ECO4 Escalation

Dear Minister,

ECO4 redress, fraud, and consumer protection — request for urgent meeting and escalation route

I wrote on 3 September 2025 and 10 September 2025 about serious harms following ECO4 installs. More than 20 working days have passed without a response. Please confirm whether DESNZ considers its complaints process complete so we may escalate to the Parliamentary and Health Service Ombudsman (PHSO). If no reply is received within 7 days, we will assume it is complete and proceed—though our strong preference remains to work constructively with DESNZ.

Why this matters now

The Ministerial statement this week offered little reassurance to many ECO4 victims—especially households with heat pumps facing higher bills and, in some cases, fuel poverty caused directly by ECO4. Lived experience gathered by Nature Society indicates systemic failure, rather than systemic failings.

Evidence of systemic problems

• Consumer protections are weaker than for a fridge freezer. No credit-card style protections or Financial Ombudsman cover; insurance/warranties commonly fail in practice.
• TrustMark has told affected homeowners it has “no duty of care to homeowners.” This epitomises the accountability gap.
• Enforcement headlines mask scale. Removing 39 installers is the tip of the iceberg; multiple bodies exhibit installer-bias in an ecosystem funded by installers.
• Redress excludes key harms. Mis-sold/poorly designed heat pumps and consequential losses (including roofing issues linked to PV and wider damage to homes) are largely sidestepped.
• Fragmented, under-powered complaint routes. Ofgem signposts to TrustMark; scheme providers often limit/decline investigations; the Dispute Resolution Ombudsman (DRO) compensation cap sits far below typical install values and possess little by way of technical insight.
• Standards in name, not practice. PAS/MCS requirements are upheld by exception; whole-home thinking is rare; technical evidence is often absent.
• No independent advocacy. Homeowners navigate a maze of complexity without representation or empathy.  Many vulnerable homeowners are unable to tackle the challenge presented.  A single body alone will not address the gaps – an independent organisation is needed to fight for and represent homeowners.  Citizens Advice does not presently provide specialist advice regarding ECO4 and us not adequately resourced to do so.  Trading Standards no longer respond to individual cases.  And the current policy of devolution has clearly failed to ensure adequate self-regulation.

Since August, 130+ ECO4-affected households have contacted us. Some report loss of the habitability and value of their home; many more report deteriorating health, chaos and hardship caused by failed installs and unresolved complaints.

Documented fraud — clear evidence, but nobody will investigate

We hold significant prima facie evidence of installer-led fraud that no party will take ownership of investigating.

Examples include:

• Misrepresented surveys/heat-loss calculations and performance claims that contradict site conditions.
• Forged or proxy signatures on homeowner declarations and commissioning sheets.
• Ineligible or mis-categorised measures/households recorded as compliant to secure funding.
• Misrepresented heating systems changed on documentation to increase grant funding
• Call recordings with clear evidence of fraud and mis-selling

Referral outcomes:

In my own experience, I have encountered / contacted over 20 organisations to seek remediation, though this will be my 3^rd consecutive winter without heat.

• TrustMark — states limited jurisdiction; refers to scheme providers; declines to open fraud investigations.
• Scheme providers/accreditation bodies — cite resource constraints; accept installer accounts at face value; decline whole-home reviews.
• Ofgem — guidance routes consumers elsewhere; available powers centre on homeowner misconduct, not installer fraud.
• DRO/Ombudsman — focuses on consumer disputes, not criminal or systemic fraud; compensation caps leave major losses unremedied.
• Police/Action Fraud —deem matters “civil,” or overly complex to investigate
• MCS — defers to scheme providers or treats matters as bilateral “disputes” rather than evidence-led investigations.

At present, no body accepts investigative ownership of credible fraud and mis-selling allegations within ECO4.  And no party accepts responsibility for investigating increased heating bills, despite the absence of affordability checks among some of the nations’ most vulnerable people.  This vacuum invites further abuse and undermines public confidence.

Practical fixes – there are many other system design recommendations, which I’d welcome the opportunity to provide

1. Government should accept accountability for design-level failures and ring-fence unspent ECO funds so that no household is worse off because of ECO4.
2. Ensure that homeowners can self-refer to an independent ombudsman and increase the ombudsman cap to £50,000, or refer via CADR or similar
3. Apply meaningful insurances with cover up to £150,000 even where installers remain trading
4. Legislate a clear duty of care to homeowners / occupants for all scheme actors (regulators, quality assurers, coordinators, scheme providers).
5. Guarantee a single contact, eight-week path to resolution for ALL measures (inc. heat pumps): single point of advocacy/triage → single whole-home investigation → binding remedy; no household left worse off – including damage to homes.
6. Adopt a customer-first system design (single-customer view; transparent evidence handling; accountable decision-making).
7. Embed homeowner representation in standards and scheme design.
8. Strengthen financial protections and insurances to cover full, verifiable and consequential losses, with timely decisions.
9. Detach final sign-off from installers; defer a portion of payment against independently verified performance.
10. Require real-world performance data (as in parts of BUS) with automatic bill adjustments where bills rise post-install.
11. Establish an ECO4 fraud taskforce and whistleblower channel, with clear thresholds for suspension/recovery of funds when credible evidence emerges.
12. Ensure sufficient enforcement of PAS and MCS standards – especially in response to homeowner concerns
13. Ensure adequate technical training at all points of consumer interface
14. Work with obligated energy companies to discount heating bills wherever higher following a grant-funded home upgrade
15. No ECO4 installer should be ‘too big to fail’ or fall out of the scope of investigations.  Sadly, this is very much the case today – for example, NICEIC penalties exist not on installer breaches but on volume of reported cases as a % of overall installs. 

Requests

1. Meeting: An urgent meeting with DESNZ and relevant regulators (Ofgem, TrustMark, MCS) to agree immediate actions.
2. Process status: Written confirmation of the stage of DESNZ’s complaints process in our case, or a date for a full response; if complete, please confirm that we may escalate to PHSO.
3. Substantive reply within 7 days addressing the concerns set out in my 10 September email and offering tangible relief this winter.

Yours Sincerely

Nature Society