Warm Homes Plan

The ‘Warm Homes Plan’ sets out how we will help people find ways to save money on energy bills and transform our ageing building stock into comfortable, low-carbon homes that are fit for the future. --- ## Deployment Estimates of deployment of fabric measures, low-carbon heating technology, and energy generation and storage technology in the ‘Warm Homes Plan’ are the result of the aggregating impacts across multiple policies. We use the National Buildings Model (NBM), a housing stock model based on the English Housing Survey, supplemented by other policy-specific models. For each policy, we identify the households in scope and estimate the measures installed as a result of that intervention, taking into account interactions between policies. While the NBM and policy-specific models go through continuous review and robust quality assurance, the results of the modelling are subject to uncertainties, real world behaviour may not match the modelled outcomes for several reasons. Therefore the actual deployment depends on final policy design and choices made by households, landlords and developers. The following sections provide more detail on specific metrics and targets presented in the ‘Warm Homes Plan’: ### Heat pump market target Our aim is to grow the heat pump market to deliver more than 450,000 annual heat pump installations in existing and new buildings by 2030. For new build, the analysis uses estimates of the new homes to be constructed to Part L 2021 or Future Homes Standard (FHS) performance standards which use a heat pump route to compliance. In 2030 around 200,000 heat pumps are estimated to be installed in new build homes. Build rate assumptions should be taken as an indicative trajectory and do not represent an official forecast of housing supply. In existing homes, the analysis uses modelled heat pump installations supported by government policies over the current Spending Review period, with an extrapolation made to 2030 informed by historic year-on-year growth in the heat pump market. This is a UK-level ambition and assumes proportionate heat pump deployment in existing homes within the devolved administrations, equivalent to that projected under UK government policies. ### Homes upgraded The analysis presented includes estimates of homes upgraded from July 2024 – December 2030 based on Official Statistics of scheme delivery published to date and modelling of potential future policy impacts at the geographic scope of the policy. The estimate includes homes treated under: * capital funding schemes and retrofit schemes (including the Boiler Upgrade Scheme (BUS), the Warm Homes: Social Housing Fund (WH:SHF), the Home Upgrade Grant, the Warm Homes: Local Grant (WH:LG), Energy Company Obligation (ECO) and the Great British Insulation Scheme (GBIS) to the end of March 2026, provisional estimates of the impact of the additional low income £1.5bn capital delivery route announced at Budget 2025 from 2027/28 onwards, and HMG backed low-interest loans through the Warm Homes Fund (WHF) and other market-led domestic solar photovoltaic (PV) installations * investment from Private and Social landlords to meet the Minimum Energy Efficiency Standards (MEES) proposals, based on estimates provided in the regulatory impact assessments[[footnote 1]](#fn:1) and adjusted for overlaps with other policies to avoid double counting; and; * estimates of the number of new build homes constructed to FHS performance standards which use a heat pump route to compliance or are built with solar panels. Build rate assumptions should be taken as an indicative trajectory and do not represent an official forecast of housing supply The estimate of low-income households benefitting from these policies was based on the number of households in the bottom 4 income deciles (equivalised, after housing costs) modelled to receive measures. New build homes were not included in this estimate. ### Solar PV installations Estimates of future domestic solar PV installations up to and including 2030 are comprised of modelled deployment from Private Rented Sector and Social Rented Sector MEES regulatory impact assessments[[footnote 2]](#fn:2); estimated new build homes built to the FHS performance standards with solar PV; the WH:SHF and the WH:LG; the continuation of market-led deployment based on domestic retrofit installs in 2024/25, and provisional estimates of the impact of the new low income £1.5bn capital delivery route from 2027/28 onwards and the Warm Homes Fund. Estimated deployment under new schemes reflects latest analysis or published positions where applicable but is subject to final policy design. Geographic coverage varies by policy. For example, Private Rented Sector MEES applies to England and Wales; Social Rented Sector MEES and FHS to England only. The deployment estimates include assumptions around landlord choices. For example, assuming all Social Rented Sector landlords choose smart readiness (proxied for with solar PV) secondary to meeting a primary fabric performance target, under the £10k cap per home.