will require significant changes to the way consumers heat their homes.  These include:

UK government

• An ambition for all homes to have an Energy Performance Certificate rating of C or above where cost-effective, affordable, and practical by 2035 [3]. This will demonstrate that the property has a certain level of energy efficiency. The target for fuel poor homes is 2030.
• A ban on the installation of new fossil fuel heating systems by 2035, excluding up to 20% of households who will struggle the most to make the switch to heat pumps or other low-carbon alternatives [4].
• An ambition to install 600,000 heat pumps a year by 2028 [5].

Scottish government

• An ambition for all owner occupied homes to have an EPC rating of C or above where cost-effective, affordable, and practical by 2033. Private rental properties should meet this target by 2028.
• A proposal to ban the use of fossil fuel heating from 2045 and a requirement to end the use of fossil fuel heating within a fixed period after the sale of a property [6].

In order to meet these targets, households across the UK will need to make significant changes to the way they heat their homes and use energy. Central to these changes is the need to phase out the use of fossil fuel heating systems and switch to low carbon heating, which for most households is likely to be a heat pump. Many households will also want to take this opportunity to consider the insulation of their homes, as a better insulated home will enable their new heating system to work more efficiently. Improved insulation will also reduce heating costs for householders, improve the comfort of their home and support householders in taking advantage of more flexible energy tariffs. They may also want to consider solar panels or solar heating as a way to generate their own energy.

It will be particularly important for consumers to be able to find qualified and reliable installers as it is often choosing the right products for the property and installing them correctly, rather than the products themselves, that is the critical issue in getting an energy efficient home with a heating system that works effectively and efficiently. 

In order to meet government targets for improving the energy efficiency of homes and installing heat pumps, the number of installers will need to increase dramatically. As Which? research has demonstrated, there is a need to increase the overall number of installers and ensure there are installers available across all regions of the UK. However it is not only a question of numbers; consumers also need to know that the people they employ to install insulation, heating and microgeneration are reliable and that their work will meet high standards.

The consumer impact of poor protection

Many households that get insulation, micro generation or new low carbon heating installed have a positive experience and there is evidence that consumers that have had new heat pumps installed are as satisfied or more satisfied, with their new heating system as they were with their old one. However, for a proportion of households the experience is less positive and these households can face the inconvenience and financial cost of having to get work put right. When poor work results in a loss of heating or hot water or damage to the fabric of a home this can be particularly stressful - especially for vulnerable groups such as the elderly, people with a health condition, or families with young children.

Difficulty finding a qualified and reliable installer

Before any work is done on a home, consumers have to choose a tradesperson and there is evidence that many find this process difficult and stressful. 

Which? research [7] in the wider home improvement sector found that 42% of consumers find it hard to know what experience or qualifications to look for or check when looking for a trader. In addition, 55% of consumers say they find it hard to trust trader information, including traders' own claims and customer reviews. In the same survey [8] we found that more than eight out of ten (84%) consumers who have chosen a trader, experienced emotional harm in the form of worry or anxiety about choosing the trader, with almost a third (32%) saying that they experienced a high degree of worry [9]. 

“I don't have many people to ask & don't really trust or feel comfortable with leaving my details online. Trying to find TRUSTWORTHY, DECENT & CAPABLE tradespeople whatever the job, is a considerable concern and all my older friends are of the same opinion.”

“dread of something going wrong … needing fixing  and having to find a decent person to sort it out - can make home owning seem quite a burden at times.”

“I hate, hate, hate having to find a trader – can’t rely or trust any of them.”

Difficulties sourcing trustworthy information not only makes trader selection overly difficult, stressful or time-consuming, but also leads to“choice avoidance” which can create other types of harm as jobs that need doing are put off creating a risk of a problem worsening. An obvious example in this case is a householder delaying the replacement of an old boiler until it breaks down completely and has to be replaced quickly.

In our 2021 home improvements survey we found that more than four out of ten (43%) consumers said they had at some time put off employing a trader to do a job that needed doing and one in four (23%) had put off a job specifically because of worry or anxiety about employing a trader to work in their home. For some (8%) this was a concern about the idea of having a stranger in their home, but for many more (20%) it was worry about employing someone who would “let them down” or “rip them off” [10]. This is in line with findings from research conducted by other organisations.

The impact of poor installations

Consumers face additional harm when work is done poorly. Our 2021 survey asked consumers about jobs completed in the previous 12 months. Within this survey 29% of consumers who had employed a trader to do an energy efficiency job reported a trader-related problem with their job [11]. Problems experienced by consumers included issues with the quality of the job (13%), problems with pricing or terms of agreement (11%), behaviour or reliability (12%) and failure to fix problems (12%). 

Of those that had experienced some difficulty, in 87% of cases this resulted in some form of consumer harm. In 46% of these cases it resulted in spending extra time to get the job done well and in 41% it resulted in the householder having to pay out more money to get the job done well. Other harms included the emotional cost of resolving the issue and feeling less confident about employing a trader in the future. 

Problems arising from poorly installed insulation can include mould and damp. In the case of new heating systems households can be deprived of heating and access to hot water, sometimes for several days before the issue is resolved.

