A System of Empty Promises
An evidence-led timeline of ECO4’s broken safeguards – what was promised, what best practice demands, and what actually happened
Dr Katherine Barrett’s home as it has been left for more than a year following a poor quality ECO4 install, without protection
Is this what ‘quality assurance’ looks like?
The Promise
- “Consumer safeguards” through TrustMark registration
- Quality assurance via audits and standards
- Fraud controls and working groups
- Clear routes to “redress”
- Public Accounts Committee assurances that “all homes will be put right” – not just those with EWI
- “Warm Homes Plan” overhaul
The Reality
- Devolved and deflected accountability
- The injustices of absent protection every bit as great as a failed install
- Ignorance of Solar PV and Heat Pump failure, including higher bills
- The priority of process and profit over people
- Empty assurances in lieu of meaningful actions
- A scheme capable of worsening lived experience, rather than improving it
- Many ECO4 victims are unaware of what a Retrofit Coordinator actually is
We Believe a Full and Urgent Independent Review of ECO4 is Now Needed, Alongside Referral to the Serious Fraud Office
Each item below contains the same four fields: Date, Promise, Best practice, Reality.
Empty Promises Since 2016
2016
x
The Promise
“Each Home Counts” reform lineage is held out as the basis for improved consumer protection/quality assurance.
Best Practice
Single point of accountability; enforceable consumer remedies; transparent reporting on failures and sanctions.
The Reality
A decade later, the NAO is still documenting widespread non-compliance, fraud exposure, and a fragmented oversight model.
Unskilled Labour Completing Highly Skilled Works
2022 – 2026
The Promise
The governance of ‘whole home’ retrofit under a comprehensive system of standards and accreditation
Best Practice
Every individual on a jobsite should be accredited, insured, and their registration details made available to the homeowner.
The Reality
Firms grow rapidly by hiring poorly skilled and unverified 3rd party contractors often with no formal qualifications. They fire as quickly as they hire.
2016
x
The Promise
“Each Home Counts” reform lineage is held out as the basis for improved consumer protection/quality assurance.
Best Practice
Single point of accountability; enforceable consumer remedies; transparent reporting on failures and sanctions.
The Reality
A decade later, the NAO is still documenting widespread non-compliance, fraud exposure, and a fragmented oversight model.
Inadequate Fraud Controls
June 2024
The Promise
DESNZ establishes a fraud working group (DESNZ/Ofgem/TrustMark) in response to TrustMark’s concerns.
Best Practice
Fraud controls should be “always on”: independent verification, rapid sampling, evidence preservation, public reporting, and immediate enforcement triggers.
The Reality
NAO later records structural incentives to overclaim and scheme weaknesses exposing ECO4 to fraud/error/gaming/non-compliance.
Weak fraud controls are introduced 3.5 years into a 4-year scheme.
Process First, not People First
July 2024
The Promise
TrustMark is first notified of my own emergency situation in July 2024; seriousness/severity is acknowledged.
Best Practice
Site visit within 7 days max, systems-led audit, and a formal remediation order with urgent timelines and clear penalties.
The Reality
No decisive action/outcome for ~18 months: “almost 18 months since notifying TrustMark… still no clarity… aware of the severity.”
The ‘Assurance’ Facade
We have reason to believe TrustMark were aware well before Nov 2024, in contrast with the assurances made at the Public Accounts Committee held 13th November 2025
Nov 2024
The Promise
TrustMark raises concerns about non-compliant IWI; DESNZ sets up a workstream to understand extent and identify remediation options.
Best Practice
Precautionary pause on high-risk measures; independent inspection surge; remediation plan before continuing volume delivery.
The Reality
NAO shows the first statistically representative estimate of scale only arrives later (Aug 2025), i.e., harm precedes certainty and control.
Focus on Political Risk, not Risk to Health and Homes
Dec 2024
The Promise
DESNZ asks certification bodies to audit 20% of EWI installs.
Best Practice
100% audit of high-risk measures; independent auditors; publish failure rates by installer/scheme provider; rapid suspensions.
The Reality
Even with escalations, NAO documents major non-compliance and cases with immediate health and safety risk.
Solid Wall-only Inspections, Reliant on Proactive Homeowners
Jan–Feb 2025
The Promise
Ofgem writes to ~60,000 households; helpline provided; audits and remediation tracking.
Best Practice
Each household gets a case owner, enforceable timelines, and funded remediation pathways—not “signposting”.
The Reality
NAO record shows limited high-priority triage volumes and extended audit programmes to understand scale. c.9000 / 11000 homes found to be faulty.
