The Hidden Path to ECO4 Escalation

The steps installers and accrediting bodies 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.


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 Action on Energy Cambridgeshire.
  • IAAI (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 Action on Energy

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

Accreditation / Quality & Technical Schemes

  • TrustMark – cross-sector scheme for retrofit quality.
  • NAPIT – UKAS-accredited certification body for building services and fabric sectors (electrical, renewables, insulation)
  • MCS (Microgeneration Certification Scheme) – writes standards and certifies renewable heating installations.
  • NICEIC – electrical certifications.
  • HIES – consumer code and ADR scheme.
  • PAS – accrediting body historically focussing on insulation – new to the concept of ‘whole home systems’
  • BSI (British Standards Institution) – developed PAS standards (e.g., PAS 2030, PAS 2035)

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

ADR / Ombudsman

  • HIES Arbitration – non-binding, narrow in scope.
  • Dispute Resolution Ombudsman (DRO) – independent redress scheme, capped at around £10k (£3k typical).
  • Parliamentary Ombudsman (see above)

Allies / Civil Society & Campaigners

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

2. Official ECO4 Complaints Process (per Ofgem)

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

StageWhat Ofgem MandatesReal-World Failings
A. Contact the installerRaise your complaint with the installer, or use the installation guarantee.Installers often ignore emails, deny responsibility, or delay indefinitely.
B. Contact the guarantee providerIf 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 providerE.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 AdviceCitizens 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 StandardsYou 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 referralIn 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).

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 – 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).

Step 5 – At the same time, Identify your PAS Coordinator (who will be TrustMark-registered).

Step 6 – Apply public pressure: reviews on Google, Trustpilot, MoneySavingExpert, TrustMark site, and social media.

Step 7 – File a complaint directly with the accrediting body and seperately with your PAS Coordinator. 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 8 – Notify your MP (and local council if your home is uninhabitable).

Step 9 – After 28 days, ask your MP to escalate your case to DESNZ (Department for Energy Security & Net Zero).

Step 10 – File SARs with both the installer and accreditor, so you have the full paper trail.

Step 11 – Escalate to the Parliamentary Ombudsman, citing systemic failure and risk to health.

Step 12a – Ask the accreditor to refer you to the Dispute Resolution Ombudsman (DRO). ⚠️ Note: capped at £10,000.

Step 12b – 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 13 – If DRO fails and your claim is < £10k, proceed to Small Claims Court, keeping your MP updated.


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.

PAS (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.

Letter Before Action

Formal notification of escalation (to courts)

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