The Hidden Path to ECO4 Escalation

The steps “they” don’t want you to know about

By accepting an ECO4 grant, homeowners are unknowingly placing both their homes and health at possible risk. When things go wrong, the journey to justice is long, fragmented, and stacked against the individual.

This broken system was the catalyst that inspired us to create Nature Society — to fight for fairness, transparency, and accountability in retrofit.

Official (failed) Process

Hidden Process

Real-world Experience

1. Navigating the ECO4 Maze

All homeowners considering a ECO4 grant should be aware of the fragmented maze of organisations, which can feel like a minefield should you need to tackle the complaints process:

Installation / Supply Chain

Installer (e.g., CES) – contractor responsible for the retrofit.
PAS Assessor / Coordinator – responsible for overseeing whole-house retrofit compliance.
Energy Company – an Ofgem Freedom Of Information can reveal the name of the company funding works

Insurance-backed Guarantees / Quality Assurance

SWIGA (Solid Wall Insulation Guarantee Agency) – not-for-profit for solid wall insulation, offering 25-year insurance-backed warranty and structured dispute resolution
CIGA (Cavity Insulation Guarantee Agency) – independent 25-year guarantee for cavity wall insulation
IAA (Installation Assurance Authorities) – oversight framework that includes SWIGA, CIGA, and loft-insulation guarantees
QualityMark (formerly GDGC) – provides insurance-backed guarantees and deposit protection for retrofit installations

Consumer Advice / Local Agencies

Citizens Advice – general consumer rights and gateway to Trading Standards.
Local Energy Agencies – advice providers (vary in effectiveness).
Local Council Environmental Health – can enforce on uninhabitable home conditions.
Trading Standards – enforcement body for mis-selling/fraud (via Citizens Advice).

Legal / Insurance

University Law Clinic – pro bono legal support (capacity and expertise / complexity limited).
Private Solicitors – costly route, risk of adverse costs. No Win No Fee might be an option in cases of negligence.
Legal Expenses Insurance (LEI) – may cover litigation costs via home or car insurance add-ons.
Pro Bono Solicitors – please start with the Law Centres Network
Good Law Project
Public Law Project

Allies / Civil Society & Campaigners

Fuel Poverty Action
National Energy Action (NEA)
End Fuel Poverty Coalition
Shelter
Friends of the Earth
Greenpeace

Accreditation / Quality & Technical Schemes

Most often, many of these schemes apply to any single install and none have ‘whole home’ accountability. All are paid for by suppliers. And, there is no organisation in place to protect homeowners.

TrustMark – The only gov-backed scheme for retrofit quality. Though many claims of uninvestigated complaints.
NAPIT – UKAS-accredited certification body for building services and fabric sectors (electrical, renewables, insulation)
NICEIC – electrical certifications.
HIES – consumer code and ADR scheme.
PAS – accrediting body historically focussing on insulation – new to the concept of ‘whole home systems’
British Assessment Bureau
Simply Certification
There are more – please contact and will update

Standards Bodies

Ofgem –Energy Regulator – issues ECO4 Guidelines, however, has very limited role in practice – e.g. no powers to investigate installer misconduct / fraud. Reliance on DESNZ for policy.
UKAS — United Kingdom Accreditation Service (the state-appointed accreditation body for PAS/MCS certification bodies)
MCS (Microgeneration Certification Scheme) – develop MCS standards for Solar and Heat Pumps. Whilst there is some overlap with PAS, MCS assume no accountability for PAS investigation, breach, or negligence.
BSI (British Standards Institution) – developed PAS standards (e.g., PAS 2030, PAS 2035)
DLUHC – leads on Building Regulations policy – whilst building regs have ultimate powers, they are scarcely involved in practice
BSR (Building Safety Regulator, within HSE) regulates building control bodies/inspectors
OPSS (Office for Product Safety & Standards) — the National Regulator for Construction Products; enforces construction-product rules alongside DLUHC policy lead

Government / Regulators / Public Bodies

Ofgem – ECO4 scheme administrator (no complaints jurisdiction).
Ofgem Fraud Team – logs allegations but lacks enforcement power.
DESNZ – government department for energy policy escalation.
MP – highly recommned that you contact your MP at the same time as your accrediting body
Parliamentary Ombudsman – Oversees parliamentary failings – ECO4 systems design being an example
Local Authorities – oversee ECO4 LA Flex route and may provide further support
ICO — enforces UK GDPR (e.g., transparency and accountability principles) relevant to sales/complaints/call recordings

ADR / Ombudsman

CTSI’s Consumer Codes Approval Scheme (CCAS) — approves consumer codes such as HIES and RECC used in this sector
HIES Arbitration – non-binding, narrow in scope, though up to 150k contract coverage
RECC (also a TrustMark Scheme Operator) — code sponsor; independent adjudication via CEDR when RECC’s process doesn’t resolve matters
CEDR – Centre for Effective Dispute Resolution
Dispute Resolution Ombudsman (DRO) – independent redress scheme, capped at around £10k (£3k typical). Limited technical expertise.
Parliamentary Ombudsman (see above)

