The UK’s net zero ambitions require scaling domestic energyefficiency and clean heat. However, scaling successfully requires unwaveringconsumer confidence.
The Government’s Consumer Protection Reform consultation rightly identifies market fragmentation, inconsistent standards, and complex redress mechanisms as pressing barriers. Yet, looking at the challenge purely through the lens of dispute resolution misses the biggest opportunity of all: stopping consumer harm before it happens.
At Cotality, our consultation response focuses on how better property data, risk-based oversight, and structural accountability can transform consumer protection from a reactive safety net into a proactive, intelligence-driven framework.
1. Shift from Post-Install Redress, unlocking Data Silos for Proactive Prevention
While robust dispute resolution and compensation are essential, relying primarily on complaints processes means the consumer has already suffered disruption, financial distress, or worse.
A mature consumer protection framework should leverage property intelligence and risk-based oversight to detect irregularities during the planning and delivery phases:
• Early Risk Identification: Ending data silos to use property and programme data to flag inappropriate projects early on, from initial scoping through to final plan
• Data over Databases: The UK retrofit ecosystem is rich in data, but poor in interoperability. Government can deliver immediate value by enabling secure data-sharing across retrofit assessments and installation registries, TrustMark and MCS data repositories, Building control, gas safety, and warranty records
With the Data (Use and Access) Act 2025 and the emerging Property Data Trust Framework (PDTF), the government will have the technical and legal mechanisms to connect these datasets. Open, trusted data-sharing can enable automated risk checks, eliminates duplicate surveys, and reduces customer acquisition friction.
2. Accountability Drives Quality: Empowering Retrofit Coordinators and Consumers
High-performing retrofit schemes - notably across local authorities and social housing providers - succeed because there is clear accountability to professional clients who maintain close oversight of the consumer experience.
To replicate this success in the private owner-occupier market, the regulatory framework and PAS standards must empower key professionals:
• Independence and Authority: Retrofit Coordinators must have the structural independence and contractual backing to challenge poor workmanship and halt non-compliant installations.
• Company-Level Accreditation: Extending accreditation beyond individual practitioners to the organizations employing them ensures institutional accountability and prevents individual coordinators from carrying systemic commercial pressures alone.
• Consumer Journey: To simplify the consumer journey, public registers shouldn't confuse homeowners with fragmented lists of individual assessors, designers, and coordinators. Instead, the service should signpost to integrated, turnkey services (Assessment + Coordination + Design) who can support the consumer with independent, tailored advice from first enquiry to completed install.
3. Intelligence-Led Audits Matter More Than Endless Standard Revisions
The industry frequently responds to quality challenges by revising technical standards. However, how standards are monitored in practice has a far greater impact on ground-level outcomes.
• Risk-Based Case Selection: Audit cases should be designated using predictive data analytics run by the consumer protection service provider for true independence.
• Cross-Body Intelligence Sharing: Findings must flow freely between Accreditation Schemes (overseeing assessors and coordinators) and Certification Bodies (overseeing installers). Issues are rarely specific to a single organisation or professional and lessons can be learned.
• Severity-Based Triage: Audit frameworks and responsible reporting should distinguish between administrative oversights and safety-critical defects, using minor failures as learning triggers for individuals and the system as a whole, while swiftly sanctioning chronic poor practice.
• Updating Outdated Audit Baselines: Current audit sampling rates were established years ago for a different scale of measures and risk; we would welcome a review for modern whole-house delivery.
4. Practical Competence and Modernizing Retrofit Design
Competence cannot be validated solely by initial certification; it must be proven through ongoing delivery quality yet no accreditation is currently required for Retrofit Designers, and they are not reported to the TrustMark data warehouse.
Equally concerning, the current framework places an unrealistic expectation on single designers to master an ever-expanding catalogue of complex, multi-measure technical specifications. We recommend:
• Accreditation for Designers: Introducing formal oversight for retrofit designers to close an existing governance gap.
• Encouraging Measure-Specific Specialism: Transitioning from an unscalable model reliant on single "generalist" designers to multidisciplinary collaboration where specialists in specific fabric or building services measures co-design complex projects.
5. Proportionate Evidence and Realistic Performance Monitoring
True consumer protection requires a golden thread linking data, audits, and accountability as an unbroken chain of assurance across the retrofit lifecycle:
• Proportionate ‘Paperwork’: Quality assurance evidence must be verifiable, consistent, and relevant to preventing fraud and defects, without imposing excessive administrative burdens on compliant installers.
• Enforcement Powers for Oversight Schemes: Auditing is toothless if Accreditation Schemes and Certification Bodies lack power. When substandard work is identified, oversight bodies must have formal authority to trigger mandatory contractor remediation and pause funding drawdowns – either directly or through clear and responsive escalation to the consumer protection service provider.
• Tackling "Phoenixing" and Liability Evasion: To stop rogue contractors from dodging remedial repairs by dissolving their businesses, the framework should introduce provisions to prevent dissolved entities from simply reappearing under a new name to repeat the cycle.
Key Takeaway: The Infrastructure Exists – Government Must Connect It
In high-stakes construction and building safety, the golden thread ensures that accurate, verified building data follows a property throughout its lifetime. In domestic retrofit, consumer protection requires the exact same discipline.
An effective consumer protection regime cannot rely on isolated checks at the end of a job. It demands an unbroken golden thread of data, intelligence-led auditing, and institutional accountability running from the initial property assessment, through specialist design and installation, to long-term warranty and redress.
The UK retrofit sector does not need a clean-slate rebuild of its standards. The data and skills exist. It needs connected intelligence, cross-industry data flows, and empowered professionals – individual and corporate. By breaking down data silos and prioritizing prevention, we can build a consumer protection regime that delivers warmer, healthier homes with confident consumers.