[[footnote 3]](#fn:3) The element of choice amongst landlords means that the degree of solar PV deployment realised may differ from that in the modelled projection. Deployment from these schemes is additional to historic domestic solar PV deployment, sourced from DESNZ published statistics,[[footnote 4]](#fn:4) and future market led deployment where homes take up solar PV outside of government schemes. ### Heat networks The National Zoning Model identifies buildings in England, where heat networks are expected to offer the lowest-cost solution for decarbonising heat. Using outputs from this model, we expect around 20% of UK heat supply to come from heat networks by 2050. Interim targets have been set in order to be consistent with the trajectory required to meet this level. Targets are presented in 2025 terms, i.e. they are not adjusted for future changes in heat demand due to factors such as changes in population, temperature or energy efficiency. ## Bills Estimates of domestic bill savings are calculated through one of the following approaches: * dynamic simulation of typical housing archetypes, building on the Cost Optimal Domestic Electrification (CODE) study[[footnote 5]](#fn:5) * NBM based estimates of example archetypes under different policies ### CODE Our estimate of a typical household being able to save up to £550 a year from adopting a package of a heat pump, solar PV and battery is based on CODE. The following assumptions have been applied: * the coefficient of performance for the heat pump is 2.8 * the modelled PV installation is equivalent to 4 kW of PV panels, and the battery is equivalent to 4 kWh of storage * 4 kW of PV panels represents a common installation size which can fit on most roofs, though PV installations smaller than 4 kW for terraced and semi-detached houses would result in lower estimated bill savings * with a conventional tariff the battery is run to maximise self-consumption of the generated PV * solar PV installations are not optimally laid out, with PV laid on the East and West facing roofs. It may be possible for an optimally installed PV array to generate more electricity than modelled * the model assumes that archetypes have had a basic level of energy efficiency measures applied (cavity and loft insulation of 100mm) to begin with as well as double glazing * model assumes that households adopting a heat pump no longer pay the gas standing charge. Households which continue to use gas, such as in cooking appliances, would therefore experience lower bill savings Additional analysis has been undertaken to estimate the potential savings from adopting an illustrative time-of-use tariff and setting up the battery to charge during off-peak hours. The estimated additional bill savings from adopting a time-of-use tariff - alongside a heat pump, solar PV, and battery - is based on the following assumptions: * figures are based on average energy prices for 2024, for a household in Yorkshire (selected to reflect weather conditions representative of the country overall) * time-of-use tariff assumed to offer 8 hours of electricity at off-peak rate, 13 hours at standard rate and 3 hours at peak rate * the battery charges during off-peak hours and aims to maximise self-consumption of solar PV and avoid peak hours Estimates on bill savings, including those from time-of-use tariffs, are presented separately. Combining or aggregating estimates on bill savings would lead to misinterpretation and therefore all figures should be considered independently. ### Example archetype bill savings Example housing archetypes have been derived from the Quarterly Energy Prices (QEP) Statistics, NBM and CODE, with projected prices for 2028 applied as set out below. The example archetype bill savings for each policy represent a specific set of installations in a specific dwelling to give an example of how a household could see bill reductions under a ‘Warm Homes Plan’ policy. This is different to the average savings expected across a policy, which will average across a larger set of homes combining smaller and larger impacts. For example, the average PRS MEES bill saving across the policy are estimated to be £210/year per household while the example archetype has bill saving of £410/year.[[footnote 6]](#fn:6) Gas price projections for 2028, used to estimate bill savings for the example archetypes, have been taken from the Green Book supplementary guidance.[[footnote 7]](#fn:7) To split prices into standing charge and unit rate an illustrative future standing charge projection for gas and electricity has been estimated based on 2024 average standing charges from QEP.[[footnote 8]](#fn:8) An implied gas unit rate was then estimated from green book gas prices using 2024 average actual consumption.[[footnote 9]](#fn:9) To produce an electricity unit rate price series more reflective of current prices, the electricity to gas ratio from the Q1 2026 Ofgem’s default price cap was applied to estimated unit gas prices.[[footnote 10]](#fn:10) The following policy adjustments were then made to reflect the announcements to remove particular costs from gas and electricity prices at Budget 2025.