Complaints arise when an installer fails to resolve an issue that they are responsible for. Failure to fix problems can be exacerbated by the difficulty of holding a trader to account for the quality of the work they have done. 

“An inverter was installed in 2017 with a 10 year warranty. It stopped working in 2022, and I asked the company that installed it to repair it. Not only would they not come out for several weeks, but they wanted to charge more than the value of the inverter.” [12]

In some cases this is still the case when the trader is signed up to a consumer code. Companies in this sector are able to sign up to consumer codes through organisations such as RECC (Renewable Energy Company Code) or HEIS (Home Insulation and Energy Systems Quality Assured Contractors Scheme) that vet their members and conduct annual audits to ensure they follow good consumer protection practices.

“The plumber who installed our air source heat pump, we discovered retrospectively, is a member of the renewable energy consumer code. They should’ve told us this at the time of our contract but they didn’t. We are currently involved in a protracted complaint procedure to seek a resolution about the poor performance of the system.    So far the complaints procedure is  making only very slow progress.  I don’t have much confidence yet that it will help us get a better result for our investment.” [13] 

Consumers can also struggle to hold a trader to account if the company they originally contracted has gone out of business or been bought out by another company. This may be an issue that is experienced more frequently in insulation, home heating or solar installations because some time may pass before the householder is aware that there is a problem. 

“I have an air source heat pump and a mechanical ventilation system made by little known manufacturers (little known in the UK). When my original installer stopped trading I was left to search for alternatives. I first googled the manufacturer websites, and then used the broader terms MVHR / ASHP services. I went through the responses contacting each in turn to see if they were able to do the servicing. I found that the majority understandably prefer to service their own installations. The ASHP service was eventually undertaken by an Air conditioning engineer. For the MVHR one company declined the work themselves but were happy to recommend someone to me and this worked out satisfactorily.“ [14]

"We had them fitted years ago through a government scheme, however the company was taken over by another company who are not registered with mortgage companies so now we cannot sell, remortgage our home! I wouldn’t recommend doing that…" [15]

Recently there have also been media stories about consumers having to have insulation removed in order to sell their house or release equity from their home. This is often an issue with spray foam insulation. 

Finally, poor work can lead to negative media coverage that further increases households anxiety about getting work done, and in the case of government schemes, can deter policy makers from promoting interventions out of concern that work will not be done well. 

Choosing an installer

Consumers that get insulation, micro generation or low carbon heating installed are protected by consumer protection legislation which covers the quality of the work and the interactions between the consumer and the installer. The Consumer Rights Act 2015 has clear rules requiring companies to provide services with reasonable care and skill and as agreed. If this is not the case then the trader should redo the work at no extra cost and in reasonable time. If this isn’t possible a consumer should be able to claim a price reduction that could be up to 100% of the cost. The Act also allows consumers to challenge unfair terms in contracts. In addition, the Consumer Protection from Unfair Trading Regulations 2008 prohibits companies from misleading actions or omissions, or aggressive practices in the marketing of their products and services.

All new insulation and home heating work should also meet the requirements of the building regulations as set out in Part L of Schedule 1 to the Building Regulations. Ultimately the owner shares responsibility with the installer for ensuring that the work meets building regulations [16]. Most local authorities recommend that homeowners have a contractual agreement with their installer that requires the installer to be responsible for submitting plans, arranging building control inspections and ensuring the work is signed off. Installers that are members of a competent person scheme do not need their work to be inspected and signed off (see below).

However, despite these legal protections, consumers can still be exposed to harm if the installer lacks the knowledge and skills to do the job well, or if they are unscrupulous in their treatment of consumers. Householders may also not be aware of their rights or the requirement that work meets building regulations. This is particularly important as, in the insulation and low carbon heating sector, anyone can set themselves up as a business and start advertising their services. 

Why is finding a qualified and reliable installer difficult?

In order to find good quality products and services, consumers often have their own strategies. These strategies are practical ways for consumers to minimise the risk of being caught out and improve their chances of getting the product or service they want at a good price. However the characteristics of this market can frustrate even these strategies.

Which? research into consumers' experience of selecting tradespeople to do work in their homes has found that word of mouth recommendation remains by far their preferred method of finding someone they can trust. This is despite a proliferation of schemes purporting to help them find someone reliable. For instance, in one 2021 study we asked more than 3,500 consumers how they had first found traders they had employed in their home over the preceding 12 months. We found that almost half (49%) of all the traders they had employed had been found originally via word of mouth recommendation (in person or via social media) [17].

These recommendations can be useful, however there is always a risk that the trader may not have qualifications or experience relevant to the job they are being asked to do - for example a tradesperson that instals boilers may not know about new heating systems, and a general builder may not be aware of ventilation requirements for insulation. This is particularly likely in this sector as low carbon heating and some insulation measures are still relatively unusual. A recommendation from a friend or family member that has had a positive experience also may not inform the consumer about how the tradesperson deals with complaints or manages a dispute, should that arise. 

