Warmer Homes Plan Release

We are finally here. The plan has been released, and on the whole, it seems a considered push to stabilise, reassure and innovate our sector, which is always welcome.

Some of our collective opinions are as follows, and while sounding negative in places should be considered in-line with the general positivity brought about by the plan. There appear to be more pro’s than con’s so here are our thoughts:

Decarbonisation and Electrification – Risks in the rush

The plan, as expected, appears to prioritise electrification and on-site generation and storage (heat pumps, solar PV and batteries) as a route to reducing household energy bills, marking a shift away from the historic insulation-first sequencing of retrofit programmes under the likes of SHDF/SHF, HUG, ECO and GBIS. The underlying aim is clearly to accelerate the transition away from combustion-based fossil fueled heating while still enabling fabric improvements as appropriate. However, whenever large-scale investment is mobilised at pace, there is a risk (based on previous, recent sector experience) that holistic, dwelling-led decision-making falls down the priority list. Concerns remain around pre-existing building condition, interactions between measures, and the integration of retrofit within long-term asset management strategies, particularly in social housing. This brings the focus back to data quality, stock condition surveys, and the competence and skills needed to avoid rushing heat pumps and solar into homes that are poorly insulated or inadequately ventilated.

EPC C by 2030 – Surveys and cost caps

If EPC (and therefore, potential MEES compliance) shifts to a new methodology, organisations will need to re-test their retrofit pathways, as what constitutes “good” performance may differ significantly from current EPC outcomes. The sector will also face the practical reality of surveying virtually every rented property in the country. While the MEES consultation recognises some crossover and allows the use of existing valid EPCs, there will still be a requirement for millions of assessments over the next decade, alongside mechanisms to bring sub-C homes up to standard, likely subject to a cost cap for harder-to-treat properties. How this is implemented will have major implications for delivery capacity and prioritisation.

Financing – Is it just about the money?

Loan and “innovative finance” mechanisms have the potential to remove upfront cost barriers, but uptake will still depend on consumer confidence, installer capacity and running-cost signals, particularly the relationship between electricity and gas prices. Models such as equipment rental or shared-payback comfort plan and ESCO arrangements for solar and batteries are already being trialled and available and could support this transition, while zero- and low-interest loans may appeal to homeowners seeking energy autonomy without releasing capital. However, finance alone will not resolve the technical and behavioural dimensions of retrofit.

Fabric Last – The wrong signals?

A particular concern is that the policy narrative could be interpreted as signalling that insulation is now secondary, especially with the comments around wall insulation that could be construed as a permissible move away from EWI and IWI. While there is acknowledgement that fabric measures still have a role, the feeling that they are “no longer the prime objective” is potentially misleading. Insulation remains fundamental to reducing space-heat demand and ensuring that heat pumps operate efficiently and affordably. There is already evidence of installers and designers pursuing “quick-win” solar-only schemes, sometimes neglecting fabric or failing to comply with PAS 2035, which risks repeating the issues realised in the NAO report (which is acknowledged and referenced). It is, however, comforting to see that PAS 2035 has not been held as an issue and remains a requirement for funded retrofit projects. Installing a heat pump into a poorly insulated home, especially at current electricity prices, has potential to increase running costs and undermine confidence in low-carbon heating. Strong delivery governance and consumer protection through PAS2035, PAS 2030 and MCS therefore remain essential. While the plan broadly recognises the need for higher standards, this must be embedded in the structures through which funding is released and work is procured, rather than assumed to emerge organically from market growth – so the formation of a Warm Homes Agency specifically for this plan is welcome.

The Labour Market and Upskilling

Workforce capacity is another critical constraint, which is addressed as a chapter within the plan, with one particularly conspicuous absence. Although there is some funding for training and manufacturer support, there is little clarity on how the existing base of gas engineers and plumbers (estimated at well over 100,000) will be retrained at scale. The UK remains heavily dependent on a workforce geared toward rapid, often oversized boiler replacement. Without a credible, funded transition pathway for these practitioners, the ambition to scale heat pump deployment will be difficult to realise. Alongside this, broader public understanding of retrofit needs to improve. Heat pumps operate differently from gas boilers, and their performance is intrinsically linked to insulation, emitter sizing and controls. A national education effort, whether through formal education, public information campaigns or focused engagement, would help build acceptance of both the technology and the wider objectives of retrofit which improves thermal comfort and reducing energy use at the household level, while cutting carbon emissions at the national level. Language and messaging will be critical to get this correct.

Our Final Thoughts

Overall, the plan’s reliance on incentives rather than mandates may be politically easier, but it leaves open the question of whether it will be sufficient to deliver long-term decarbonisation without clearer phase-out signals for fossil fuel heating. The absence of such signals here does not mean they do not exist elsewhere (and these objectives have been widely publicised and scrutinised) but timing and coherence between policies will matter. At a secondary level, it would be very useful to see a national retrofit strategy with process maps and working examples so there is less guesswork (and accordingly risk) in getting this right.

In all, the increased funding and certainty for the sector is absolutely welcome but the transition cannot be driven by unmeasured, technology-led interventions. Decisions must remain data-led, quality assured and holistic, grounded in the realities of individual dwellings and the needs of their occupants, if the programme is to deliver durable, equitable and cost-effective outcomes.

On the whole, the above concerns are secondary issues in delivery and strategy. The fact the plan is in place at all is a monumental achievement in mainstream recognition and activity on an issue that has been largely ignored in years gone by. The plan unlocks a truly exciting period in retrofit and decarbonisation.