Consultation outcome

Summary of responses and government response

Updated 6 March 2026

Introduction 

The Department for Environment, Food and Rural Affairs (Defra) published a consultation on proposed reforms to the WaterSure scheme in the water sector. This was open for responses from 21 July to 1 September 2025. The consultation was conducted primarily through the Citizen Space online consultation tool and was supplemented with some email communications and engagement with stakeholders. 

This publication includes: 

• a summary of responses received, with basic analysis of responses and themes of note 

• a government response and planned next steps 

The analysis presented in the summary of responses is mostly based on the formal responses received through Citizen Space and by email. Additional themes brought out through the informal engagement processes alongside the consultation have been taken into consideration in the production of the government response. 

Background 

WaterSure was introduced in 1999 through the Water Industry (Charges) (Vulnerable Groups) Regulations. The Regulations were subsequently added to in 2000, 2003 and 2005 to include minor amendments e.g. making home dialysis patients eligible for WaterSure only if they do not receive support from a health authority to cover the cost of extra water use. In 2015, all prior regulations were consolidated into the Water Industry (Charges) (Vulnerable Groups) (Consolidation) Regulations 2015. 

WaterSure is a statutory scheme water companies must provide to eligible customers. The scheme caps water bills for low-income households who have high essential water use due to having a qualifying medical condition or having three or more children in residence and are entitled to receive child benefit. 

The policy is designed to safeguard low-income households and households with medical conditions that cause high water usage from financial hardship by capping their bills at the average household charge for water and sewerage services in their company’s area. Eligibility is targeted at metered customers in receipt of qualifying means‑tested benefits, with criteria designed to capture households either with three or more children under 19 or with a medical condition that necessitates high essential water consumption. 

WaterSure is funded through cross subsidy from customer bills. This currently adds around £2-3 to customer’s annual bills. WaterSure currently supports over 220,000 households in England and Wales, with average annual bill savings in excess of £300 a year. Some companies have voluntarily expanded their approach by introducing WaterSure Plus, an enhanced package of affordability support. These enhanced schemes often extend eligibility beyond the statutory minimum or provide greater bill reductions. However, under current rules, the additional costs of WaterSure Plus cannot be added to customers’ bills, meaning companies must absorb or fund those enhancements through other means. 

The scheme has remained relatively unchanged over the past 25 years. In light of this, the Consumer Council for Water (CCW), the statutory consumer representative body in the water sector, undertook a call for evidence on reforms to WaterSure and published recommendations for improvement in January 2025. The government independently assessed these recommendations with wider stakeholder engagement and incorporated these recommendations into the proposals that were consulted on between 21 July to 1 September 2025. 

The proposed changes to update the WaterSure regulations for customers in England included: 

• extending the list of qualifying benefits to include non-means-tested disability benefits for those claiming through a qualifying medical condition 

• updating the WaterSure bill cap to the amount of the average metered or unmetered bill (whichever is lower) 

• capping bills for single occupiers at the average bill for a single occupier 

• removing the option for water companies to require a medical practitioner’s note for health conditions not specifically listed in the WaterSure regulations

• specifically listing more potential qualifying medical conditions 

The proposed changes included in this consultation are expected to apply to England only. Welsh Government has indicated that it will not concurrently pursue the statutory implementation of WaterSure as the scheme is currently offered voluntarily by water companies in Wales. 

Summary of responses 

63 responses were received in total. 54 were via Citizen Space (Defra’s online consultation tool, referred to as ‘Online responses’) and the remaining 9 were sent via email (where 3 of these respondents responded broadly to the proposals rather than answering the questions directly). 

Of the respondents who responded to the questions directly via Citizen Space or email: 

• 34 were categorised as ‘a customer or individual’ 

• 12 were representatives of water companies and retailers 

• 8 were representatives of sector stakeholder groups and regulatory bodies 

• 6 respondents selected the ‘other’ category 

Of the 3 respondents who responded indirectly to the consultation: 

• 1 was a representative of a water company 

• 2 were representatives of sector stakeholder groups and regulatory bodies 

As 3 respondents did not answer the questions directly, these responses were analysed separately in the ‘miscellaneous response’ section.  The following section details the responses for the remaining 60 respondents. 

