Small firms installing insulation, heat pumps, solar panels or batteries under government-backed home upgrade schemes should watch a new consumer protection proposal. The Competition and Markets Authority (CMA) has backed plans for clearer oversight, complaints and guarantees in a response published on 23 September. It also wants the government to consider protection for customers who pay for the same work themselves.
This is a response to a closed Department for Energy Security and Net Zero consultation, not a change to the rules today. The details, timing and final scope have yet to be settled. For a small installer, the useful step now is to understand which parts of its work fall under government schemes and whether its customer records and aftercare are clear enough to stand up to scrutiny.
What is being proposed?
The department’s consultation proposed one consumer protection service for government-supported home upgrades. It would bring advice, oversight, complaint handling and case management into a clearer system. Other proposals include stronger agreements with organisations involved in delivery, a data system to spot problems earlier and a public register of installers and retrofit professionals approved for government schemes.
In its 12-page response, the CMA supports simpler routes for customers to get work put right. It backs a single complaints function, with an independent ombudsman for unresolved disputes. It also supports a proposed requirement for installers on government-supported schemes to provide a guarantee with a minimum level of financial protection. Neither the design of that guarantee nor a start date is set out as a new live requirement in the response.
The CMA also favours stronger inspection and escalation where suppliers repeatedly or seriously fail customers. Under the proposals, consequences could include removal from approved supplier lists or withdrawal of certification. Small firms should treat that as a direction of policy, rather than assume that a new enforcement process has already started.
The question about privately funded work
Much of the proposed system is aimed at work funded through UK government schemes. The CMA warns that customers paying the full cost themselves could otherwise face weaker protection for similar upgrades. It asks the department to consider whether approved alternative dispute resolution should become a requirement more widely across the sector, and whether self-funded customers should receive comparable financial protection.
That wider requirement is a CMA recommendation, not an obligation that has been introduced. It matters commercially because many local installers do both scheme-funded and private jobs. Separate promises, complaint routes or guarantees for essentially similar work can be difficult for customers to understand. Firms should check what they currently offer in each case before the government sets out its final approach.
Four checks for smaller installers
- Map your jobs and memberships. List the schemes you work under, the accreditation or consumer code each requires, and the protection offered to customers who pay privately. Do not assume an approval for one scheme covers every service you sell.
- Make the handover record useful. Keep a clear written scope, the agreed price and variations, evidence of completed work, product information and the applicable guarantee. If a customer reports a fault months later, the business should be able to identify who is responsible for investigating it.
- Test the complaint route. Make it easy for a customer to contact the firm, record the issue and explain the next step. Check where an unresolved complaint can go under the firm’s current scheme or code. The proposed single service and ombudsman do not replace those existing routes yet.
- Check sales claims now. The CMA’s existing business guidance on marketing green heating and insulation covers accurate product claims and upfront price information. That guidance concerns current consumer law; a firm should not wait for this consultation to review a claim it cannot substantiate.
BritishSME has also covered the separate trusted trader announcement for home improvement firms. That wider trade listing should not be confused with the consumer protection reforms discussed here, which chiefly concern government-supported home upgrade schemes.
What happens next?
The consultation is closed and the CMA has given its view. Installers can read the department’s proposals and the CMA response, then watch for the government’s decision and the terms of any scheme they use. There is no new enrolment deadline or universal guarantee figure in this response.
In the meantime, a short review of quotes, guarantees, installation records and complaint handling is worthwhile. It helps customers understand what they are buying and gives a small firm a sound starting point if the proposed system becomes more demanding.
Sources: CMA response, published 23 September 2026; DESNZ consultation; and CMA guidance for businesses, checked on 24 September 2026.