Choosing a good tradesperson is particularly difficult in sectors where consumers lack prior experience and knowledge, or where the complexity of the job makes it difficult for the consumer to engage with tradespeople and make an informed choice. For example:

• For many years consumers have tended to replace their old heating system with a new version of the same. In the future it is expected that most households will make the switch to a heat pump, however this is not the only option and in some cases moving to a heat pump straightaway may not be the best option depending on the household's circumstances. Currently it is relatively difficult to get independent advice on these options and most installers will have their own technology preferences.
• The installation of insulation and heating systems are infrequent purchases that most householders will probably only make once or twice in their lifetime. In the case of a new low carbon heating system, such as a heat pump, a consumer will almost certainly have no prior experience about the product and its installation, and there will be a considerable imbalance between the knowledge of the installer and the householder.
• The installation of low carbon heating tends to be relatively complicated as the standards require installers to meet higher energy efficiency standards than those which have been applied to fossil fuel heating systems such as gas or oil heating. This means that an installer has to take heat loss measurements around the property and ensure that the insulation, the size of the radiators and the size of the heating system are sufficient to enable the system to work efficiently and keep the home warm and comfortable. This can require trade offs between the different elements of the system, decisions about whether to phase in some of the changes over a period of time and liaison between different trades.
• The technology can also be quite new to installers. Whilst a lot of the technology in low carbon heating systems, such as heat pumps or solar panels, has been in existence for many years and used in the UK and different countries, there is a lot of innovation in the market as industry seeks to find new ways to further improve efficiency and make the technology suitable for a wider range of properties. This can create challenges for installers and households if they are unable to keep up with developments.
• For the time being, households are also likely to have a restricted choice of installers due to shortages in the number of skilled and qualified installers available. The heating and insulation sectors are also dominated by small companies  with 80% of businesses in this sector being micro enterprises with one to three employees [18]. As a result consumers don’t always have the option of using large, well known companies that may confer more confidence in consumers.

Third party endorsements

Another common way for markets to overcome the imbalance in information and knowledge between consumers and sellers, is for an independent third party to review products and services and recommend those that consumers can trust. The endorsement acts as a signal of quality to consumers [19] serving to reduce the information asymmetry that exists otherwise. The consumer can then shortcut the lengthy and uncertain process of doing their own research by restricting their choice to those products or services that are certified. This is particularly useful in a market where consumers face multiple barriers to making an informed choice independently.

Third party endorsements vary considerably however from a consumer’s point of view, they are likely to want assurance in three areas:

• The work will meet relevant technical standards,
• The installer will respect consumer protections,
• The scheme will conduct rigorous auditing to ensure its members are compliant with the schemes rules.

Technical standards

Traders that are members of a competent person scheme can self certify work they have completed. This means that any insulation or low carbon heating that they install is certified as meeting Part L of the building regulations without being checked by building control. Installers must have the relevant qualifications and an established track record of good work, and must have insurance-backed warranties and established procedures for handling complaints. Installers join Competent Person Schemes by applying to scheme providers that vet their initial application and then conduct regular audits to ensure that members of the scheme continue to deliver good work. 

In a written statement the government has said that it intends to review the requirements (known as the conditions of authorisation) that a scheme provider must meet to be authorised as a competent person scheme. There is a potential risk from having multiple scheme providers offering competent person schemes as the providers could compete for members by making their audits less robust or reducing costs which may also affect the quality of audits. This underlines the importance of having strict oversight of schemes to maintain high standards. 

The number of scheme providers can also cause confusion amongst consumers. A consumer faced with quotes from different installers may want to research the schemes each installer belongs to in order to assess any differences between them. For example, there are at least six scheme providers that provide certification for cavity wall insulation. The same schemes, plus one more, also provide certification for internal wall insulation. 

In addition to the statutory requirements that are set out in Building Regulations, schemes can also require members to adopt additional standards. For example, insulation installers could be expected to meet the PAS 2030 standard for energy efficiency measures or the PAS 2035 standard for whole house retrofit. Installers of microgeneration or low carbon heating can be expected to meet the relevant MCS standards.

Consumers are also reassured if installers have a catalogue of previous work and satisfied consumers, but it is important that any such reviews are from verified customers. 

Consumer Protections

In addition to the technical standards that an installer should have it is important that the installer is also committed to following a comprehensive consumer code that ensures that the consumer is treated fairly. This should include and go beyond the legal requirements set out in consumer protection legislation [20] and is critical in preventing harm and resolving disputes should a problem arise. 