All 60 online respondents were asked if, prior to the consultation, they were aware of the WaterSure: 

• 32 responded ‘Yes’ 

• 25 responded ‘No’ 

• 2 responded ‘Unsure’

• 1 did not answer 

All 60 online respondents were asked if they or someone in their household has been in receipt of WaterSure support in the past year: 

• 2 responded ‘Yes’

• 34 responded ‘No’

• 4 responded ‘Unsure’ 

• 3 responded ‘Other’ 

• 17 did not answer 

Analysis of responses 

Methodology 

Questions were posed to respondents on proposals to: 

• extend the list of qualifying benefits to include non-means-tested disability benefits for those claiming through a qualifying medical condition 

• update the WaterSure bill cap to the amount of the average metered or unmetered bill (whichever is lower) 

• cap bills for single occupiers at the average bill for a single occupier 

• remove the option for water companies to require a medical practitioner’s note for health conditions not specifically listed in the WaterSure regulations 

• specifically list more potential qualifying medical conditions 

For each proposal, respondents were asked if they support the proposal overall and given an opportunity to explain why they did or didn’t support the proposal. 

For each question, respondents could answer ‘Strongly agree’, ‘Agree’, ‘Neither agree nor disagree’, ‘Disagree’, ‘Strongly disagree’, or ‘Don’t know’. For each answer respondents were given an opportunity to explain why they had selected a particular option. 

The ‘Strongly agree’, ‘Agree’, ‘Neither agree nor disagree’, ‘Disagree’, ‘Strongly disagree’, or ‘Don’t know’ responses received online via Citizen Space have been quantified. Defra has conducted a thematic analysis of the qualitative comments from both online and email respondents. In the following sections is a summary of the analysis, a government response and planned next steps. 

Defra has analysed written responses received by email and has considered them in the context of specific consultation proposals where appropriate. Otherwise, the responses have been considered more broadly as applying to the proposals as a whole. This analysis is included in the following summary of analysis. 

Summary of analysis – consultation responses 

We have summarised all online and emailed responses which followed the consultation format and provided answers directly to the questions included in the consultation.  

The support from recipients who responded directly to the questions for the proposed recommendations ranged from 37% to 78% agreement. The median support for the questions was 67% showing the response was generally favourable but there were two questions where less than 50% of respondents selected ‘strongly agree’ or ‘agree’ which indicates that not all proposed recommendations were welcomed by respondents. We will look at these questions in more depth below. 

Across all proposals, only 26% of respondents on average expressed disagreement. This low level of opposition indicates that the proposals were generally well received and reaffirms that there was broad support for the reforms. In many cases, respondents who withheld their support did so not because they opposed the proposal’s objective, but due to technical or detailed concerns rather than disagreement with the proposal. 

In the following sections we will be analysing the online responses by question to better show the breakdown of responses. 

Consultation Part 2.1 

Under this section we posed three questions. The first question sought an overview of support or opposition to extending eligibility for more households with disabilities. The following two proposals were to ascertain whether respondents agreed or disagreed with including an income threshold to limit eligibility to low-income households and whether the income threshold, when calculated, should include non-means tested disability benefits. 

Proposal 1: extending eligibility to include non-means tested disability benefits for those claiming through a qualifying medical condition (subject to income threshold). 

From respondents who replied directly to the questionnaire 75% supported extending the eligibility criteria of the scheme. Whereas 18% disagreed with extending the eligibility criteria and 7% either neither agreed or disagreed or did not answer. 