[[footnote 11]](#fn:11) These impacts have been calculated against baseline prices produced using 2025 values taken from Ofgem’s default price cap[[footnote 12]](#fn:12), using summer and winter demand weights to produce an annual average value paid by those on single rate metering arrangements. Future £/MWh prices have been adjusted to account for changes in aggregate sales, using the DESNZ Energy and Emissions Projections gas and electricity demand projections.[[footnote 13]](#fn:13) * 75% of Renewable Obligation (RO) funded by exchequer from April 2026 until March 2029. Baseline RO cost projections have been taken from Office for Budget Responsibility November 2025 Economic and fiscal outlook * Energy Company Obligation (ECO) and Great British Insulation Scheme (GBIS) levy funding ends in April 2026. Baseline ECO/GBIS costs have been assumed to remain flat in real terms until 2030 The illustrative impact of a higher performing heat pump with a Time of Use (TOU) tariff demonstrates what some households could achieve in the nearer term from switching from a gas boiler to a higher performing heat pump. This is based on average actual electricity and gas consumption for 2024 taken from QEP statistics. Prices are based on the Q1 2026 price cap, adjusted for changes announced at Budget 2025. Gas demand converted to heat-pump consumption based on 8% demand uplift, 84% boiler efficiency and 311% heat pump efficiency and assumes heat pump household no longer pays the gas standing charge. Savings from adopting a time of use tariff are consistent with a 10% reduction in the unit rate for electricity, based on a review of evidence of time of use tariffs in relation to heat pumps and adjusting for the role of other demand shifting technologies in shifting electricity to lower price periods. ## Jobs supported Estimates of jobs supported by the ‘Warm Homes Plan’ includes estimates of both direct and indirect jobs, which can be defined as: * Direct jobs: the roles involved in the deployment, installation and maintenance of technologies such as heat pumps, heat networks, energy efficiency measures and solar PV and batteries * Indirect jobs: intermediary roles in the supply chain, such as manufacturing The 2030 estimates are for jobs supported by the Plan but do not measure net additional jobs across the sector. The 2030 figure is inflated by the assumption that a large proportion of private rented sector homes will be treated in that year, in time for the regulations. The overall job impact, from this policy, estimated at 180,000, may be more spread out, reducing the 2030 figure. Further details of how the number of for jobs supported are estimated are detailed in the ‘Clean Energy Jobs Plan Technical Annex’.[[footnote 14]](#fn:14) This applies to both UK and regional estimates, with equivalent policy actions assumed in devolved governments. ## Investment Estimates of investment over 2024 to 2030 are calculated by aggregating estimates of gross capital expenditure for multiple policies (new build standards use net capital expenditure to avoid counting the impact of general construction costs). Estimates include both public investment through spending review settlements and private investment, for example Housing Association Co-funding. The gross capital expenditure for each policy is calculated based on measures costs; it therefore does not include additional costs needed to administer policies. The capital expenditure is calculated based on the geographical scope of the policy, however, where devolved governments are expected to take similar actions, an appropriate scaling factor is applied to the gross capital expenditure to account for this. The public funding committed in the ‘Warm Homes Plan’ - £15bn this Spending Review period – is the largest capital allocation to schemes improving the energy efficiency and heating of homes to date. This is based on a comparison of the £15bn committed under the ‘Warm Homes Plan’ to the following comparable historic funding commitments and outturn funding: * 2025/26 – 2027/28: £6 billion capital funding committed for homes, public sector and industrial decarbonisation[[footnote 15]](#fn:15) * 2022 – 2025: £6.6bn capital funding committed for homes and public sector decarbonisation[[footnote 16]](#fn:16) * In 2013 – 2015, £540 million committed over 3 years for energy efficiency upgrades[[footnote 17]](#fn:17) * In parallel, since 2014 the Renewable Heat Incentive has to date made £1.2bn of payments[[footnote 18]](#fn:18) * From 2000/01 – 2012/13, the Warm Front scheme funded £2.9bn of heating and energy efficiency upgrades for qualifying households[[footnote 19]](#fn:19) 1. Social Rented Sector MEES consultation stage impact assessment Improving the Energy Efficiency of Socially Rented Homes in England - GOV.UK; Private Rented Sector MEES Impact Assessment to be published alongside the ‘Warm Homes Plan’. [↩](#fnref:1) 2. Social Rented Sector MEES consultation stage impact assessment Improving the Energy Efficiency of Socially Rented Homes in England - GOV.UK; Private Rented Sector MEES Impact Assessment to be published alongside the ‘Warm Homes Plan’. [↩](#fnref:2) 3. For further detail see the Social Rented Sector MEES consultation stage impact assessment Improving the Energy Efficiency of Socially Rented Homes in England - GOV.UK; Private Rented Sector MEES Impact Assessment to be published alongside the ‘Warm Homes Plan’. [↩](#fnref:3) 4. DESNZ (2025) ‘[Solar photovoltaics deployment](https://www.gov.uk/government/statistics/solar-photovoltaics-deployment)’ (GOV.UK) [↩](#fnref:4) 5. See the full CODE study for further details: BEIS (2021) ‘[Cost Optimal Domestic Electrification (CODE)](https://www.gov.uk/government/publications/cost-optimal-domestic-electrification-code)’ (GOV.UK) [↩](#fnref:5) 6. For further detail see the Private Rented Sector MEES Impact Assessment to be published alongside the ‘Warm Homes Plan’. [↩](#fnref:6) 7. DESNZ (2023) ‘[Green Book supplementary guidance: valuation of energy use and greenhouse gas emissions for appraisal](https://www.gov.uk/government/publications/valuation-of-energy-use-and-greenhouse-gas-emissions-for-appraisal)’ (GOV.UK), data tables 1 to 19: supporting the toolkit and the guidance [↩](#fnref:7) 8. DESNZ (2025) ‘[Annual domestic energy bills](https://www.gov.uk/government/statistical-data-sets/annual-domestic-energy-price-statistics)’ (GOV.UK), QEP Average unit costs and fixed costs for gas for GB regions and electricity for UK regions, Table 2.3.4 and Table 2.2.4 [↩](#fnref:8) 9. DESNZ (2025) ‘[Annual domestic energy bills](https://www.gov.uk/government/statistical-data-sets/annual-domestic-energy-price-statistics)’ (GOV.UK), QEP Average annual domestic gas bills by various consumption levels, Table 2.3.5 [↩](#fnref:9) 10. Ofgem (2025) ‘[Energy price cap (default tariff) levels](https://www.ofgem.gov.uk/energy-regulation/domestic-and-non-domestic/energy-pricing-rules/energy-price-cap/energy-price-cap-default-tariff-levels)’, 1 January to 31 March 2026, ‘Policy Cost Allowance Methodology (Annex 4)’ [↩](#fnref:10) 11. DESNZ (2025) News story: ‘[What does the Autumn Budget mean for your energy bills?](https://www.gov.uk/government/news/what-does-the-autumn-budget-mean-for-your-energy-bills)’ (GOV.UK) [↩](#fnref:11) 12. Ofgem (2025) ‘[Energy price cap (default tariff) levels](https://www.ofgem.gov.uk/energy-regulation/domestic-and-non-domestic/energy-pricing-rules/energy-price-cap/energy-price-cap-default-tariff-levels)‘,1 January to 31 March 2026, ‘Policy Cost Allowance Methodology (Annex 4)’ [↩](#fnref:12) 13. DESNZ (2024) ‘[Energy and emissions projections: 2023 to 2050](https://www.gov.uk/government/publications/energy-and-emissions-projections-2023-to-2050)’ (GOV.UK), ‘Annex F: Final energy demand in TWh’ [↩](#fnref:13) 14. DESNZ (2025) ‘[Clean Energy Jobs Plan technical annex](https://www.gov.uk/government/publications/clean-energy-jobs-plan/clean-energy-jobs-plan-technical-annex-html)’ (GOV.UK) [↩](#fnref:14) 15. DESNZ (2023) News story: ‘[Families, business and industry to get energy efficiency support](https://www.gov.uk/government/news/families-business-and-industry-to-get-energy-efficiency-support)’ (GOV.UK) [↩](#fnref:15) 16. DESNZ (2023) News story: ‘[Families, business and industry to get energy efficiency support](https://www.gov.uk/government/news/families-business-and-industry-to-get-energy-efficiency-support)’ (GOV.UK) [↩](#fnref:16) 17. DECC (2013) News story: ‘[Government action to help hardworking people with energy bills](https://www.gov.uk/government/news/govt-action-to-help-hardworking-people-with-energy-bills)’ (GOV.UK) [↩](#fnref:17) 18. Ofgem (2025) ‘[Domestic Renewable Heat Incentive Annual Report: April 2024 to March 2025](https://www.ofgem.gov.uk/transparency-document/domestic-renewable-heat-incentive-annual-report-april-2024-march-2025)’ [↩](#fnref:18) 19. House of Commons Library (2013) ‘[Warm Front Scheme Research Briefing](https://researchbriefings.files.parliament.uk/documents/SN06231/SN06231.pdf)’ (PDF, 249 KB, 7 pages) [↩](#fnref:19) --- ## 1. Outline of proposals This PSED Equality Impact Assessment (EIA) provides a strategic overview of equality impacts of policies within the Warm Homes Plan and considers cumulative strategic-level impacts of the Plan. ### Strategic case for the Warm Homes Plan The Warm Homes Plan is the government’s strategy to bring down energy bills, upgrade up to 5 million homes by 2030, and decarbonise British buildings. Consequently, it also supports: * progress towards meeting other key government decarbonisation commitments, including the government’s legally-binding Carbon Budgets, our nationally determined contribution (NDC) to the Paris Agreement, and our statutory target of reaching Net Zero greenhouse gas emissions by 2050 * the statutory fuel poverty target for England – to improve as many fuel poor homes as is reasonably practicable to achieve a minimum energy efficiency rating of Band C by 2030 * Alongside the energy mission – to decarbonise the power grid by 2030 and accelerate to Net Zero – the Warm Homes Plan also supports this government’s health and growth missions, by improving health outcomes in British buildings, creating high-quality jobs and boosting domestic supply chains ### Overarching policy intent The Warm Homes Plan will look to increase the deployment of low-carbon technologies across the country. As such, the Plan sets out the following ambitions: 1. That, by 2030, the heat pump market will have expanded to over 450,000 annual installations, as heat pumps increasingly become the natural choice for households replacing an existing heating system at the end of its life, and as the Future Homes Standard and Future Buildings Standard ensure that new homes and buildings have low carbon heating as standard. 