• Marketing and communication. From the first contact between a trader and consumer it is important that marketing material and any discussions are honest and clear. The CMA has highlighted practices including the use of pricing in marketing that is not a realistic estimate of likely costs, examples of exaggerated savings and prices that include reductions that are based on the availability of grants without making this clear. 
• Contracts. Consumers should also receive contracts that clearly set out the work and prices that have been agreed, as well as the timetable and any additional responsibilities. There is considerable evidence from consumer complaints that some providers in the home improvements sector are resistant to providing consumers with written contracts, or they use vague contracts with unclear or unfair terms and conditions, hide extra charges or costs in small print, and use unnecessarily complex terminology. There is some evidence that similar practices are also found in the green heating and insulation market.
  In some cases this may be a reflection of a trader's lack of knowledge and understanding rather than an intention to cheat or fool the householder, however if a contract has gaps or there is a lack of clarity this can lead to problems for both parties.
• After sale services. This includes provision of appropriate warranties, guarantees (including ‘insurance backed guarantees’ in case the business stops trading) and servicing plans. Providing support to consumers after the installation of a heating system, for instance to ensure it is properly calibrated, is important but there is evidence of ‘add-ons’ or items that are ‘upsold’ to the consumer which are not always necessary or not what they seem. Examples include overly long maintenance contracts [21] for low carbon heat systems that are hard to get out of, and unnecessary tech add-ons for green energy products [22].
  Should a trader go out of business or refuse to complete work or rectify problems the scheme should have mechanisms for ensuring the problems are rectified and work is completed promptly to the consumer’s satisfaction.

Auditing and compliance

There can be significant differences in relation to how rigorous schemes’ auditing and enforcement processes are, including the level and number of checks that are carried out and whether there are back office assessments and/or on site assessments. If a consumer is unable to resolve a complaint with a trader, schemes will also vary considerably in their ability to investigate the issue and support the consumer in accessing alternative dispute resolution if it is available. Due to the lack of standardisation and transparency in this area, it can be difficult to understand what level of auditing and enforcement schemes have. 

Customer reviews are another aspect of the landscape with several schemes and platforms giving customers the opportunity to leave a review which can then inform subsequent customers. It is important that the scheme verifies that reviews are left by genuine customers. Verified reviews can be an important tool alongside other checks however schemes should not outsource the important job of verifying the quality of installers work to previous customers. 

Where an installer doesn’t meet the standards set out by the scheme they should be removed from the scheme and if an installer fails to rectify a problem the scheme should have processes in place to hold them to account and ensure problems are rectified and the work is completed to the consumer’s satisfaction.

Why third party endorsements aren’t solving consumers’ problems 

A confusing choice

Consumers are more likely to use third party endorsements when information about the endorsement is easy to access and understand. This requires consumers to be aware of what to look for and for this information to be easily found [23]. Unfortunately in the low carbon heating and insulation sectors neither of these conditions exist. 

Currently, a consumer that is looking to get insulation or a new heating system installed, and is looking for some form of third party assurance on which installer to contact, is faced with a bewildering variety of different certification schemes, accreditation schemes, certification bodies, review sites, consumer codes, trade associations and directories. In many cases, installers will belong to several schemes or organisations, some of which will relate specifically to insulation or low carbon heating, and others which may be more general. 

Some of the different schemes, organisations and platforms include:

• Competent person schemes: a govt scheme allowing traders to self certify work without getting building regs approval. The trader must be certified by one of 17 schemes.
• Certification bodies: responsible for assessing and certifying trades for a fee paid by the business. 
• Consumer codes: Chartered Trading Standards Institute approved consumer codes. Members follow strict codes of practice covering interactions with consumers, provide insurance backed guarantees and access to ADR.  
• Code of Practice: BSI PAS 2035 is a code of practice for insulation work, but traders may also display other standards that are related to other sectors that they work in.
• Guarantee Agency. Provide insurance backed guarantees. 
• Trade Associations: Voluntary associations that do not provide any assessment, but may offer a directory of members.
• Directory websites: The level of checks and accreditation varies considerably. Reviews are sometimes available.

Weak or missing protections

A lack of clarity for consumers can lead to confusion about what safeguards, if any, a trader’s membership of any given scheme, organisation or platform offers. In some cases a trader’s membership of an organisation may not convey any guarantee in terms of technical qualifications or consumer protection, because that organisation was not set up with that purpose. However a consumer that only sees the name of a scheme or the scheme’s logo on the traders website or van would not necessarily be aware of that. In other cases installers are certified under schemes that primarily focus on the necessary technical qualifications and skills and provide limited assurance in relation to consumer protections. 

A consumer that is looking for assurance about the qualifications and reliability of a tradesperson would have to undertake considerable research to understand what the different schemes, organisations and platforms offer in terms of both the standards they use and how robust their processes are for ensuring their members meet these standards. There is no standard way in which protections are set out or described, and it can be difficult to piece together the information that is made available.

The costs of certification

Good quality certification of installers requires effective vetting and auditing which incurs costs, but it is important that the costs of certification are reasonable so that installers see certification as a good investment for their company and the reputation of the sector, and to ensure that excessive costs are not passed on to consumers.

The fact that the government requires installers to meet Building Regulations and has a building control service and the competent person scheme to ensure that standards are met is recognition that there is a cost involved in ensuring work meets the relevant standards. Where higher standards are required it is important that these are proportionate and relevant to the measures that are being taken. For example, there has been some debate as to whether the rigorous assessments that are required for a whole house retrofit should be required for a relatively straightforward job such as loft insulation. 

Schemes have sought to find ways to make it easier for installers to achieve certification through the development of more proportionate standards or through schemes that allow installers to operate under the guidance of a scheme member that also takes responsibility for the work. 