Two reasons respondents cited for agreeing with the threshold were: 

• there was broad agreement focused on the benefits from extending the eligibility criteria to capture more households with disabilities that lead to high essential water usage 

• several water companies and retailers and charities agreed that there are increased costs associated with disability and people that have a condition that leads to high water usage should be eligible for WaterSure 

One water company noted that by including non-means tested benefits as part of the eligibility criteria there is a risk that the cross-subsidy might be funded by households that have greater affordability issues. We agree that the scheme should be targeted to support low-income households which is why we proposed to include an income threshold which would limit eligibility to households that need support most. 

Several respondents expressed support for the proposal, citing data from the disability charity Scope. Their research found that households with a disabled member require, on average, £1,095 more per month to achieve the same standard of living as those without a disabled member. The report highlighted that current benefits are insufficient to cover disability-related expenses, which often include higher energy bills, increased food costs, insurance premiums, specialist equipment, and therapies. 

Proposal 2: Setting the income threshold at 60% of median income for those applying under this eligibility criteria. 

We found that 47% of respondents agreed with applying the threshold at the 60% median income. The reasons respondents cited for agreeing with the threshold were: 

• using median income was seen as better than setting the government setting a pound figure which would need regular updates in legislation 

• 60% of median income is a widely accepted threshold for low income and would be a good threshold to make sure WaterSure targets the households which need support most 

We found 35% disagreed with applying this threshold. This was above the 26% average across all proposals. The main concerns shared by respondents who disagreed were: 

• a concern that the proposed threshold was too low and should be raised to capture more people was disabilities that lead to high essential water usage 

• water companies raised that expanding eligibility to households on non-means tested disability benefits may conflict with other social tariffs that support low-income households 

• a concern that this may bring too many people onto the scheme and inflate the cross subsidy

19% of respondents neither agreed or disagreed, were unsure, or did not answer. This was the question which created the most indecision amongst respondents. One respondent highlighting the need for more data and modelling is required to see how this will affect cost and the cross-subsidy. 

Proposal 3: including non-means tested disability benefits in income calculations showed: 

This was the only proposal where more respondents disagreed with the proposal than agreed with it. The consultation results show 37% of respondents supported including non-means tested disability benefits in income threshold calculations. Whereas 52% of respondents opposed the proposal. 

The key concerns of those who did not support the proposal were: 

• other income calculations do not include these benefits, there is not much justification to do it when calculating an income threshold 

• these benefits are to cover general increases in costs caused by having a disability and not to cover high water bills due to having a medical condition which requires the use of more water 

• there were concerns that requiring customers to submit income and benefit information might complicate the application process  

The key reasons for those who supported the proposal were: 

• it was stated that the benefits are designed to pay for the higher water bills in the first place  

• that to make the system as fair and consistent as possible all income streams should be included when calculating household income 

Results show that 12% neither agreed or disagreed, were unsure, or did not answer. One respondent stated this was due to the need for further modelling and data to see the effects of this proposal. 

Consultation part 2.2 updating the WaterSure bill cap to the amount of the average metered or average bill, whichever is lower. 

We found that 67% of respondents agreed with updating the WaterSure bill cap to the amount of the average metered or average bill showing clear support for this proposal. The main reasons respondents cited for agreeing with the threshold were: 

• this will make the use of the average bill consistent across water companies

• capping bills to the lower average type of bill will save eligible customers money  

We found only 17% disagreed with capping bills at the lower of the average metered bill or average bill. This falls below the 24% average across all proposals. The main concerns shared by respondents were: 

• the cap should only be the metered bill  

• the cap should depend on the household size  

Despite strong overall support for the proposal, 17% of respondents neither agreed or disagreed, were unsure, or chose not to answer. This suggests that while many agreed, a portion of respondents were unconvinced. Comments from respondents highlighted the need for further analysis of data to fully support the recommendation. 

Consultation Part 2.3 capping bills for single occupiers to the average bill for a single occupier. 