2. To more than double the amount of heat demand met via heat networks in England to 7% (27 TWh) via heat networks by 2035. 3. To boost the deployment of generation technologies (such as solar PV), flexibility technologies (such as home batteries) and fabric insulation, to bring down bills for consumers and to give them more control over their energy usage. Our analysis suggests that the plan could support up to 3 million additional domestic rooftop solar installations across Great Britain by 2030. The plan also aims to ensure that the UK’s building stock is adapted to the UK’s future climate. Through the provision of consumer advice and by encouraging the adoption of low-cost passive cooling measures, the plan looks to ensure that those most vulnerable to the impacts of climate change are protected. Support in the ‘Warm Homes Plan’ will be made available to the most vulnerable in our society. That means supporting the fuel poor and those on lower incomes – through both CDEL investment and the implementation of Minimum Energy Efficiency Standards. We will also provide support to the supply chain to ensure that workers (such as fossil fuel heating installers) can benefit from the transition and have ample opportunities to retrain and upskill. ## 2. Check list of key activities to provide confidence that the duty has been considered | Key activity | Considered (Y/N) | | --- | --- | | Have you given sufficient time in your work plan to properly engage with the PSED, before and at the time of the decision? | Y | | Have you used evidence to understand the impact of your policy on protected characteristics separately, against each aim of the PSED? | Y | | Have you considered mitigations against adverse impacts? | Y | | Have you recorded your thinking in this form, and saved this form with key policy/programme documents? | Y | | As the duty is ongoing, have you built in dates to review the impact of this decision? | Y | ## 3. Evidencing equality impacts To show due regard to the equality duty, we commissioned relevant DESNZ teams to gather evidence on the possible equality impacts generated by the policies and proposals contained in the current package. A summary of the results of this commission is laid out in this report. The impact assessment also considers relevant wider literature. See below a summary of evidence used: * Published government data, for example: + Household Energy Efficiency Statistics[[footnote 1]](#fn:1) + Annual Fuel Poverty Statistics in England[[footnote 2]](#fn:2) + Published government data on the ethnicity of fuel poor households and social housing tenants[[footnote 3]](#fn:3) + ONS data on housing outcomes for disabled adults.[[footnote 4]](#fn:4) * Policy Equality Impact Assessments (including equality analyses for the Clean Heat Market Mechanism and the Boiler Upgrade Scheme) * Wider literature, such as studies on the groups most vulnerable to fuel poverty and on the impacts of retrofits on lower-income groups[[footnote 5]](#fn:5) * Government research identifying which groups are most vulnerable to the effects of overheating within UK buildings due to climate change ## 4. Findings – analysis of evidence in respect of equality aims ### Aim 1: Eliminate unlawful discrimination, harassment, victimisation and any other conduct prohibited by the Equality Act 2010 We are not aware of any evidence that suggests that the Warm Homes Plan will lead to an increase in the discrimination, harassment or victimisation of any groups with a protected characteristic. Policies that upgrade homes with low carbon heating solutions may cause disruption to residents, and this has the potential to cause distress, particularly among older people and those with certain disabilities. As a result, we are setting an ambition that for homes needing minor upgrades (such as fuse and/or cut outs) works are completed within 5 days, and even sooner for vulnerable households. For more complex cases (for example, unlooping and cable upgrades) we want to bring down connection times to within a month, and we will work with DNOs, local authorities and residents to address these barriers together. Moreover, we will work to ensure that comfort, health, and well-being are considered in the design and through life management of our capital schemes. ### Aim 2: Advance equality of opportunity between people who share a particular protected characteristic and people who do not share it. The ‘Warm Homes Plan’ sets out a strategy to upgrade homes and improve the energy efficiency of buildings, especially for the fuel poor, low-income owner-occupiers, and renters in private-rented homes or social housing. Studies have shown that groups with protected characteristics – such as the elderly, women, people from an ethnic minority background and people with a disability – have an increased likelihood of energy vulnerability.