Certification in the ECO scheme and government funded programmes

In contrast to the complex landscape that consumers have to navigate if they are funding work themselves, all government funded work in this sector, and work that is undertaken under the ECO scheme, is subject to a more straightforward approach whereby all installers are required to be registered with either the Micro Certification Scheme (MCS) for low carbon heating and solar installations, or with TrustMark for the installation of insulation. Some financial providers also require that any work that is funded by their loans or that benefit from their incentives must be done by MCS and TrustMark certified installers. This helps to reduce the risk of the loan becoming a failed investment.

The benefits of this approach are that all installers meet relevant technical standards, follow consumer codes, provide insurance backed guarantees and offer access to ADR in order to resolve any disputes that may arise between the installer and the consumer. 

• MCS develops standards and provides certification for installers of low carbon heating and micro generation. Members must follow relevant MCS standards covering the installation of low carbon heating and micro generation and be a member of one of the consumer codes. Members are audited by certification bodies on behalf of MCS. MCS is owned by the MCS Foundation which is a charity. MCS is currently undergoing reforms that aim to reduce complexity and “reset the Scheme’s consumer protections to give people the confidence that they need to engage with small-scale renewables.”
• TrustMark is the government endorsed certification scheme for tradespeople offering services around the home, including companies installing insulation. The scheme has more than 15,000 registered businesses. Similar to MCS, TrustMark requires members to be a member of a consumer code. Members must also be a member of one of the 35 TrustMark scheme providers that are responsible for auditing companies on behalf of TrustMark.
  For the installation of insulation the main scheme provider is the Installation Assurance Authority. Installers must be PAS 2035:2019 certified, or meet TrustMark Licence Plus requirements. PAS 2035 is required for ECO or government funded work. TrustMark Licence Plus was introduced for work that households are self funding and is positioned as a transition towards the higher PAS 2035 standard. It uses the key principles of a ‘whole house’ approach but with less onerous requirements that aim to make it accessible to more installers and also help to reduce costs.

Work in progress

As noted above, the requirement for all work that is funded by the government or by the ECO scheme to be done by Trustmark and MCS certified installers has a number of benefits, however the complex web of organisations and bodies that are used to deliver the schemes, including scheme providers, certification bodies, consumer codes and organisations providing insurance backed guarantees, can create issues with oversight, and the quality of the overall consumer experience. It also adds to the plethora of organisations and logos that create consumer confusion in this sector.

MCS has recognised some of these challenges and has consulted on proposals to reduce complexity and improve the quality of the services offered [24]. As TrustMark covers many more trades than MCS it is unlikely to be able to follow the same path as MCS. 

In 2023 the Competition and Markets Authority conducted a Call for Information on the Green Heating and Insulation sectors. The report focused specifically on certification schemes and codes operating in low carbon heating and insulation sectors and therefore didn’t include some of the other online platforms, accreditation schemes and trade associations that consumers may also consider when looking for an installer. However even within the area that the report focused on, the CMA found that the standards landscape was not working as effectively as it could: 

• The standards landscape is complex and confusing, with low consumer awareness. 
• The level of protections vary in some important areas, such as compliance monitoring, leading to a risk of poor outcomes for consumers.
• Complaints management processes are unclear and confusing, with no simple route for people to raise complaints if they have a problem. 
• Limitations of some post-installation financial protections provided by standards bodies where a business ceases to trade. 

Alongside the publication of their findings, the CMA published good practice principles that standards bodies in the sector should follow, and guidance to support consumers and businesses. Several schemes have responded to the best practice principles by publishing assessments of how their policies and practices align with the principles and the CMA is continuing to work with schemes and publishes updates on the progress that is being made. The update notes that the certification schemes cannot address all the consumer protection concerns in the sector and that the CMA is continuing to work with the government on these issues.

Given that the focus of standards bodies work should be the improvement of consumer outcomes, in addition to the principles and guidance set out by the CMA, it is important that they also demonstrate a clear commitment to consumers through their structures and processes. This can be achieved through engagement and input from consumer representatives as well as the transparency of their processes, board level responsibilities and investment in understanding consumers’ experience of the sector and their services.

Tackling rogue traders

Rogue traders and scammers are a particular concern in the home improvements sector. This can increase consumers’ anxiety when looking for an installer, and when consumers are tricked into using a rogue trader the damage and emotional and financial harm can be considerable. 

Energy-related scams are a well established area of fraud with scammers taking advantage of consumers' concerns about energy bills and keeping warm in winter [25]. National Trading Standards address energy related fraud as part of its work on doorstep crime and cold calling and recorded 10,762 energy related fraud events in 2022/23. They have also noted that other agencies were receiving increasing numbers of complaints in this area.  Fraud covers a wide range of practices, and can include installers delivering work that falls below the standards promised and failing to rectify it, and the mis-selling of supplies and products (e.g. roof and wall coatings) including misrepresentation of products with false energy efficiency and environmental claims. There have been widely reported examples of the mis-selling of spray foam loft insulation and solar panels. Spray foam insulation was the second most common topic of nuisance calls in 2023 according to call blocking device provider trueCall. Solar panels are also the focus of several types of scam. These scams can involve relatively large companies with the impact felt across hundreds of households. The traders generally target vulnerable groups with cold calling and use pressure selling techniques. They have even tricked consumers into taking out loans in order to pay for the work. 