2. Official ECO4 Complaints Process (per Ofgem)

Sadly, the official ECO4 complaints process is fraught with difficulty and often devoid of accountability:

Stage	What Ofgem Mandates	Real-World Failings
A. Contact the installer	Raise your complaint with the installer, or use the installation guarantee.	Installers often ignore emails, deny responsibility, or delay indefinitely.
B. Contact the guarantee provider	If applicable, contact the guarantee provider.	Providers frequently pass blame back to installers or stall progress. Critically, there are no ‘whole home’ guarantees and a systemic lack of ‘whole home’ knowledge. There is no guarantee that your heating costs will be lower following installation. And remediation is often capped and insufficient.
C. Contact the accrediting body / scheme provider	E.g. CIGA, GGF, Gas Safe Register, or TrustMark (if relevant).	Bodies often under-resource complaints, leaving homeowners waiting months for resolution. Installers ultimately pay fees to these bodies and carry significant influence. There is no independent body fighting on your behalf – a key reason Nature Society was created.
D. Citizens Advice	Citizens Advice can give independent consumer rights advice.	They have no enforcement powers; cases are logged but in reality, they have neither the funding nor the remit nor expertise. No real knowledge of ECO4 or PAS standards and so, the reality is that they can neither advise nor support.
E. Trading Standards	You may be directed to Trading Standards if mis-selling or fraud is suspected.	Access only through Citizens Advice, and action is rare in ECO4 cases. Again, funding has been cut dramatically for Trading Standards over recent years and this is no longer a realistic means of escalation.
F. Ombudsman referral	In theory, complaints can be escalated to an Ombudsman scheme (e.g. Dispute Resolution Ombudsman).	Access is inconsistent; referrals blocked or capped (usually at £10k). Payouts rarely above £3k and so suited to smaller claims only. If agreed blocks all further claims. Non-specialist, with limited knowledge about ECO4 / PAS Standards.

Ofgem’s role: Ofgem administers ECO4 but does not handle installation complaints. If you don’t know the name of your accrediting body, your installer, or the energy company funding works, you can email ECO.SAR@ofgem.gov.uk with proof of address to request details. Even if you obtain this information, you’re typically pushed back into the same ineffective complaint loop.

⚠️ Result: The official path looks like protection, but in practice it’s fragmented, weak, and stacked against homeowners.

3. The Hidden Path to Escalation (What Actually Works)

Step 1 – Document everything (photos, notes, dates, times, correspondence) during your install and be sure to keep orderly records. Record temperature, energy usage and £cost data pre vs. post install.

Step 2 – Email the installer clearly setting out your complaint. Be factual, mention any vulnerabilities or urgencies applicable and set a clear deadline.

Step 3 – If ignored, send a concise reminder email and follow up with a phone call.
Side note – PAS standards determine that your heating must be more affordable than prior to the install.

Step 4 – Notify Trustmark – hot off the press – it seems Trustmark have started investigating at least some complaints (previously a source of huge frustration, rather than action)

Step 5 – If you don’t know the name of your accrediting body, your installer, or the energy company funding works, file a Subject Access Request (SAR) with ECO.SAR@ofgem.gov.uk (provide proof of address) and separately with TrustMark. Be sure to specifically ask for details of the energy co, or they may not be provided.

Step 6 – Identify your PAS Coordinator in TrustMark’s response ). They have an obligation to you under PAS2035. First approach them directly. If they refuse to engage, are slow to respond, or try to limit their enquiries, notify their accrediting body – this can be found via the TrustMark register. PAS Coordinators should always introduce themselves prior to works commencing.

Step 7 – Apply public pressure: reviews on Google, Trustpilot, MoneySavingExpert, TrustMark site, and social media.

Step 8 – Notify your MP (and local council if your home is uninhabitable / unheatable).

Step 9 – File a complaint directly with the accrediting body. State:

“My MP is being notified, and if unresolved within 28 days, I will escalate to the Department of Energy Security and Net Zero.”

Step 10 – After 28 days, ask your MP to escalate your case to DESNZ (Department for Energy Security & Net Zero). If MP not yet engaged, escalate to complaints@energysecurity.gov.uk, asking for arbitration / citing lack of traction with TrustMark / PAS Coordinator / Accrediting Body.

Step 11 – File SARs with both the installer and accreditor, so you have the full paper trail. Do this now and following any declaration of investigation behind closed doors.

Step 12 – Write to the energy company who funded your works. Point out how the install failed to meet the PAS Objectives (if applicable) – please see PAS documentation received via TrustMark following your Subject Access Request in Step 5. Ask the energy company to conduct an independent RdSAP Survey (EPC) if this is your PAS Objective – proving it was not met. Once this is established, demand the energy company declares breach of contract, or advise Ofgem / The Energy Ombudsman of their breach of HHRO:

Your Energy Company has an obligation called the Home Heating Cost Reduction Obligation (HHCRO). They are also obliged to deliver the PAS objectives to which the grant was assigned. Bit technical – do get in touch for more info!

