In April 2025, the Department for Energy Security and Net Zero (DESNZ) issued a two-part consultation. Part one proposed changes to the Boiler Upgrade Scheme (BUS) that are designed to stimulate further demand and enhance consumer protections. Part two sought views on proposals to mandate MCS as the sole certification scheme for all DESNZ clean heat schemes. You can read the full consultation here.
The consultation closed on 11 June 2025. MCS has submitted its response to the consultation:
Incorporating new technologies into the BUS
MCS’s mission is to give people confidence in low carbon energy technology by defining, maintaining, and improving quality. We are therefore committed to working closely with DESNZ to ensure that rigorous standards are in place for all clean heat technologies supported through government schemes.
To support, we are already taking proactive steps to update and expand our standards:
- We have updated the heat pump product standard (MCS 007) to cover the requirements of air to air heat pump products. We are also in the process of updating all other relevant MCS standards and tools, including the system performance estimate, and the design and installation standards.
- We are developing a new installation standard for Thermal Energy Storage Systems (TESS) to include heat batteries.
However, MCS call for careful consideration being given to the success of the current BUS, part of which is down to its relative simplicity. While MCS supports incentives for new technologies, they must be presented to consumers in the right way to ensure continued growth of the market.
Third-party ownership
In our response to the consultation, we have shared our concerns with allowing third-party ownership agreements within the BUS. While we acknowledge the potential benefits of these models in providing greater access to low-carbon heating, there are inherent risks with third-party ownership that require careful consideration: including consumer understanding, contract fairness, long-term affordability, and route of redress. Third-party ownership models present an additional layer that requires consumer protection – and there needs to be particular emphasis on ensuring payment methods / contractual terms do not lead to consumer detriment.
Enhancing consumer protections
MCS welcomes the proposal to include the MCS Customer Commitment as an eligible code of practice for the BUS. The Customer Commitment sits at the heart of the redeveloped MCS, and has been developed with input from industry and oversight from an independent consumer protection panel.
The Customer Commitment outlines how installers must behave and interact with their customers, including how they should handle complaints. MCS will monitor each installer’s compliance to the Customer Commitment by contacting every consumer who has received an MCS certified installation. This will be enforced via the MCS Installer Agreement – which affords a direct relationship between MCS and the installer. It means that an installer’s ability to trade as MCS certified, and therefore participate in the BUS, can be withdrawn based directly on their delivery of the consumer experience.
We understand the reasoning behind DESNZ’s proposal to automatically discount the BUS grant funding from the upfront cost of a consumer’s installation. This is important for protecting consumers in the unlikely event that the installer ceases to trade before the installation is complete. However, this must be carefully balanced with the need to support installers in managing their cashflow. Prompt, reliable payments will be critical to maintaining installer participation and confidence in the scheme.
Certification requirements for clean heat schemes
There are clear and significant advantages to having a single, trusted certification scheme for clean heat measures. It will simplify the landscape by giving households and industry a single, trusted route to certification. It also allows DESNZ to maintain a consistent and rigorous approach to quality assurance in their clean heat schemes.
We are concerned that ‘equivalency’ in this context could lead to a race to the bottom, at the cost of quality and consumer protection. It also risks an installer losing their certification with one scheme, only to move to an alternative to maintain their access to government grants. We understand that competition can achieve good outcomes for consumers in driving innovation and bringing down costs in other industries – but consumer protection and standards are not an appropriate area for competition.
MCS is well-placed to take on the responsibility of being the sole certification scheme for clean heat installations under government clean heat schemes. As a charity-owned company, we are committed to improving quality and consumer protection for the greater good of the sector – we do not have to satisfy the investment needs of shareholders. The effective delivery of the Scheme is our single focus, we are not conflicted by other commercial interests.
MCS standards are also written by industry, for industry, developed with expert working groups drawn from industry to ensure they reflect best practice. This places MCS at the heart of the sector, with standards development benefiting from over 200 experts, including representatives who are installers, manufacturers, consumer protection experts and respected academics. This is underpinned by robust governance which ensures proposed changes to / the creation of new standards are subject to public consultation.
Finally, as we deploy the redeveloped MCS during 2025 / 2026, it’s clear that there isn’t, and won’t be, an equivalent scheme that offers:
- design and installation standards across the spectrum of technologies;
- the same level of consumer protections;
- the existing working relationship with Ofgem in delivering the BUS.
MCS looks forward to seeing the outcome of DESNZ’s consultation, and will continue to support the government in giving everyone confidence in home-grown energy.