Policy paper

Warm Homes Plan: Public Sector Equality Duty Equality Impact Assessment

Published 21 January 2026

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]}
  • Annual Fuel Poverty Statistics in England^{[footnote 2]}
  • Published government data on the ethnicity of fuel poor households and social housing tenants^{[footnote 3]}
  • ONS data on housing outcomes for disabled adults.^{[footnote 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]}
• 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]} 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]} 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]} – 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]} this should have the impact of advancing equality of opportunity. For example, Black households are over-represented in the social rented sector,^{[footnote 10]} and Black and some Asian households (such as Bangladeshi) are over-represented in the private rented sector.^{[footnote 11]} Moreover, evidence shows that people with disabilities are over-represented in the social rented sector.^{[footnote 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]} 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]} 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]} 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]} 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 ↩

2. Annual Fuel Poverty Statistics report 2025  ↩

3.  Fuel poverty - GOV.UK Ethnicity facts and figures; Social housing lettings - GOV.UK Ethnicity facts and figures ↩

4.  Disability and housing, UK - Office for National Statistics  ↩

5. For example, see ‘Although it’s my home, it’s not my house’ – Exploring impacts of retrofits with social housing residents - ScienceDirect; Who is vulnerable to energy poverty in the Global North, and what is their experience? ↩

6. Who is vulnerable to energy poverty in the Global North, and what is their experience? ↩

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 ↩

8. https://assets.publishing.service.gov.uk/media/67e51e2cbb6002588a90d5d5/annual-fuel-poverty-statistics-report-2025.pdf ↩

9. Ibid. 14.9% of black households and 12.2% of Asian households are fuel poor, compared to 10.7% of white households. ↩

10. Social housing lettings - GOV.UK Ethnicity facts and figures: “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” ↩

11. https://www.ethnicity-facts-figures.service.gov.uk/housing/social-housing/social-housing-lettings/latest/ ↩

12.  Disability and housing, UK - Office for National Statistics: “One-quarter (24.7%) of disabled people in 2019 rented social housing, compared with just 8.2% of non-disabled people.” ↩

13. Assessing the future heating and cooling needs of the UK housing stock ↩

14. Home safe: Giving consumers confidence to install low carbon technologies - December 2023. 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.” ↩

15.  ‘Although it’s my home, it’s not my house’ – Exploring impacts of retrofits with social housing residents - ScienceDirect ↩

16. These are tenants not guinea pigs: Barriers and facilitators of retrofit in Wales, United Kingdom - ScienceDirect ↩