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CAS response to BEIS' consultation on Warm Home Discount Scotland 2022-26

The Warm Home Discount scheme provides important funding for the short-term relief of fuel poverty. However, a combination of research and evidence from the Citizens Advice network in Scotland has previously found that while the Warm Home Discount is seen as vital by those who receive it, it is not adequately reaching those who need it most. Whilst CAS welcomes proposals for a scheme for Scotland for 2022-26, we have raised concerns that the proposals do not go far enough to address the issues of the previous scheme years.

CAS welcomes proposals to extend Warm Home Discount until 2026. Warm Home Discount provides important funding for the relief of fuel poverty. Research and evidence from the Citizens Advice Network in Scotland has found that the Warm Home Discount is seen as vital by those who receive it, yet it is not reaching those who need it most.

In August 2021, CAS responded to the Warm Home Discount consultation and raised concerns that there was no backstop scheme in the event that agreement could not be reached on a future scheme with the Scottish Government. Our research shows that the design of the scheme in previous years has been poorly targeted and created barriers for consumers to easily switch supplier. CAS would therefore highlight that there has been a missed opportunity to put into place a better designed and targeted scheme alongside the proposals for England and Wales.

CAS has raised concerns that the Warm Home Discount scheme proposed for Scotland has not adequately addressed some of the issues of previous scheme years. The introduction of data-matching for England and Wales for previously Broader Group customers addresses some of these issues. As no equivalent scheme has been proposed for Scotland, the proposals represent a poorer scheme for Scotland than those agreed for England and Wales.

Therefore, CAS would like to see any agreement on proposals for Warm Home Discount to be applicable for the first year only, with a similar scheme to England and Wales, within confines of data availability, to ensure that successive years beyond 2022-23 provide a scheme which is on par with that offered in England and Wales.

The proposed apportionment figure for Warm Home Discount also has implications for fuel poverty across Scotland. Furthermore, the proposed allocation mechanism creates risks for both suppliers and consumers - particularly it creates a lottery of WHD support depending on which supplier a consumer is with. Therefore, CAS would like to see a allocation mechanism based on customer need and not on metering points. 


Grace Remmington
Publication date
May 2022
Publication type
Number of pages