[[footnote 6]](#fn:6) As such, these policies are likely to have positive impacts on these groups. For example, we will continue to provide fully funded home upgrades to households in lower income groups through our £15 billion package of investment through schemes such as the Warm Homes: Social Housing Fund (up to 2029/2030) and Warm Homes: Local Grant (WH:LG) (up to 2027/2028). These schemes will provide eligible households with technologies that can help them save significantly on their energy bills. Our analysis suggests that typical homes which adopt a heat pump, solar PV and a home battery – an eligible technology package as part of our schemes – could potentially save hundreds of pounds annually on their energy bill, compared to a gas boiler.[[footnote 7]](#fn:7) Given the intersection between ethnicity and income – evidenced by the fact that households with a black household reference person (HRP) had the highest rate of fuel poverty in 2025, at 14.9 per cent (compared to 10.7% for those with a white HRP)[[footnote 8]](#fn:8) – it is likely that these schemes will advance equality of opportunity between ethnic groups. The 2025 fuel poverty strategy sets out an updated policy plan to accelerate progress to the fuel poverty target to improve as many fuel poor homes as is reasonably practicable to achieve a minimum energy efficiency rating of C by 2030. The policies outlined in the Warm Homes Plan will help contribute to a forecast reduction in the number of fuel poor households in England by approximately 1 million by 2030. Within the fuel poverty population, the primary beneficiaries of support for energy efficiency by 2030 will be those in the rental sectors, which represent 56% of the remaining fuel poor households. New minimum energy efficiency standards are anticipated to lift 415,000 private rented sector and 250,000 social rented sector households out of fuel poverty by 2030. Given the overrepresentation of ethnic minorities and other protected groups living in fuel poor homes,[[footnote 9]](#fn:9) this should have the impact of advancing equality of opportunity. For example, Black households are over-represented in the social rented sector,[[footnote 10]](#fn:10) and Black and some Asian households (such as Bangladeshi) are over-represented in the private rented sector.[[footnote 11]](#fn:11) Moreover, evidence shows that people with disabilities are over-represented in the social rented sector.[[footnote 12]](#fn:12) As such, these policies will advance the equality of opportunity with regards to race and those with disabilities – and improved fabric insulation can improve both thermal comfort and health outcomes in households. The delivery of £1.5 billion of additional funding to support upgrades for low income owner occupiers has not yet been determined and will be subject to stakeholder engagement, including consultation with consumer groups and representative bodies for those with protected characteristics, such as Age UK and Scope. We will continue to draw on evidence and statistics relating to fuel poverty and vulnerability to support this, to help ensure that any equalities issues are considered and mitigated. The Plan also looks to promote equality of opportunity through outlining our strategy to ensure that homes are well-adapted to future temperature rises. The building occupants most at risk from overheating and vulnerable to heat stress are the very young (under 5 years old), the elderly and those with pre-existing health conditions and some disabilities. Our research has identified that there is a strong correlation between these groups and the lower socio-economic indicators, and between the buildings in which they live and those most vulnerable to overheat.[[footnote 13]](#fn:13) Addressing this risk for these vulnerable people, in addition to the risk of increasing energy bills for them, is at the centre of the approach suggested within the Plan. Our strategy for deploying new heat networks will benefit consumers, as we will support their deployment where they offer the greatest potential for consumer savings – which is likely to be denser, urban environments. However, it is not possible to say whether this will affect specific protected characteristic groups. Our strategy for existing heat networks is to provide greater regulation and consumer protections. Existing heat network consumers contain a greater proportion of people who are 65 years and older, people with disabilities, and people from ethnic minority backgrounds compared to the general population. The impact of this strategy is assessed to be positive and should therefore advance equality of opportunity between people who share a particular protected characteristic and people who do not share it. We also acknowledge that with the roll-out of clean heating and other low-carbon technologies, there lies a risk that those with a protected characteristic (such as older individuals or those with disabilities) are mis-sold products and technologies.