NAO Report Fails to Address all High-Risk Measures – Only Those that are Politically Convenient
May 2025
(NAO timeline item)
The Promise
A DESNZ-commissioned report finds the scheme is significantly exposed to fraud/error/gaming due to weaknesses in design/operation/oversight.
Best Practice
Automatic redesign of scheme controls; enforceable gatekeeping; independent verification of eligibility and outputs.
The Reality
Later ministerial correspondence still describes a system where oversight is diffuse and consumer resolution difficult.
TrustMark Responsible for a 3rd Winter in the Cold
Sept 2025
TrustMark dispute comms
The Promise
After failing to record a prior inspection, TrustMark confirm – after over a year of complaint – that they will attend my home; engage with MCS; review heat loss calculations.
Best Practice
Independent inspection promptly, with clear scope, published methodology, and immediate interim safeguarding.
The Reality
An incomplete and opaque Subject Access Request, failure to provide transparency as to process and standards applied. Refusal to receive or analyse homeowner evidence.
Still awaiting the outcome of a straightforward inspection, which could be definitive within 1 hour onsite, resulting in an avoidable 3rd Winter in the cold.
Months of ‘Oversight’ Abstracted from Moments of Reality
Oct 2025
TrustMark ‘process’
The Promise
TrustMark describes visits aimed at “verify the factual timeline” to build “fact-based picture moving forward.”
Best Practice
Outcome-focused enforcement: assess compliance against PAS/MCS/Building Regs; issue determinations; compel remediation.
The Reality
The framing centres chronology/process; not a decisive enforcement posture visible in the record excerpt.
Minister Assurance: Gov has Duty of Care
5th Nov 2025
Official Correspondence
The Promise
Government duty to “safeguard consumers”; officials + TrustMark “here to help”; independent assessor visit; “expect TrustMark to assist… remediation”; overhaul promised via Warm Homes Plan.
Best Practice
Immediate enforceable action: temporary accommodation support where needed; remediation instruction; deadlines; public accountability.
The Reality
Subsequent correspondence indicates continued waiting for reports/audits; the case remains unresolved in the period covered.
Communications Protect Government, not Homeowners
5th Jan 2025
Official Correspondence
The Promise
“Protections in place”: TrustMark installers; QA oversight “including auditing of up to 10%”; routes to redress; acknowledges fragmentation; again promises “sweeping overhaul” via Warm Homes Plan.
Best Practice
If protection is real, it is measurable: high audit coverage for risk, open outcomes, fast adjudication, and compensation where harm occurs.
The Reality
MCS states it is not accredited to handle complaints and that outcomes aren’t shared with consumers; dispute framing is procedural and excludes compensation.
Meetings Promised but Never Materialise
5th Jan 2025
Official Correspondence
The Promise
Between TrustMark and DESNZ, I have received no fewer than 6 seperate assurances of meetings with officials and have sent many requests in light of the urgent plight of homeowners in receipt of ECO4
Best Practice
The transition to greener energy must be a “just transition”. ECO4 excludes and depricates homeowners by design. In constrast, customer-led design also results in more sustainable outcomes for schemes and shareholders.
The Reality
Despite representing over 300 homeowners affected by poor and shoddy work under the ECO4 grant scheme, no meetings have materialised.
TrustMark MLA and Code of Conduct are Meaningless
——–
TrustMark Master Licence Agreement
TrustMark Code of Conduct
The Promise
Master Licence / Code of Conduct language implies proactive standards, assurance, and consumer-facing integrity obligations.
Best Practice
Governance must translate into action: transparent determinations, sanctions, remediation orders, and consumer updates with evidence.
The Reality
The communications record includes explicit limitations (“not a technical specialist”), prolonged handling, and repeated requests for transparency and urgency.
Retrofit Coordinator Obligations Absent and Unenforced
Sep–Oct 2025
RC / monitoring & evaluation
ECMK Communications
The Promise
Retrofit Coordinators are present to oversee the Retrofit process in the homeowner interest, ensuring a high level of quality is delivered and that ECO4 measures are appropriate.
Best Practice
RC function should be independent in substance, not just wording; no procedural hurdles that delay safeguarding.
The Reality
The communications record includes explicit limitations (“not a technical specialist”), prolonged handling, and repeated requests for transparency and urgency in light of uninhabitable conditions – all of which go ignored in practice.
Inconvenient Expert Evidence is Ignored and Buried
Jan 2026
Expert evidence – Part35 Compliant
The Promise
A system of Quality Assurance designed to protect homeowners. (date on report page excerpt)
Best Practice
Part35-compliant technical inspection, according to PAS2035, MIS, and Building Regulations
The Reality
TrustMark refusal to accept any evidence that is not of their own or the installer’s making. TrustMark act as a trade association, rather than for the purposes of consumer protection