CMA backs independent ombudsman and stronger financial protections in response to DESNZ consultation on consumer protection for home upgrade schemes
The Competition and Markets Authority (CMA) published on 23 September 2026 its formal response to a Department for Energy Security and Net Zero (DESNZ) consultation on reforming consumer protection for home upgrade schemes, such as government-backed insulation and green heating programmes. The CMA's response supports the core proposals in the consultation, including the creation of an independent ombudsman, a single complaints and case-management function, and improved financial protections for consumers. The CMA also endorsed proposals for a simpler and more accessible consumer journey and stronger oversight and inspection powers, with the ability to take robust action where consumers have been failed. Drawing on its previous work on consumer protection in the green heating and insulation sector, the CMA highlighted two additional priorities. First, the new arrangements must work effectively for all consumers, including those in vulnerable circumstances and those whose home upgrades are not funded by government-backed schemes. Second, the reforms should give consumers greater confidence to invest in home improvements and upgrade technologies, which the CMA views as essential to achieving the government's net zero objectives. The response underscores the CMA's growing role as a consumer protection authority in regulated sectors, particularly where rapid market growth, such as the expansion of heat pump and insulation installation, creates conditions for potential consumer harm.
Why this matters
The CMA's formal endorsement of an independent ombudsman model for home upgrade schemes is significant because it signals a preference for sector-specific, enforceable redress mechanisms rather than reliance on general consumer law. The CMA's emphasis on extending protections to consumers outside government-backed schemes is commercially important: it suggests the regulator expects the new framework to apply broadly across the green home improvement market, not just where public subsidy is involved. This comes at a moment when the government is scaling up its energy efficiency programmes to meet net zero targets, making robust consumer protection architecture a prerequisite for market confidence. The explicit reference to the CMA's prior work in green heating and insulation shows this is a sustained regulatory focus rather than a one-off intervention.
On the Ground
Regulatory lawyers will be tracking whether DESNZ adopts the ombudsman model in its final policy, which will shape the legal framework governing installers and scheme providers across the home upgrade market. Consumer law and energy regulatory practices will advise clients, including installers, warranty providers, and financial protection scheme operators, on compliance with the new regime once finalised. A trainee on this matter would draft summaries of the CMA's consultation response, prepare regulatory notification memos comparing the proposed requirements against existing consumer protection frameworks, and maintain a remediation tracker as the final regime takes shape.
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“How does the CMA's support for an independent ombudsman in the home upgrade sector fit with its wider approach to consumer protection, and what does it mean for businesses operating in that market?”
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