Fraudsters often take advantage of government initiatives or media stories, such as local stories about solar panel fires. Citizens Advice estimated that in 2021, 19 million adults in the UK had been targeted by a green scam and an estimated 5.2m actually fell for a green scam.A survey of Which? members that had solar PV panels installed revealed that 53% had been contacted by cold callers who had offered them services such as a free ‘health check’ or told them that their solar panels needed work such as an inverter changed [26]. The tendency of scammers to jump on any form of government promotion or media attention to trick consumers is a particular concern given the likelihood that there will have to be a considerable public awareness raising campaign in order for the UK to meet its targets in this area.

Trading Standards Services in England, Wales and Scotland have responsibility for enforcement against rogue traders, and in Northern Ireland this is the responsibility of the NI Trading Standards Service. In Scotland, Trading Standards Scotland also has resources to look at particular national challenges and has prioritised this area. Approaches differ between services and over time, but they typically use consumer awareness campaigns, investigations and enforcement to tackle traders that are operating illegally. 

Consumer awareness campaigns such as ‘Turn Down Energy Scams’ that was launched by Trading Standards Scotland in 2023 can raise awareness of the techniques scammers use and highlight sectors where scams are prevalent, such as spray foam loft insulation which was a focus in the TSS campaign, as well as a Wales Against Scams campaign organised by a coalition of organisations (including Trading Standards) in Wales. Awareness campaigns such as these can help to empower consumers and reduce the number of scams but the campaigns need to be sustained and responsive, as scammers can quickly change tactics. 

However a combination of local prioritisation decisions, a lack of relevant skills within Trading Standards Services and poor resourcing of local authorities constitutes a major risk to this area of work. As the number of trading standards officers has decreased, the service lacks the resources to investigate cases. Prosecutions can also be difficult to pursue due to a lack of resources in local authorities. Where prosecutions are successful, Trading Standards can ask the court to make an order requiring traders to pay compensation to victims. Trading Standards can also take action in the civil courts, by applying for an enforcement order against a trader. Again, this can also include a requirement for compensation to be paid to consumers. However, Trading Standards cannot themselves order traders to provide redress to consumers, or take court action on their behalf. 

Reform of the landscape

The lack of consistent and effective consumer protection in the home heating and insulation sectors has been the subject of a number of proposals in recent years, however to date none of them have been implemented in the self funded market. 

In 2016, the ‘Every Home Counts’ report set out the findings from an independent review commissioned by the government. The report made a number of recommendations including the introduction of a Quality Mark that would include a Consumer Chapter, a Code of Conduct and Code of Practice as well as an information hub, and making training more widely available. The government has implemented these changes for work that is funded by the ECO scheme or a government funded scheme, but has failed to address these issues for households that are funding work themselves.

In 2020 the government consulted on a proposal to make ADR mandatory in the home improvements sector that would include home heating and insulation. The government’s proposal was based on criteria including: 

• the nature of consumers: potential vulnerability of consumers
• the nature of the purchase: complexity, value, incidence, competitiveness 
• the consumer experience: consumer confidence/trust, level of complaints 
• alternative routes: availability and effectiveness of other types of consumer protection/enforcement

The government’s analysis included a ranking of consumer sectors against the comparability of offers, trust in businesses to respect consumer protection rules, the extent to which markets live up to consumer expectations, choice of retailers/suppliers, and the degree to which problems are experienced in the market cause detriment. The home improvement sector ranked only second to the real estate sector in the problems that were identified.

The industry has also made recommendations for improving standards across the construction sector. In 2019 a cross industry licensing task force led by the Federation of Master Builders was established to make the case for mandatory licensing in the construction sector including home repairs and maintenance. The taskforce called for a mandatory licensing scheme covering all legal entities including sole traders and micro enterprises that would require members to have technical qualifications and follow a consumer code. As evidence it cited examples of similar schemes in Germany and part of the US and Australia. It also pointed to widespread support for the proposals amongst reputable businesses and the Chartered Trading Standards Institute has also supported the proposal.

As the government considers the structures that will be needed to ensure high standards are met in the insulation and low carbon heating sectors, it should seek to meet the following principles.

1. Consumers should be able to easily identify qualified and reliable installers through their membership of a scheme or schemes.

• The scheme or schemes should be easily recognised and differentiated from other schemes, codes etc. 
• The scheme or schemes should regularly audit and assess their members’ work, seek and act on consumer feedback, and take effective enforcement action.
• Consumers should be able to easily access support should an issue arise with their installer.
• The CMA good practice principles should be used to define a good certification scheme.

2. Installers that are a member of these schemes should:

• Have the technical skills and qualifications relevant to the work they advertise.
• Abide by a consumer code including all aspects of their work from marketing to aftersales.
• Ensure complaints are dealt with fairly and if a dispute cannot be resolved the consumer has access to an approved ADR scheme.
• Ensure all deposits and work is covered by insurance backed guarantees. The duration of the guarantee should be sufficient to cover the expected lifetime of the work and be valid even if the installer has gone out of business.
• Register all relevant jobs with the scheme in order for the consumer to be eligible for the protections offered by the scheme.

