Our response to the Heat and Energy Efficiency Technical Suitability assessment (HEETSA) scoping consultation

• Mostly agree.

We mostly agree that it would be valuable for the Scottish Government to develop a HEETSA (a government-led approval and accreditation mechanism to provide oversight and standardisation of the retrofit and assessment market).

We support, in principle, the proposal to develop HEETSA as a mechanism to safeguard consumers by helping them identify the most technically appropriate heat and energy efficiency measures for their buildings. However, the consultation does not provide clarity on who would be responsible – and ultimately accountable – for the advice provided through HEETSA, or for the consequences if that advice leads to poor retrofit outcomes.

Unless HEETSA is integrated into a trusted framework such as PAS 2035, HEETSA is unlikely to provide any additional safeguarding in practice. PAS 2035 defines clear roles and responsibilities, including oversight by a retrofit coordinator, which helps ensure that advice is consistent, accountable and trusted. If HEETSA sits outside of this framework, there is a risk that its advice may be seen as secondary or less authoritative – particularly if it conflicts with advice from installers or designers. In practice, consumers are likely to follow the advice of the installer delivering the work, especially in the absence of clear accountability. Where this happens, the HEETSA assessment may have little influence on decisions and may fail to fulfil its intended purpose – undermining its effectiveness as a safeguard.

We also note that there are practical limitations to pre-installation assessments. Issues such as damp, structural problems, or poor ventilation may only be discovered once work has started. While it doesn’t require assessors to carry out invasive investigations as standard, it does set out a process for identifying potential risks and making sure they’re followed up, with oversight from the retrofit coordinator. This helps ensure that even hidden issues are flagged and dealt with appropriately. If HEETSA assessments are not delivered within this framework, there’s a risk that important problems could be missed or not properly addressed – reducing their value as a safeguard and potentially leading to poor retrofit outcomes.

We also note that improving training for installers could play a vital role in ensuring that building owners only install improvement measures that are technically appropriate for their buildings. Even where assessments are technically sound, poor installation can still lead to inappropriate measures being installed. With the right skills and understanding, installers are less likely to install measures that aren’t suitable for the building.

As a member of the Existing Homes Alliance, we endorse the concerns raised in the Alliance’s response regarding the potential impact of HEETSA on the retrofit industry. Key challenges include deliverability, the ambitious timeline, coordination with existing assessment providers, and the need to train sufficient assessors. We also recognise the risk that added costs and complexity could deter homeowners and slow market progress. It is essential that any new mechanism builds on existing momentum, remains practical and affordable, and strengthens rather than disrupts the wider retrofit ecosystem.

• Retrofit assessment (i.e. identifying whether measures are present or can be installed)
• Retrofit design (identifying the types of measures (e.g. loft insulation) that can be installed)
• Installation (identifying the relevant installation standards)
• Occupancy (including factors related to the building’s current occupancy in assessment of suitable measures)

We support HEETSA covering retrofit assessment, retrofit design and occupancy as these are central to identifying appropriate measures for individual homes. We note that the consultation broadens the meaning of “retrofit assessment” to include the identification and evaluation of improvement options – effectively encompassing what PAS 2035 defines as the design stage. On that basis, we support the inclusion of both assessment and design within HEETSA.

We also support HEETSA including reference to relevant installation standards, as this would help to ensure that recommended measures are not only technically suitable but are also installed to a recognised quality benchmark.

Beyond the inclusion of retrofit assessment, retrofit design, occupancy and installation standards the Scottish Government may wish to consider whether there is a case to be made for HEETSA to take an even more comprehensive approach, with the aim of giving householders complete confidence that the measures being recommended are appropriate for their homes. This could include touching on specification and design in more detail – for example the type of insulation, method of installation, approximate system size, as well as information on potential running costs. Including this level of detail could help ensure that households feel confident that what installers are offering will genuinely suit their property and deliver the intended outcomes.

Ultimately the intended purpose(s) of HEETSA will be key in determining its scope. While its primary objective as outlined in the consultation is around safeguarding retrofit delivery, it may also be used for other purposes – such as providing a route to regulatory exemption. These different potential uses may require different levels of assessment. A tiered approach could help accommodate this, allowing the scope and depth of assessment to vary depending on the purpose it is intended to serve.

• Direct Government accreditation of assessors
• Government accreditation of assessor organisations who in turn accredit assessors

We think there is merit in exploring either direct Government accreditation of assessors or accreditation of assessor organisations who would then accredit individual assessors.

Providing HEETSA as guidance only, without any form of accreditation, seems less likely to be effective.

Our response to this consultation focuses on the Advice and Communications functions, both of which we believe require a high degree of intervention to deliver the level of consumer engagement needed for the necessary levels of flexibility to achieve Clean Power by 2030.

One notable gap relates to the assessment of complex to decarbonise homes, which may have physical, locational or behavioural characteristics that make standard methodologies less effective.

