Policy paper

Warm Homes Fund call for evidence: CFP response

Published 11 June 2026

1. Introduction

1. The Committee on Fuel Poverty (the Committee) is an Expert Committee sponsored by the Department for Energy Security and Net Zero (DESNZ). The Committee advises on the effectiveness of policies aimed at reducing fuel poverty and encourages greater co-ordination across the organisations working to reduce fuel poverty.

2. As currently proposed, the Warm Homes Fund is likely to have very limited impact in terms of reducing fuel poverty for owner occupied homes. Multiple studies have shown that most of these households are likely to be currently under-heating their homes and living in cold, damp and energy inefficient properties to better manage their ability to meet energy costs.

3. This means owner occupied fuel poor households that do receive energy efficiency upgrades to their home – almost all of which are typically 100% grant-funded – take the benefit of a more efficient home in the form of increased comfort rather than the creation of additional disposable income. Low levels of disposable income – often coupled with existing energy debt, which is rising across the population – are a key factor in evidencing why grant-based support for owner occupied fuel poor homes remains the most effective route to reducing fuel poverty in this demographic^{[footnote 1]}.

4. However, the Committee welcomes the commitment to allocate “up to £600m to support low-income households, ensuring the transition to low carbon homes is fair and delivers for all”. The key will be translating this into delivery and impact in a meaningful way, which means finding the right target groups to whom action can be properly directed.

5. With this in mind, the Warm Homes Fund could have an important role to play in the private rented sector, which is a key focus for the Committee. If it is targeted in the right way, then the Fund could support landlords in achieving SRS and PRS Minimum Energy Efficiency Standards. However, it will be difficult to get the required level of traction and momentum in a notoriously fragmented and diverse space. The Fund will have to ensure that the right level of resource is allocated to make it properly focused, well targeted and made accessible to the right landlord groups if it is to have a meaningful end state impact for fuel poor tenants. Targeting lower income landlords will enable retrofit work to be completed that may not otherwise have been possible. Equally there needs to be a clear framework of governance and assurance to ensure resources are well spent with quality outcomes.

Please note that this this response only contains responses to the questions that were relevant to the Committee’s subject area.

2. Response

Question 1: Do you agree with our assessment of the strategic opportunities, challenges and risks presented by warm homes financial transactions? Please provide evidence to support your response.

6. The Warm Homes Fund presents an opportunity to further drive momentum in the uptake of energy efficiency improvements, supporting an increase in the scale and pace of retrofit, which is the most sustainable way to remove households from fuel poverty. Provided the right mechanisms and incentives are in place to meaningfully realise the value of the £600m that has been ringfenced for low-income households, then the Fund will have the ability to make an impact on fuel poverty at an important time. Equally there needs to be a clear framework of governance and assurance to ensure resources are well spent with quality outcomes.

Question 4: How should the Warm Homes Fund ensure that it includes an offer suitable for those on low incomes? Any information on specific models is encouraged

7. The Fund is unlikely to have a significant impact on owner occupiers in fuel poverty, and there could be adverse consequences if it were to be actively targeted at this particular group of households. The consultation acknowledges that fuel poor homes already underheat their homes and typically take the benefit of improved energy efficiency in increased comfort, supporting better physical and mental health. This demographic is not well placed to take on additional debt or repayment commitments, and it is difficult to see how any traction or scale could be achieved in this sector.

8. There is much greater potential for the Fund to focus its low-income interventions on fuel poor homes in the private rented sector, which should be strongly encouraged. Further work should be undertaken to help the Fund gain momentum in what is a notoriously fragmented and diverse space. Specific work should be undertaken to make it properly focused, well targeted and made accessible to the right landlord groups (i.e. those with lower incomes, who may need support accessing finance) if it is to have a meaningful end state impact for fuel poor tenants.

9. We recognise the potential to support heat networks and community energy initiatives, but this is likely to have a lower impact than a more targeted focus on private landlords and their tenants.

Question 5: Do you agree with the proposed overarching aims of the Warm Homes Fund?

10. If the Fund has made the not insignificant commitment to potentially allocate £600m specifically to low-income consumers, then it would seem sensible to directly reference the reduction of fuel poverty within the Fund’s overarching aims.

Question 8: Do you agree with the proposed list of activities the Warm Homes Fund could support and are there any other types of activities that should be supported?

11. Given the response to question 4 above and the clear benefits that could be delivered in respect of reducing fuel poverty in the private rented sector, the Fund should consider allocating resource to facilitate effective and proactive private landlord engagement and the potential development of targeted, bespoke incentives in this area.

Question 21: What barriers and opportunities do private landlords encounter when accessing loans or investing in warm homes upgrades for their properties and how could the Warm Homes Fund help them overcome these barriers?

12. The key challenges here are around accessibility, the straightforwardness of the offer and full clarity about quality and compliance. The private landlord audience is a fragmented one, and simplicity and clarity are key to cutting through.

Question 22: What are the barriers that affect the ability for social housing providers to invest in warm homes upgrades? And how could the Warm Homes Fund support?

13. Although social landlords can’t necessarily access PWLB, many of the larger RSLs are already leveraging their balance sheet strength and market positioning as pseudo-public sector organisations to access preferential rates on borrowing and investment. The Warm Homes Fund should explore any potential routes to make it easier for them to test investment in energy efficiency upgrades for their tenant base.

Question 40: Would the energy as a service models outlined (or any others, including those emphasising consumer-led flexibility) support the draft Warm Homes Fund aims, when could benefits be realised, and what risks need to be considered?

14. The range of technologies that will underpin heat as a service can clearly provide benefit to fuel poor households in terms of lower bills and increased comfort. The Fund should consider several routes that effectively skew the rollout of such models in a way that provides disproportional benefit to those households with most to gain.

Question 61: How could the Warm Homes Fund support the market growth of heat networks as set out in the Warm Homes Plan?

15. The Fund has an opportunity to support this market growth. However, given that the Fund has committed up to £600m to create benefit for low-income households, then it should consider designing project selection criteria and targeting demographic areas for intervention where it can be shown that said intervention will create higher levels of benefit for these same homes and communities.

Question 66: How would investments in community energy projects (including generation and flexibility) or community buildings support the draft Warm Homes Fund aims, when could benefits be realised, and what risks need to be considered?

16. The Fund has an opportunity to support this market growth. However, given that the Fund has committed up to £600m to create benefit for low-income households, then it should consider designing project selection criteria and targeting demographic areas for intervention where it can be shown that said intervention will create higher levels of benefit for these same homes and communities.

1. Energy debt: Everyone pays - Energy UK ↩