This recommendation received the highest level of support amongst our proposals, with 78% of respondents either agreeing or strongly agreeing. The main reasons respondents cited for agreeing with capping bills for single occupiers were: 

• this change makes the scheme more accessible to those who live on their own, and whose bills may previously have fallen below the average household bill 

• the recommendation could be easily implemented as single occupancy data is usually collected by local authorities

We found only 11% disagreed with applying this threshold. This is well below the 24% average across all proposals. The main concern shared by respondents were: 

• concerns of admin cost to businesses and collecting evidence on confirming single occupancy 

10% of respondents neither agreed or disagreed, were unsure, or did not answer. From comments left by respondents the main reason was on the reliability and access to council single occupancy data. 

Consultation part 2.4: removing the option for water companies to require a medical practitioner’s note in respect of health conditions not specifically listed in the WaterSure Regulations.  

We found that 58% of respondents agreed with removing the options for water companies to require a medical note. The main reasons respondents cited for agreeing with the threshold were: 

• this is a practice water companies have voluntarily agreed too  

• obtaining a GP letter is difficult and includes other barriers such as costs. This will help to remove these  

We found 33% disagreed with this proposal which makes it the proposal with the second highest number of respondents who opposed it. The main concerns shared by respondents were: 

• the potential for fraud was highlighted 

• there is a need to confirm qualifying conditions in some manner  

9% of respondents either neither agreed nor disagreed, were unsure, or did not provide an answer. Comments suggest that this lack of clear support was not necessarily due to opposition to the proposal, but rather a desire for the government to issue clearer guidance on what constitutes acceptable evidence of eligibility. 

Consultation Part 2.5: specifically listing more potentially qualifying medical conditions 

This recommendation received strong support, with 69% of respondents agreeing or strongly agreeing with the measure. The main reasons respondents cited for agreeing with the threshold were: 

• adding to the list will give further confidence to those applying to WaterSure and may help to validate the customer’s condition  

• this may help those with dementia to confidently apply to the scheme

We found 15% disagreed with this proposal. The main concerns shared by respondents were: 

• removing the list entirely may be the answer to transparency and keeping the scheme open ended  

• guidance may be more suitable to making it clear with what cases/conditions are suitable for WaterSure  

16% of respondents either neither agreed nor disagreed, were unsure, or did not provide an answer. Comments suggest that this lack of clear support was not necessarily due to opposition to the proposal, but that these respondents were not convinced that adding conditions to regulations would have a material impact on applications. 

Consultation part 2.6: Data Sharing 

We posed two questions as part of the data sharing section. These were to gather views about the existing data-sharing barriers between water companies and government and how government could increase awareness of WaterSure amongst those who are digitally excluded. We did not provide an agree or disagree option for these questions, instead we have compiled the written responses by themes. 

Firstly, the themes for respondent views on the barriers to existing data-sharing between water companies and government: 

• certain water companies articulated the struggle to identify all financially vulnerable households because data sharing is limited to those already flagged as having a vulnerability 

• data matching between water companies and government systems is hindered by record volume limits and a lack of household-level data 

• some respondents called for a government-led approach to streamline eligibility checks and data sharing regulation and practices 

Secondly, here are the themes on how government could increase awareness of WaterSure for the digitally excluded: 

• multiple respondents advocated for automatic enrolment onto WaterSure wherever possible, to ensure vulnerable or digitally excluded households receive support without needing to actively apply 

• cross-sector advertising campaigns were suggested across water companies and government, including the involvement of NHS and DWP to inform eligible customers

• third sector organisations suggested embedding sign-up in primary care settings and linking to social prescribing services to simplify access for those with medical conditions and who are digitally excluded

Consultation part 2.7

Finally, respondents were invited to share any additional thoughts on the WaterSure consultation. While some chose not to provide further comments, several common themes emerged among those who did. There was general support for widening eligibility to capture more households with disabilities that lead to high essential water usage. Other themes that come through the consultation included: 

• one water company observed issues with securing permission to install water meters for social housing tenants

• personal respondents queried the impacts of increasing eligibility would have on bill payers

Summary of analysis – miscellaneous responses 

We received responses via email that did not follow the questionnaire format laid out in the consultation. We have classified these responses as miscellaneous. They were thematically and qualitatively analysed to bring out key themes which we explore in more detail below. 

