Introduction

The Fuel Poverty (Targets, Definition and Strategy) (Scotland) Act 2019 (the Act) sets out a statutory role for the Scottish Fuel Poverty Advisory Panel (the Panel) in responding to the Scottish Government’s triennial periodic reports. The Act stipulates that the Panel should consider the Scottish Government’s:

1. Progress toward meeting the fuel poverty targets.
2. The likelihood of meeting the fuel poverty targets.
3. The extent to which the four drivers of fuel poverty are being addressed.

The Act also includes that the Panel may:

1. Propose changes to the fuel poverty strategy.
2. Make such other recommendations to the Scottish Ministers as the Panel considers appropriate.

Table 1, below, sets out Scotland’s 2040 fuel poverty target – and the interim targets in 2030 and 2035.

Table 1: Fuel poverty targets as defined in the Fuel Poverty Act 2019

We, the Panel, cannot begin our assessment of the Scottish Government’s progress towards meeting fuel poverty targets without first reflecting on the extent of fuel poverty in Scotland today. According to the most recent Scottish House Condition Survey reporting on 2023 data, 34% of all households (approximately 861,000) are estimated to be in fuel poverty, with around 19.4% (approximately 491,000) estimated to be in extreme fuel poverty. The median fuel poverty gap stands at £1,250[1]. This represents a significant increase from 2019 fuel poverty rates, the most up-to-date data available at the time the Strategy was published, when an estimated 24.6% (around 613,000 households) of all households were in fuel poverty, and 12.4% (or 311,000 households) were living in extreme fuel poverty. In 2019, the median fuel poverty gap was £750[2].

Behind these high-level figures, the lived experiences and day-to-day reality of fuel poverty is stark. We have heard stories of a person in the Western Isles with hypothermia induced by self-disconnection of their heating because of lack of money to pay their latest electricity bill and families living in tenement flats in Central Scotland who only heat their property when their children are at home. We have heard about people resorting to extremes so that they can access heat and power. This includes a person topping up their electricity meter instead of buying food, or another ripping up the floorboards in their home so that they could burn them as a heat source. We have heard of an older woman, living alone, who has resorted to heating only one room in her home, causing the rest of her home to develop damp and mould. We have heard from disabled people who have additional energy costs to run medical equipment and get into debt trying to stay warm, and of families in rural and remote Scotland choosing between heating and eating, and in some cases being able to afford neither.

The Panel recognises that in 2019, when the Act and the subsequent fuel poverty strategy were developed, the world was a very different place. This was before the COVID-19 pandemic, the energy price crisis, and the ensuing inflationary impacts faced by millions of people across the country. While this context could not have been predicted, its impacts have undeniably, and sharply accelerated fuel poverty and its associated health, economic and social hardships. Rising energy costs have slowed, but bills remain challenging, with the average bill under the October to December 2025 price cap being 44% higher than in winter 2021/22[3]. Energy debt is now also a major challenge, with 4.15 billion pounds worth of domestic debt and arrears in GB as of Quarter 1 2025[4] [5].

The Panel’s view is that given the escalation in fuel poverty rates, tackling fuel poverty should be a greater priority now than it was when the 2019 Act was passed by the Scottish Parliament. Yet in comparison to other policy areas with statutory targets – child poverty and climate change – fuel poverty has, in the Panel’s opinion, not seen the required level of strategic prioritisation.

The voice of those in fuel poverty and extreme fuel poverty, as well as the voice of those who work in the frontline supporting them, has shaped and influenced the Panel’s thinking and the advice we have given to Scottish Ministers. The full list of this advice provided to Scottish Ministers since 2022 is set out in Appendix 2. Our response to the Periodic Report is underpinned by and consistent with our previous advice.

In evaluating progress towards the fuel poverty targets and the extent to which the four drivers of fuel poverty are being addressed, we also recognise that some key policy, regulatory, fiscal and market levers sit outside the Scottish Government’s devolved powers and that the wider energy landscape has shifted significantly. Given this changing landscape, there is a pressing need to refocus and ramp up devolved government action commensurate with the increased scale of the fuel poverty challenge, and to bring the statutory targets into view.

This document sets out the Panel’s response to the Scottish Government’s Tackling Fuel Poverty in Scotland: Periodic Report 2021 – 2024 (Periodic Report). In Part 1, we offer our view on the Scottish Government’s progress towards and likelihood of meeting the fuel poverty targets, and the extent to which the four fuel poverty drivers are being addressed. In Part 2, we consider progress on the specific commitments made in Tackling Fuel Poverty in Scotland: a Strategic Approach (the Strategy). In Part 3, we conclude with reflections on future challenges and recommendations for the revised strategy, which there has been a Ministerial commitment to do by December 2026.

In preparing this response to the Periodic Report, the Panel sought clarification from the Scottish Government on several points made in the Periodic Report. The Panel also engaged with six stakeholders directly who were invited to share their reflections of the Periodic Report and progress being made towards the statutory targets, as well as issuing a general invitation to comment[6]. The Scottish Government and stakeholder responses are published alongside this report on our website. No more than 15% of Scottish households.