Step 13 – If DESNZ have not responded, inform your MP that you wish to escalate to the Parliamentary Ombudsman, citing systemic failure and risk to health. Note – the Parliamentary Ombudsman will not investigate individual cases of installer dispute. You can file the application online, however, will need your MP as a sponsor.

Step 14a – Ask the accreditor to refer you to the Dispute Resolution Ombudsman (DRO). ⚠️ Note: capped at £10,000 and paid for by the industry.

Step 14b – If your complaint is more substantial, first check if you have Legal Expenses Cover with your home or car insurance, or via your workplace (if applicable)

Step 15 – If DRO fails and your claim is < £10k, proceed to Small Claims Court, keeping your MP updated.

Step 16 – If DRO your claim is > £10k, see https://www.lawcentres.org.uk/ , raise media profile, remind Trustmark of their statutory duty and seek independent arbitration (via Trustmark). Consider hiring an independent PAS Coordinator to review the case, which may provide the confidence to proceed with a lengthy court case.

Noting here, no homeowner should be forced to explore a lengthy court case as a result of installer failure. We are working to resolve this great injustice.

4. Our Experience with ECO4 Complaints

We followed the “official” process. This is what really happened. We’d love to help you avoid this complexity, whilst working to highlight that no homeowner should have to go through such a process in pursuit of a heatable home.

Installer

Claimed low bills proved efficiency — but bills were only low because the heating was switched off (the system couldn’t heat the home).

TrustMark

Referred us directly to PAS.

PAS

Assessor with no heat-pump knowledge; focused only on insulation contracts. Hugely frustrating and irrelevant.

Ofgem

No ability to act — outside remit. Filed FOI request.

HIES

Contacted us out of the blue (told they visit ~1 in 1000 installs). Arbitration limited to ASHP; no roof or heat-loss investigation.

Trading Standards

Didn’t respond (funding cuts).

Citizens Advice

No ECO4 knowledge and no funding to assist.

Local Energy Agency

Seeking support and insight

Back to HIES

Non-legally binding arbitration focused on ASHP only; installer refused to fix system before winter 2024 unless we accepted their terms.

Ombudsman

Confirmed maximum cap of £10,000 (typical ~£3,000). Install cost ~£35k, roof ~£40k, property damage £30k+ — not viable to pursue.

Back to TrustMark

Spoke with their Consumer Director — zero empathy or duty of care. Filed a complaint.

Ofgem → TrustMark

Due to the solid wall insulation campaign, Ofgem contacted TrustMark; a TrustMark assessor visited.

TrustMark records lost

TrustMark then lost all records of the visit and stopped responding to emails or calls.

MP

MP contacted Ofgem.

Ofgem statement

Ofgem stated they take installer-fraud allegations very seriously.

Ofgem Fraud Team

Confirmed they have no powers to review installer fraud.

NICEIC

No resources to investigate; refused due to contact with HIES.

FOI / SAR (Subject Access)

Filed with installer who did not comply for 8 months and then only with partial info

PAS Coordinator

Contacted the PAS Coordinator as they were wrongly named by the installer as their Data Protection Officer

University Law Clinic

Took the case on, then stepped back after ~2 months due to limited experience; recommended seeking a solicitor.

Solicitors

Can be ~£80k fees for multi-track court cases – seek no win no fee, or pro bono

Fuel Poverty Action

First real ally to step in.

FOI / SAR (Subject Access)

Filed with Trustmark, HIES, MCS

MCS

Empathised but confirmed there’s nothing they can do — no investigation.

British Assessment Bureau (again)

Stated that they work on specificaly assigned cases only. Have no remit to investigate alleged mis-selling and no knowledge of whole home systems (Air Source, Solar and Insulation combined)

MP → DESNZ

DESNZ agreed to investigate, however, appear to have simply passed the case back to MCS:

MP → DESNZ → MCS → CES

MCS wrote a one-paragraph note to CES and declined to investigate; because CES denies the allegations, they classify it as a ‘dispute’ outside remit — despite compliance concerns.

MP → DESNZ

MCS failed to invite evidence, inspect the house, or even offer a phone call. They did say they would investigate ‘behind closed doors’ without homeowner input or update. This is not an investigation – it is a clear preference for installers over homeowners, without outcomes. So, it’s back to DESNZ.

TrustMark

Couldn’t let it pass that Trustmark simply lost all record of my visit – filed an SAR and re-contacted their complaints team, copying in my MP and DESNZ.

Retrofit Coordinator

Having had no meaningful engagement with a Retrofit Coordinator over the course of the complaint, the RC refused to attend site or to respond to my concerns.

ECMK

Reported RC refusals / failures / negligence / RdSAP anomalies

Minister

Minister personally confirms that he expects TrustMark to ensure remediation of my home occurs.

TrustMark

Finally commission an inspection (though no meaningul action as yet). Inspection confirms many of my claims – including alleged misrepresentation.

Scottish Power (Grant Provider)

Claim to be utterly beholdent to TrustMark

Letter Before Action

Formal notification of escalation (to courts)