[[footnote 14]](#fn:14) The Warm Homes Plan will ensure that installations must be certified by the relevant competent body such that this risk is mitigated. As an example, with BUS all installers must be MCS certified, which should ensure that consumers are protected and are not sold technologies that are unsuitable for their property (from a technical or an energy perspective). Bill estimates should be provided by the MCS certified installers to property owners ahead of the system being installed, providing protections for all households from significant bill inflation. Similar measures will be in place for each certification scheme to mitigate the risk of older individuals or those with disabilities being mis-sold products or technologies. Studies have also shown that women are at risk of procedural exclusion in the retrofit process, often due to childcare responsibilities: that is, they are more likely to be excluded from participation events (for example, engagement meetings set up by housing providers to inform tenants about the retrofit works in their building).[[footnote 15]](#fn:15) The ‘Warm Homes Plan’ outlines plans for a new impartial consumer advice service delivered by the Warm Homes Agency. To mitigate the risk of exclusion, we expect that this provision of advice will be integrated with local advice services, thereby improving engagement with groups with protected characteristics, such as women. There is also a risk of digital exclusion, given that our policy direction involves a subtle move towards the use of digital technologies. For example, the decision to prioritise the deployment of generation and flexibility technologies could lead to increased digitalisation and a proliferation of Home Energy Management systems. Whilst we believe that this will benefit most consumers, who will be able to more closely and easily manage their energy usage, for older people and people with disabilities there is a risk of digital exclusion.[[footnote 16]](#fn:16) To mitigate this, we will monitor the impact of deployment on older people and those with disabilities and adjust our policies accordingly. This is also a potential risk when it comes to the increased provision of consumer advice through online channels, which some protected groups (such as the elderly and the disabled) will be more likely to not have access to. To mitigate this, we will ensure that our digital advice platform will be backed by a national phoneline. Whilst, as we outline above, millions of consumers will be able to obtain bill benefits from installing measures such as solar PV through the Warm Homes Plan, it is possible that consumers without solar PV will see increases to their electricity tariffs. Based on how retail electricity prices are currently structured, the more self-generated energy solar households consume ‘behind the meter’, the more fixed system costs will likely need to shift onto households drawing their electricity from the grid. We will look to mitigate this potential impact on lower income consumers by deploying solar PV in lower income households through our ‘Warm Homes Plan’ policies, and exploring the role of domestic batteries in reducing overall electricity system costs. We will also continue to monitor the impacts of increased solar deployment on household energy bills. Our plan also sets out our strategy to ensure equality of opportunity for the home upgrade and construction workforce. The home upgrade and construction workforce is currently dominated by white males, and so our ‘Warm Homes Plan’ points to some measures that we are taking to improve the diversity of the sector, and to ensure that ethnic minorities and women are provided opportunities to join the workforce. For example, our policy to bring new entrants into the low carbon heating installer workforce – through the Low Carbon Heating Technician Apprenticeship – will involve working closely with DfE to monitor the diversity of apprentices and promote the apprenticeship to candidates across all protected groups, especially race and gender. ### Aim 3: Foster good relations between people who share a particular protected characteristic and people who do not share it Whilst we have not identified any evidence to suggest that the ‘Warm Homes Plan’ will have a significant impact on the relations between groups who share a particular characteristic and those who do not, the ‘Warm Homes Plan’ outlines our strategy to develop local partnerships, which will have the aim of improving community engagement. In turn, this could help to foster good relations between people who share a particular characteristic and those who do not. ## 5. Recommendation We recommend that we proceed with the ‘Warm Homes Plan’ on the basis that we believe that the strategy has an overall positive impact on equality and, where potential negative impacts exist, we believe they can be mitigated through future policy design and engagement. Further investigation into equality impacts and mitigating actions are required as policies are designed and delivered. ## 6. Monitoring and evaluation Our programmes and policies have evaluation plans already in place or being developed. The specific methodologies and approaches taken will vary across programmes and will encompass both quantitative and qualitative approaches. Delivery of programmes is monitored through the collection of scheme data including the publication of official statistics. This allows us to track deployment as well as assess progress towards benefits such as carbon savings, bill reduction and number of upgraded homes. 