3. Government or an independent body should have oversight of the scheme or schemes. 

4. Better certification of installers will reduce the opportunities for rogue traders but it is still important that Trading Standards can effectively investigate and take enforcement action against traders that operate outside of the certification system.

There are several potential models for improving consumer protection in the home heating and insulation sectors. We have assessed the different approaches according to a set of criteria including clarity for consumers, the impact on competition and standards and the ability to deliver change quickly.

• Clarity for consumers. Any solution needs to be easy for consumers to understand. Many of the certification schemes and codes of practice in this sector were established to  raise standards and support consumers in choosing a trader that they can trust. However the complexity of the current landscape with multiple schemes and codes offering differing levels of protection means that most consumers are confused and potentially exposed to poor work and limited protections. 
• Competition and impact on standards. Competition drives both installers and schemes to improve the service they offer and maintain competitive prices. However, competition between schemes can also lead to confusion for consumers and, if it is the installer rather than the consumer that is choosing, this can lead to schemes offering lower costs and weaker standards to attract more members.
• Ability to deliver change quickly. Over the next two decades UK governments will be encouraging and potentially requiring most households to make changes to the way we heat our homes. In order to meet these targets, the number of installations has to start increasing rapidly. The government has set a target for 600,000 heat pumps to be installed by 2028. This means that any solution has to have the potential of being implemented quickly. 

There are a number of options for how the government could improve standards in these sectors, including:

Mandatory licensing for all sectors. A single licensing body with scheme providers covering each sector.

• Clarity for consumers: Very good, all legitimate companies would be licensed.
• Impact on competition and standards: there would be competition between schemes if there were multiple scheme providers but a potential risk to standards if providers compete for membership.
• Ready to go: No, it would require legislation and time to establish a UK licensing body and structures that cover the whole construction sector.

Quality Mark. The government awards a quality mark to those schemes that meet its criteria, providing consumers with a clear signal as to which schemes they should use. 

• Clarity for consumers: It will be easier for consumers to identify good companies, but some schemes and companies will continue to operate without a quality mark.
• Impact on competition and standards: there would be competition between companies and schemes, but it would require effective oversight to maintain high standards.
• Ready to go: No, there would need to be a strong oversight body, criteria, monitoring and enforcement.

Mandatory Sectoral Schemes. The existing government endorsed schemes for insulation and low carbon heating are made mandatory.

• Clarity for consumers: Very good, there would be two schemes but all companies in these sectors should be certified.
• Impact on competition and standards: there would be less competition between certification schemes therefore the government would need to ensure costs remain reasonable. 
• Ready to go: The structure exists, but legislation would be needed to make certification mandatory.

Ultimately there is also a need to address consumer protections in the wider home improvements market, and proposals for compulsory licensing of all trades in the construction industry should be considered. However, given the need to make rapid progress in the installation of low carbon heating, a practical approach needs to be taken to ensure consumers are protected. This approach should build on the structures that are already in place, but with a view to how they might fit into future reforms of the wider home improvements sector. 

Mandatory certification using the two schemes that are currently endorsed by the government would require legislation but it would require all installers to meet technical standards, follow a consumer code and offer complaint handling and alternative dispute resolution. It would build on existing structures. There is also some precedent for this approach as many consumers are already aware of the need to check gas boiler servicing is done by a GasSafe engineer.

Recommendations

For the UK to meet its ambition to meet net zero by 2050, the vast majority of households will need to switch from fossil fuel heating to low carbon heating. This has the potential to provide households with warmer homes, lower energy bills and major reductions in carbon emissions. In order to make these changes households will have to engage with a new and emerging market and the government has a responsibility to ensure protections are in place so that the work is done to a high standard, consumers are treated fairly and if problems arise they are quickly and effectively resolved. Currently standards are too often patchy and dependent on a consumer’s choice of trader and the certification schemes, codes or platforms they belong to. If something does go wrong there is often a lack of effective enforcement or consumer redress. 

We recognise that there is also a shortage of installers, particularly in some areas. The government should look to support the recruitment and training of installers by supporting training and apprenticeships and committing to long term support for the transition to low carbon heating as this will give companies the confidence to invest. However this is not simply a question of numbers; the government should also ensure that installers meet the necessary technical standards and are reliable.

