From: duncan@nature-society.org
Sent: 28 November 2025 11:20
To: ‘Public Accounts Committee’ <pubaccom@parliament.uk>; enquiries@nao.org.uk; commonsesnz@parliament.uk
Cc: xxxxxxx
Subject: ECO4 – Request for Further / Urgent Inquiry into Fraud, Assurance Failures and Consumer Harm

Dear Members of the Parliamentary Committee and colleagues at the NAO,

This email highlights the injustice of ECO4 and forwards a clear and troubling case study concerning alleged / unchecked fraud.

What if committing £28,000 of ECO4 fraud on a single installation was as simple as ticking the wrong box or entering the wrong value?
No one required to check or validate it against the reality of a home – not even against an independently lodged SAP one year earlier.

What percentage of ECO4 installer revenues might relate to fraud when reporting is so devolved and so self-regulated that installers’ words are taken as final?

Among the trusted Retrofit Coordinators I speak with, they estimate that over 70% of installers (by volume) are either on a “get rich quick crusade” or “simply not up to the job”.
I know of such installers – some with interesting pasts – who parade £300,000 cars, whilst homeowners suffer in the cold.

What if legislation demanded real-world poverty alleviation (ECO Order 2022), but there were no metrics and no resources to assess real-world impact?

What if energy suppliers relied almost exclusively on installer-reported RdSAP figures as proxies for real-world savings – and Ofgem then used those same figures as their primary accountability mechanism?

What if projected “ABS – Annual Bill Savings” were routinely inflated by up to 70% versus realistic scenarios?
And what if ABS allowed heat pump fuel bills to increase – sometimes dramatically– while still meeting grant criteria?  Those same installs recorded and reported as successful.

Where this constitutes mis-selling / misrepresentation – who is doing the mis-selling?  The installer? The Energy Supplier?  Ofgem?  Or DESNZ?

What if there were no meaningful, accessible processes for homeowners to report fraud, and no advocacy or support for those who suffer its consequences?
And, what if only 0.1% (or fewer) of ECO4 homeowners had access to sufficient data and expertise to identify and evidence misconduct?

What if TrustMark claimed “no remit”? Nor the British Assessment Bureau, NICEIC, MCS, UKAS, Ofgem – nor anyone, for that matter.

What if, when asked to clarify their process for handling installer fraud, no organisation replied?
What if it was deemed “too technical” for Action Fraud?

And what if those same homeowners were left without affordable heat – effectively forever – without a single person or organisation able or willing to help?

What if those people were already distressed, already struggling, already vulnerable?

Such is ECO4.

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I write as someone who leads a group of ECO4 victims. I can offer many harrowing stories. Many of the people I speak with continue to struggle without safe, affordable heating. Current policy and assurance arrangements are plainly not sufficient.

There are clear solutions and existing unutilised mechanics for resolving this crisis (which I’d love to discuss). But despite repeated attempts to open dialogue – particularly with DESNZ and TrustMark – there has been no meaningful engagement. DESNZ appear unwilling or unable to confront the human consequences of a scheme that they architected and oversee. One under which they hold a clear duty of care to citizens.

By way of illustration, I attach / link a recent email I sent to Ofgem and DESNZ. That email sets out a detailed case study where manipulated RdSAP inputs appear to have generated a very substantial ECO4 grant uplift on a single property, while leaving the home unheated for three consecutive winters.

The allegations are made carefully and in good faith, based on documentary evidence from:

• Obligated supplier data
• Pre- and post-installation RdSAP submissions
• PAS 2035 documentation
• EPC / SAP records
• Call recordings and other contemporaneous evidence

I am of course willing to correct any errors if any of the bodies involved can demonstrate them. And to provide all evidence on request.

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What I am asking of the Committee and the NAO

In light of the above – and the many similar stories I hear from other households – I respectfully ask that you:

1. Scrutinise the ECO4 assurance and fraud-control framework
   • What independent checks exist today, in practice, on RdSAP data integrity, ABS claims and FPS/ABS-linked carbon credits?
   • How will DESNZ / Ofgem / Energy Suppliers seek to recover fraudulent funds?  And will they commit to using such funds to guarantee 100% remediation for homeowners and occupiers?
2. Examine the scale and impact of potential ECO4 fraud and mis-selling
   • Using NAO powers, sample ECO4 installations and compare reported RdSAP data against independent surveys and pre-existing EPCs.
   • Assess the prevalence and value of suspected over-claiming and the number of households left with higher bills, unsafe installations or no heat at all.
3. Consider immediate protections and redress for affected households
   • Establish a clear, independent route for ECO4 fraud and mis-selling reports that does not rely on the bodies who may be implicated.
   • Recommend a mechanism for urgent interim support (including temporary heating / accommodation where necessary) while investigations proceed.
4. Ensure that ECO4 genuinely delivers its statutory purpose
   • Review whether scheme design and oversight are genuinely aligned with the ECO Order 2022’s intention of alleviating fuel poverty and reducing bills in the real world – not merely a paper exercise.

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I trust in you as people who care – and as people who can demand action and resolution.

I am here to:

• Provide detailed case studies and supporting evidence (including the full ECO4 victim group’s testimonies), and
• Support any inquiry, review or investigation you may initiate.

As victims of ECO4, many of us now feel that the media is our only outlet. We are left to fight complex legal battles without resources, facing further risk and distress simply to secure safe, habitable homes.

This is all so deeply, deeply wrong.

Thank you for your time and for any steps you can take to help end this injustice.

Yours sincerely, Duncan Hayes