Emailed responses 

Defra received 3 miscellaneous responses, which were analysed in terms of support and concerns regarding the proposals. 

Of the 3 responses, 2 expressed support for some or all of the proposals, while 1 opposed them. Notably, all 3 of the responses did not directly reference the consultation questions but discussed the proposals as a whole. Of these, 1 conveyed concern on the lack of information regarding the cost to customers and businesses created by the reforms and indicated that further analysis is required. However, these responses did not address updates to the WaterSure scheme. 

2 responses raised concerns on data sharing amongst water companies and government. One response stated there is need for additional data from DWP and local authorities to help enhance auto-enrolment. Another response stated there will need to be improved data sharing arrangements between industry and government to make the process of applying for support as accessible and targeted as possible across water support schemes. Improving the application process will also be an efficient route to save water company from administrative costs of verifying customer eligibility. 

1 response highlighted that WaterSure will need to be reformed whilst keeping in mind the broader landscape of affordability support and any other future reforms to affordability schemes. The response also flagged the need to consider how this scheme will be affected with innovative charges for households and reforms to consumers as a whole. 

Overall, while email responses supported the proposals as a whole, there were concerns about the cost to business and customers and how other consumer reforms might interplay with the proposed reforms to WaterSure.  

Water company responses 

There were 1 written email response and 11 Citizen Space submissions from water company respondents. 

Defra conducted a thematic analysis of all water company responses, including the response received by email. We found that water companies expressed support for most of the proposals, while one response showed opposition to several proposals but supported specific aspects. No response was entirely opposed to all proposals. Several water companies indicated agreement with the proposals but did not select ‘agree’ or ‘strongly agree’ due to associated concerns. For example, one company withheld support pending further guidance to accompany the proposals. 

One common theme raised by companies in these responses was a call for better data sharing between government and water companies. Current data sharing was said not to be suitable for processes such as auto-enrolment. Additional respondents noted that information from HMRC is also needed to help to identify households with low incomes and provide them with the most beneficial social tariff.  

Government response 

Responses to the consultation were broadly supportive of the proposed changes. Among those who did not support the proposals, the most common concern was the lack of data included in the consultation to demonstrate the potential impacts of the reforms. Defra has conducted analysis to model impacts of the expected impacts of the proposed reforms. 

The consultation responses received have played a key role in shaping the policy positions. Further detail on how these responses have influenced Defra’s approach is provided in the ‘Changes to Proposals’ section below.  

The updates applied to the WaterSure scheme will serve the same purpose as the existing scheme: to safeguard low-income families and households with medical conditions by capping their bills at the average household charge for water and sewerage services in their company’s area.  

Defra will therefore proceed to implement updates to the WaterSure scheme by bringing forward secondary legislation. 

The legislation will amend the existing regulations to: 

• extend eligibility to disabled households in receipt of a disability benefit 

• increase support where appropriate for existing WaterSure customers 

• update the Regulations to mirror current water sector best practice 

• remove the requirement for customers to submit an application 

Alongside the amendment to regulations, guidance will be brought forward to compliment the regulations and highlight established best practice. 

The amendments brought forward have taken responses to the consultation into consideration, with reasoning for changes to the original proposals detailed below. 

Changes to proposals 

In general, responses to the proposals were positive. 

All proposals to reform WaterSure, aside from including non-means tested disability benefits in an income threshold, received positive support. As a result, the proposal to include non-means tested benefits in an income threshold, on which Defra consulted, has been reviewed. Alongside this, further analysis has been undertaken to support the full suite of reforms we have brought forward. 