1. <https://www.gov.uk/government/collections/household-energy-efficiency-national-statistics> [↩](#fnref:1) 2. [Annual Fuel Poverty Statistics report 2025](https://assets.publishing.service.gov.uk/media/67e51e2cbb6002588a90d5d5/annual-fuel-poverty-statistics-report-2025.pdf) [↩](#fnref:2) 3. [Fuel poverty - GOV.UK Ethnicity facts and figures](https://www.ethnicity-facts-figures.service.gov.uk/housing/housing-conditions/fuel-poverty/latest/#:~:text=Download%20table%20data%20for%20%27By,Data%20sources); [Social housing lettings - GOV.UK Ethnicity facts and figures](https://www.ethnicity-facts-figures.service.gov.uk/housing/social-housing/social-housing-lettings/latest/) [↩](#fnref:3) 4. [Disability and housing, UK - Office for National Statistics](https://www.ons.gov.uk/peoplepopulationandcommunity/healthandsocialcare/disability/bulletins/disabilityandhousinguk/2019) [↩](#fnref:4) 5. For example, see [‘Although it’s my home, it’s not my house’ – Exploring impacts of retrofits with social housing residents - ScienceDirect](https://www.sciencedirect.com/science/article/pii/S2214629624004602#bb0140); [Who is vulnerable to energy poverty in the Global North, and what is their experience?](https://wires.onlinelibrary.wiley.com/doi/epdf/10.1002/wene.455?getft_integrator=sciencedirect_contenthosting&src=getftr&utm_source=sciencedirect_contenthosting) [↩](#fnref:5) 6. [Who is vulnerable to energy poverty in the Global North, and what is their experience?](https://wires.onlinelibrary.wiley.com/doi/epdf/10.1002/wene.455?getft_integrator=sciencedirect_contenthosting&src=getftr&utm_source=sciencedirect_contenthosting) [↩](#fnref:6) 7. Internal analysis, building on the Cost Optimal Domestic Electrification (CODE) study. Notes: (1) savings were modelled for typical terraced, semi-detached and detached housing archetypes. (2) savings will vary depending on the capacity of installations, housing archetype and circumstance (3) figures based on average UK energy prices for 2024 [↩](#fnref:7) 8. <https://assets.publishing.service.gov.uk/media/67e51e2cbb6002588a90d5d5/annual-fuel-poverty-statistics-report-2025.pdf> [↩](#fnref:8) 9. Ibid. 14.9% of black households and 12.2% of Asian households are fuel poor, compared to 10.7% of white households. [↩](#fnref:9) 10. [Social housing lettings - GOV.UK Ethnicity facts and figures](https://www.ethnicity-facts-figures.service.gov.uk/housing/social-housing/social-housing-lettings/latest/): “In the year ending in March 2024, lead tenants from the Black ethnic group made up 7.8% of new social housing lettings – at the time of the 2021 Census, Black people made up 3.9% of the population of England aged 16 and over” [↩](#fnref:10) 11. <https://www.ethnicity-facts-figures.service.gov.uk/housing/social-housing/social-housing-lettings/latest/> [↩](#fnref:11) 12. [Disability and housing, UK - Office for National Statistics](https://www.ons.gov.uk/peoplepopulationandcommunity/healthandsocialcare/disability/bulletins/disabilityandhousinguk/2019): “One-quarter (24.7%) of disabled people in 2019 rented social housing, compared with just 8.2% of non-disabled people.” [↩](#fnref:12) 13. [Assessing the future heating and cooling needs of the UK housing stock](https://assets.publishing.service.gov.uk/media/67a08e731d14e76535afb6b2/CS-N0W_Assessing_future_heating_and_cooling_needs_of_UK_housing.pdf) [↩](#fnref:13) 14. [Home safe: Giving consumers confidence to install low carbon technologies - December 2023](https://assets.ctfassets.net/mfz4nbgura3g/7rZZMRTuhvXiUaVfeT8UCW/992749175b8b867fa8239a78af10fb51/Home_20safe__20Giving_20consumers_20confidence_20to_20install_20low_20carbon_20technologies_20-_20December_202023.pdf). This report highlights, in particular, “a rise in cases of pressure-selling and poor quality installation of spray foam insulation, which have particularly taken advantage of vulnerable consumers looking to reduce their energy bills.” [↩](#fnref:14) 15. [‘Although it’s my home, it’s not my house’ – Exploring impacts of retrofits with social housing residents - ScienceDirect](https://www.sciencedirect.com/science/article/pii/S2214629624004602#bb0140) [↩](#fnref:15) 16. [These are tenants not guinea pigs: Barriers and facilitators of retrofit in Wales, United Kingdom - ScienceDirect](https://www.sciencedirect.com/science/article/pii/S2214629624000537#:~:text=Social%20Practices%20Theory%20and%20Energies,exacerbating%20the%20already%20noticeable%20inequalities.) [↩](#fnref:16)