In this context, the Scottish Government may be interested to note that DESNZ has recently commissioned Energy Saving Trust to carry out research exploring the costs and archetypes of these homes. This work aims to understand the economic trade offs involved and to inform the development of appropriate methodologies that can better reflect the real world challenges of retrofitting such properties. Insights from this research could help shape HEETSA by identifying where existing tools fall short and where new or adapted approaches are needed to ensure assessments are both accurate and actionable.

Our initial thinking is that a government-led approach may be the most effective way to fill the identified gaps in methodologies required for HEETSA. This could involve the Scottish Government procuring and developing methodologies – similar to how SAP and more recently, HEM have been developed.

Relying solely on the market could risk delays, as there may be limited incentive to develop something that meets the specific needs identified. A government-led consortium could offer a way forward – drawing on existing approaches to develop something fit for purpose without starting from scratch.

Delivering high quality HEETSA assessments will require a combination of skills that are not commonly found in a single existing qualification. In particular, assessors will need a solid understanding of building physics, heating systems and retrofit principles. There are also known gaps in current training provision which will need to be addressed.

A sensible starting point would be to look at the existing qualifications linked to PAS 2035 retrofit roles, particularly retrofit assessors and retrofit coordinators. These roles already cover some of the relevant skills and could provide a foundation for defining HEETSA requirements.

It will however be important that any qualification pathway reflects the complexity of the role and supports assessors to develop the necessary breadth of knowledge.

• It is feasible for an individual assessor to have sufficient skills and knowledge to complete a HEETSA

We think it would be preferable for a HEETSA to be completed by a single, well-trained assessor with a sufficiently broad skill set and knowledge base. If this were not possible, the process would become significantly more complex and burdensome. Requiring input from multiple specialists would likely mean coordinating several visits to the same property – which would add time and cost. Such an approach would be inefficient and impractical at scale, particularly in rural or remote areas, or for households with limited availability.

There may however be exceptional circumstances where additional specialist input is appropriate. For example, this could include historically significant buildings, properties installing emerging technologies or complex retrofit plans that fall outside the HEETSA assessors’ expertise. In such cases, it is important that the system allows for flexibility and enable occasional additional specialist support where genuinely required.

To maintain the integrity and robustness of the assessment, the HEETSA assessor should be empowered to flag the need for specialist advice and specify the qualifications or competencies required. This would help ensure that any additional input is targeted, defensible and adds value.

• Strongly agree.

We strongly agree that non-personal data gathered through a HEETSA should be stored to form part of a ‘building logbook’ or ‘green-building passport’.  Doing so would help build a long-term record of retrofit suitability, risks and decisions for a property which would be valuable for future owners, advisors, installers, government analysts, and others involved in retrofit delivery and planning.

Separately there are considerations around how context-specific decisions are recorded in any future logbook or passport. If an assessment concludes that a retrofit plan is unsuitable not due to technical reasons but because of household specific factors such as affordability or disruption, it raises questions about how that information should be represented. These decisions are context-dependent and may not reflect the technical suitability of the property itself.

There is a risk that storing such information without clear framing could misrepresent the property’s potential or discourage future retrofit efforts. Therefore, if logbooks or passports are used, they must clearly distinguish between:

• Technical limitations of the property (e.g. damp risk, structural issues)
• Householder-specific constraints (e.g. cost, disruption, timing)
• Recommendations for future reassessment or conditions under which suitability might change

This would ensure the logbook or passport remains a useful and fair tool for long-term planning, rather than a static record of one moment in time.

We also think that non-personal data gathered through a HEETSA should be stored and recorded centrally to allow it to be integrated into tools like Home Analytics and PEAT (which are developed and managed Energy Saving Trust and funded by the Scottish Government), supporting strategic planning and programme design by local authorities and other stakeholders.

Finally, storing assessments centrally would also support monitoring and evaluation over time, helping to assess the impact of interventions and inform future policy.

• Strongly agree.

We strongly agree that the HEETSA assessor should be required to be independent of the outcome of the assessment, including having no financial interest in whether the measure is deemed technically suitable.

If assessors stand to gain financially from recommending certain measures – through either them or their company installing them or receiving a commission – there is a clear risk of biased or inappropriate recommendations being made. This could undermine public trust in HEETSAs and lead to poor outcomes for households.

Assessors not being sufficiently independent has previously led to significant consumer harm in Scotland. For example, under the UK Government’s Green Deal scheme (2013-2015), providers could employ and financially reward Green Deal assessors based on the measures they recommended and that were subsequently installed. This created a clear conflict of interest and contributed to poor consumer outcomes, such as being mis-sold measures that were unsuitable for homes or failed to deliver the promised savings. Ensuring energy assessor independence in HEETSA would help avoid repeating the mistakes of the Green Deal and support the delivery of high-quality, impartial advice that genuinely benefits households.

• The results of a HEETSA should be made available to inform the production of a revised EPC and should be considered acceptable ‘documentary evidence’ to override default values.

The second statement “The results of a HEETSA should be made available to inform the production of a revised EPC and should be considered acceptable ‘documentary evidence’ to override default values” is the statement that comes closest to our view on the relationship between the EPC and HEETSA.