Defra has considered how the original proposals can be improved upon in the following cases, particularly accounting for respondents who highlighted where further data is necessary to show the impacts of the following proposals: 

• at what level to set an income threshold

• including non-means tested disability benefits in an income threshold

• extending the list of medical conditions included in the regulations 

Following the responses to this consultation, Defra undertook further policy development and data analysis on the proposed reforms. Work with stakeholders across government and industry also helped inform the changes to the proposals as laid out below. 

The key changes to the proposals contained in the consultation are laid out in the following sections. 

Income threshold level 

Responses received through the consultation prompted Defra to review the appropriate level at which an income threshold should be set, in order to effectively target low-income households with disabilities that result in high essential water use. A significant proportion of responses focused on the 60% of median income threshold being too low. Respondents outlined the increased costs associated with a disability and that setting the threshold at the relative low income didn’t take into consideration the extra living costs of having a disability.

53% respondents disagreed with the suggested threshold of 60% median income, the relative poverty indicator. This included 7 non-government organisations and 7 water companies, which stated this threshold was too low to effectively capture vulnerable households. Several respondents referenced Scope’s findings, which show that disabled households face additional costs of around £1,095 a year.  

As a result, further work has been undertaken to assess the impacts of different income thresholds. This work includes a review of alternative income thresholds and further analytical work by Defra to understand their potential impacts. 

To ensure the scheme better reflects the additional costs of having a disability and aligns with existing WaterSure support provided to those on means tested benefits, Defra proposes to increase the income threshold to mirror the benefit award of a couple on Universal Credit where a disability is present.  

This approach will more effectively support low-income households where a disability is present. Defra proposes to set the income threshold at £25,745, which will extend support to an additional 52,897 households. 

Including non-means tested disability benefits in the income threshold 

A high percentage of respondents disagreed with including non-means tested disability benefits in the applied income threshold. In the consultation and stakeholder sessions Defra repeatedly heard that it is not a standard practice to include disability benefits when calculating household incomes.  

Respondents raised concerns that including disability benefits in the income threshold will create a complicated application process that adds to water company administrative costs required to verify applicant eligibility, and would therefore potentially increase the cost of the scheme for consumers. 

Consultation responses also highlighted that disability benefits such as Personal Independence Payments are intended to help meet wider disability‑related costs and are not designed to cover high water usage.  

These considerations, along with concerns about creating a more complex and burdensome application process, have informed the decision to exclude non‑means‑tested disability benefits from an income threshold under the reformed WaterSure scheme.  

Extending the list of conditions 

 The current regulations provide that households are eligible for support where a person in the household suffers from the specific medical conditions listed in the regulations, or are suffering from a condition which results in the use of a significant additional volume of water. In the consultation, we considered whether additional medical conditions should be added to the list, as water companies and industry stakeholders had highlighted the risk of customers self-eliminating as their condition was not specifically listed in the regulations, despite eligibility.  

We asked whether there were any conditions that regularly lead to high water usage which should be explicitly listed in the regulations. While there was general support for the proposal, there was insufficient quantitative data submitted to indicate which conditions regularly lead to high essential water usage. 

Further work was undertaken to identify possible conditions which could be added to the regulations. Defra worked with the National Health Service and the Department of Health and Social Care to understand the potential conditions that could regularly lead to high essential water usage. Though this work provided useful insights Defra was unable to obtain sufficient data to clearly demonstrate which conditions consistently lead to high essential water usage. Without this evidence, it is difficult to determine which conditions should be explicitly included in the regulations and which should be out of scope. 

Defra remains committed to reducing barriers to access and ensuring that individuals do not self-exclude simply because their condition, or one similar, is not explicitly listed. Instead of extending the conditions explicitly listed in the regulations, Defra will introduce guidance to instruct water companies to use inclusive language in their application process and communications to prevent self-elimination. While non‑statutory guidance cannot guarantee that customers will not self‑eliminate, advising water companies to adopt more inclusive language in their application materials and communications should help support the same aim, without requiring the government to determine which specific medical conditions should or should not be added to the list. 

Next steps 

Following the publication of this response document, Defra will bring forward secondary legislation to implement the recommendations set out above.