In order to ensure consumers are effectively protected, the UK government should:

• Set a date by which all tradespeople that install low carbon heating, micro generation and insulation and  are certified by MCS (for low carbon heating and micro generation) or TrustMark (for insulation) and ensure that these schemes are focused on delivering good consumer outcomes and abide by the CMA’s Good Practice Principles for Standards Bodies.
  We have recommended MCS and TrustMark as the government currently endorses these schemes for work that is supported by the ECO scheme or government funding. This is a pragmatic approach that will avoid the creation of new structures and systems that would delay the impact of reform at a time when rapid progress is needed to meet government targets for more sustainable home heating.
• In advance of this date the government should clearly recommend that consumers use installers that are members of these schemes. This should be supported by marketing and working with other businesses and organisations (including manufacturers, banks, energy companies and One Stop Shops) to raise consumer awareness of the schemes. 
• The government should maintain oversight of both schemes in order to maintain standards and ensure the costs of certification are reasonable and don’t create a barrier to companies entering the market.
• Consumers may choose to use online platforms to find installers, but they should look for installers that have MCS and TrustMark certification, and the platforms should ensure tradespeople offering this work are certified.
• The government should conduct a fundamental review of Trading Standards Services to ensure that the service has the appropriate balance of resources and skills at central, regional and local levels to effectively tackle rogue traders, including necessary intelligence-sharing and effective regulatory powers.

Footnotes

[1] Nationally representative survey of 4,587 consumers in England and Wales who had employed a trader to do work in their home. Home Improvements Experience Survey conducted by Yonder, on behalf of Which?, July 2021  ↑

[2] The Energy Company Obligation scheme provides insulation and low carbon heating in low income homes. It is delivered by energy companies and funded by a levy on energy bills  ↑

[3] Heat in Buildings Strategy, UK Govt, Oct 2021  ↑

[4] PM recommits UK to Net Zero by 2050 and pledges a “fairer” path to achieving target to ease the financial burden on British families, UK Govt, Sept 2023  ↑

[5] Heat in Buildings Strategy, UK Govt, Oct 2021  ↑

[6] Delivering net zero for Scotland's buildings - Heat in Buildings Bill: consultation, Scottish government, Nov 2023  ↑

[7] Nationally representative survey of 4,587 consumers in England and Wales who had employed a trader to do work in their home. Home Improvements Experience Survey conducted by Yonder, on behalf of Which?, July 2021  ↑

[8] ibid  ↑

[9] We assess that consumer harm exists where worry or anxiety is associated with difficulties created at least in part by market forces, information deficits, an imbalance of power between consumers and traders that could be remedied, rather than where worry is a personal characteristic or tendency. For this reason we only identify consumer harm where a consumer also reports difficulties engaging in this market for practical reasons where an intervention (supply or demand side intervention) could make a difference – e.g. better consumer information/advice/support or changes in trader behaviour  ↑

[10] Nationally representative survey of 4,587 consumers in England and Wales who had employed a trader to do work in their home. Home Improvements Experience Survey conducted by Yonder, on behalf of Which?, July 2021  ↑

[11] Nationally representative survey of 4,587 consumers in England and Wales who had employed a trader to do work in their home. Home Improvements Experience Survey conducted by Yonder, on behalf of Which?, July 2021. Analysis of a subset of 237 energy efficiency jobs conducted in the preceding 12 months  ↑

[12] An example of the practices that Which? Trusted Traders staff are aware of in the sector. All negative reviews on the Trusted Traders site are followed up on by Trusted Traders staff  ↑

[13] Which? survey of 3,054 Which? members with experience of employing a trader in the preceding 12 months. Which? Connect Panel. August, 2021  ↑

[14] ibid  ↑

[15] ibid  ↑

[16] The Planning Portal, Failure to comply with planning regulations  ↑

[17] Nationally representative survey of 4,587 consumers in England and Wales who had employed a trader to do work in their home. Home Improvements Experience Survey conducted by Yonder, on behalf of Which?, July 2021  ↑

[18] ONS (2021) Construction statistics annual, Table 3.4a [accessed 8 July 2021]  ↑

[19] Chatterjee, S. (2020). Signalling Service Quality through Price and Certifications. Global Business Review  ↑

[20] Trading Standards provides guidance on the legal requirements and good practice that businesses should follow  ↑

[21] Lessons for net zero: What past energy efficiency and low carbon home improvement schemes tell us, Citizens Advice, 2020  ↑

[22] Home truths The challenge and experience of making home energy improvements , Citizens Advice, 2021  ↑

[23] David Dranove & Ginger Zhe Jin, 2010. "Quality Disclosure and Certification: Theory and Practice," NBER Working Papers 15644, National Bureau of Economic Research, Inc  ↑

[24] MCS scheme redevelopment consultation  ↑

[25] Rogue traders exploit energy fears, CTSI Nov 2022. TSS launches home energy campaign, TSS, Aug 2023. Which? reveals huge jump in energy-related scams as fraudsters seek to exploit cost of living crisis – Which?  Shocking scammers cash in on the energy crisis, Which? Money magazine, June 2022  ↑

[26] Survey of 1,255 Which? members who had previously told us they had a renewable heating system installed, June 2021  ↑

About

Which? is the UK’s consumer champion, here to make life simpler, fairer and safer for everyone. Our research gets to the heart of consumer issues, our advice is impartial, and our rigorous product tests lead to expert recommendations. We’re the independent consumer voice that works with politicians and lawmakers, investigates, holds businesses to account and makes change happen. As an organisation we’re not for profit and all for making consumers more powerful.

Citation

Our preferred citation for this publication is: Which? (2024), “Building Trust: improving the reliability of installers in sustainable home heating.”

This publication reflects the view of Which?. 

For further information, please contact advocacy@which.co.uk