Citizens Advice response to MCS scheme redevelopment consultation

Citizens Advice response to MCS scheme redevelopment consultation [ 270 kb]

If executed successfully, we are broadly supportive of the changes proposed in this consultation. Our research in recent years has highlighted that the existing protections landscape is failing consumers. The changes proposed here would simplify the MCS scheme (both for consumers and for contractors), while also providing greater alignment with Trustmark. This can drive better consumer outcomes provided the proposals are rigorously developed and implemented successfully. However, wider change would still be needed in the sector in order to truly give consumers the confidence to engage in the energy transition.

Supportive of moves to simplify the landscape

Our research shows that consumers would value having a single point of contact, with clear protections for them if something goes wrong. To that end, if they can be delivered successfully we would be supportive of more functions being centralised within MCS. Moreover, it is good to see alignment between the MCS Customer Duty and Trustmark’s Customer Charter . However, we think the ‘Customer Duty’ could be better named. It uses the language of a regulator, and we are worried this could provide an illusion of enforcement powers that MCS can’t match. Since the creation of a ‘consumer charter’ was a recommendation of the Each Home Counts review, we don’t see a reason why this same language shouldn’t be used here.

More detail needed on how proposals will be implemented

Some of the proposals require more detail before we can fully support them. We address this more in subsequent questions, but we would expect more details on how vulnerable customers will be treated under new rule changes, the short and long-term funding arrangements for proposals, and details on how MCS will ensure adequate third-party oversight over the successful implementation of proposals.

Clarity needed on how Customer Duty will be enforced

Whilst we acknowledge that it is still a draft, it is not clear to us how compliance with the Customer Duty will be assessed. Some of the language used in the Customer Duty may also not be easily understandable to all consumers. As a result, we think MCS should investigate the possibility of simplifying some of the language in the Customer Duty, and creating a parallel document that outlines clearly how compliance with the Customer Duty will be enforced.

MCS must be clear that more work is needed in the sector to protect consumers

Changes to a single scheme only go some way to creating a protections framework fit for a mass rollout of low carbon technologies. In particular, our research points to a need to extend accreditation across the entire sector, and further simplify the network of different accreditation schemes. We see a role for MCS in advocating for these changes more clearly, as it would minimise the risk of more installers moving into the unregulated part of the sector in response to the potential for greater monitoring of their installations.

In our response, we identify several risks that would need to be addressed in order for us to fully support these proposals. In particular, we are concerned that the proposal to transition to a new form of financial protection could come with quite a significant delivery risk - we would support this being looked at once other proposals have been successfully implemented.