EPCs already have a process for being updated when new or corrected information becomes available, provided sufficient evidence is submitted. If a HEETSA assessment identifies an inaccuracy in an EPC – for example, an incorrect assumption about insulation – this evidence could be passed to an accredited EPC assessor to generate a revised certificate. In this sense, HEETSA can play a valuable role in improving the accuracy of EPCs.

However, we note that the consultation proposes that HEETSA is expected to go beyond the scope of EPCS including by incorporating household-specific factors such as the behaviour of the occupants and their circumstances and needs. These elements are not part of the EPC methodology, which focuses on standardised metrics. As such, HEETSA recommendations may diverge from those in the EPC, but this does not mean that one invalidates the other – they serve different purposes in the retrofit journey – with EPCs providing a starting point and HEETSA (if introduced) adding depth and nuance to support more tailored decision making. HEETSA should be seen as a complementary tool that enhances retrofit planning, rather than a replacement or correction mechanism for EPCs.

(a) HEETSA should result in a standardised certificate or report?

• Strongly agree.

We strongly agree that HEETSA should result in a standardised certificate or report.

A standardised format would allow for easy comparison between properties – for example, someone looking to move house could compare the retrofit potential of different homes. This comparability would also be valuable for private landlords managing multiple properties, or for local authorities assessing their housing stock. Standardisation would also help consumers recognise and understand their assessment results more easily. A consistent format would mean that once someone has seen a HEETSA report – whether for their own home or another – they’re more likely to understand the layout and key information, which would build confidence in the assessments.

It would also make it easier for advice providers, such as Home Energy Scotland, to offer tailored support following a HEETSA assessment. A standardised report format would make it quicker and simpler for advisors to interpret results and provide accurate advice. It would also allow for the development of standardised guidance on interpreting HEETSA reports, helping householders to better understand their report and reducing the risk of confusion or misinterpretation.

Having a standardised format would also make it easier for the data to be integrated into tools like Home Analytics and PEAT (which are developed and managed Energy Saving Trust and funded by the Scottish Government), supporting strategic planning and programme design by local authorities and other stakeholders.

Finally, assuming HEETSA reports are stored centrally, standardised outputs would support monitoring and evaluation over time, helping to assess the impact of interventions and inform future policy.

(b) What information should be included when presenting the results?

The presentation of HEETSA results should be designed with both householders and installers in mind, recognising that their needs and priorities may differ. To ensure the format is genuinely useful and accessible, we recommend that the Scottish Government engage directly with householders to understand what information they would find most valuable and how they would prefer it to be presented.

To support different user needs, we suggest developing an interactive online version of the HEETSA report. This would allow householders to explore the assessment in greater detail, revisit it as their plans evolve, and access tailored advice over time.

To support informed decision making, HEETSA reports should clearly signpost to Home Energy Scotland, as this is the main route through which households can access Scottish Government funding and support schemes for energy efficiency and clean heating measures. This should be included in both online and offline formats to ensure accessibility for all households. We also welcome the consultation’s proposal to include contextual information – such as heat network zones, Local Heat and Energy Efficiency Strategies (LHEES) and other area-based initiatives – as these factors can significantly influence the suitability, cost effectiveness and timing of certain measures. Providing this broader context will help householders make decisions that are aligned with local and national long-term energy planning.

For installers and other retrofit professionals, the report should be structured and shareable, with clear and consistent information on:

• Which measures are recommended or not recommended
• The rationale behind each recommendation (e.g. technical limitations, household-specific constraints)
• Required qualifications or standards for the installation
• Contact points for queries or challenges to the assessment
• Types of evidence needed to revise recommendations
• Remediation options and guarantees available to the householder, and how to access them.

We see HEETSA as a valuable tool to support informed decision making and effective communication between stakeholders. A well-designed reporting format will help ensure that assessments translate into practical, trusted actions that deliver meaningful energy and carbon savings.

We agree with the circumstances in which a HEESTA should be required that are outlined in the consultation, namely when a building owner chooses to act on a voluntary basis and wants more detailed technical advice, when it is a condition of eligibility for a government funding programme to undertake a more detailed assessment, when a building owner is required to comply with a regulatory standard and is seeking more detailed technical evidence which could be used to support a requires for exemption from the standard, flexibility in meeting its requirements or an appeal.

We also think that the consultation’s suggestion that HEETSA results could be used to “address the potential risks of blanket funding criteria or blanket exemptions by making determinations on the building level on what was appropriate” is particularly interesting and deserves further exploration. This approach could help ensure that funding is directed towards measures that are genuinely suitable for individual buildings, rather than being constrained by a fixed list of eligible technologies. Basing funding decisions on HEETSA recommendations could support a more flexible, whole house approach to retrofit, and help optimise the impact of public investment. And as the consultation notes it could also provide greater confidence to funders, regulators and building owners at the right measures are being installed and unsuitable ones avoided.

We also note the consultation’s suggestion that government funding programmes or regulations could specify circumstances in which a HEETSA is required, such as for traditional or protected buildings, or tenements as a condition or funding. This seems like a sensible approach, particularly where there is a need for greater assurance around the suitability of measures.

• Don’t know.