Our Work since April 2025

In delivery of our April 2025 to March 2026 workplan, we have met four times in person and twelve times online to deliver on our workplan priorities. We have also worked to advise and influence the Scottish and UK Governments, and Ofgem through direct advice to policy officials, responding to consultations and participating in the Scottish Government’s Social Tariff Working Group and sector conferences.

Priorities

In our April 2025 to March 2026 workplan we set out three core priorities for the year. These were to:

Respond to the Scottish Ministers’ Periodic Report – as required by provision 14 of the Fuel Poverty (Targets, Definition and Strategy) (Scotland) Act 2019 by the end of the second quarter (September 2025).
Build on last year’s work on the systemic impact of rural and remote fuel poverty in order to explore solutions to rural and remote fuel poverty.
Look forward to exploring the benefits of a public health approach to fuel poverty in 2026-2027 by setting the groundwork for this in the final quarter (January – March 2026).

This year we have also continued to work flexibly to respond to consultations on key issues for those in fuel poverty. In addition, we carried out an exploration of the evidence on income-based support versus money off energy bills for fuel poverty support, a topic often raised by stakeholders and which is important in effective policy responses and progressing Scotland’s fuel poverty targets.

1. Respond to the Scottish Ministers’ Periodic Report

Our response to the periodic report was a significant piece of work, drawing together the evidence, analysis and advice developed over our first four years. It not only includes many of our previous recommendations to Ministers but also sets out a potential framework for revising the Fuel Poverty Strategy.

Our approach

On the 1 April 2025, Scottish Ministers published the first of their triennial periodic reports –Tackling fuel poverty in Scotland: periodic report 2021-2024, as stipulated by the Fuel Poverty (Targets, Definition and Strategy) (Scotland) Act 2019. The Act requires the Panel to respond to this periodic report within 6 months. In making our

response, we explored the following questions mandated in provision 14 of the Fuel Poverty (Targets, Definition and Strategy) (Scotland) Act:

I. What progress has been made towards meeting the fuel poverty targets?

II. What is the likelihood of meeting the fuel poverty targets?

III. To what extent are the four drivers of fuel poverty are being addressed?

IV. Are there changes which should be made to the fuel poverty strategy?

We also engaged with a small number of third sector organisations and Scottish Government policy leads to complement our reflections on our collective stakeholder engagement since appointment. The findings from the third sector engagement, the questions we posed to Scottish Government, and our feedback to their periodic report consultation, informed our response to the Scottish Government’s Tackling fuel poverty in Scotland: periodic report 2021-2024. Our work on the periodic report influenced our other two work priorities last year – rural and remote fuel poverty, and the impact of fuel poverty on health.

What we did

We used the majority of our Panel meetings, two thirds, to reflect on our advice to Scottish Ministers since our appointment, especially our feedback on the periodic report consultation, alongside the views of others and the status updates provided by Scottish Government, to discuss and formulate our response to the periodic report. In answer to the four questions posed by the Act.

What we concluded

Our headline conclusion is that Scottish Government needs to give greater strategic prioritisation to fuel poverty policy and programmes than has been the case since the Fuel Poverty (Targets, Definition and Strategy) (Scotland) Act 2019 came into force. We considered and offered our opinion, as directed by the Act and also presented recommendations for an improved approach to form a potential framework for revising the Fuel Poverty Strategy.

I. Progress towards meeting Scotland’s statutory fuel poverty targets.

There is little evidence that current policies and programmes are delivering progress towards the targets, and the Scottish Government’s periodic report does not assess how far actions taken between 2021 and 2024 have contributed to meeting them. There is no monitoring and evaluation framework to enable assessment of whether actions are reducing fuel poverty and no evidence showing the impact of spending and programmes on fuel poverty rates. Reporting does not clearly link actions, outcomes, and progress towards statutory targets and there is limited data on who has benefited from interventions and whether measures have improved people’s lived experience of fuel poverty.

II. What is the likelihood of meeting the fuel poverty targets?

We recognise the important investment and policy activity, particularly in energy efficiency programmes. However, we concluded that rising fuel poverty levels, weak monitoring, lack of outcome measurement, and insufficient assessment of policy impacts mean there is little evidence that Scotland is currently on track to achieve its 2030, 2035 or 2040 fuel poverty targets. We believe progress needs to accelerate significantly, especially in improving home energy efficiency and addressing the impact of persistently high energy prices

III. To what extent are the four drivers of fuel poverty are being addressed?

Some progress has been made in addressing fuel poverty drivers, particularly through energy efficiency programmes, with a 3% improvement in homes rated Band C or above in 2023, up around 3 percentage points from 2022. However, we believe this rate of improvement is not fast enough to meet statutory fuel poverty targets and there is insufficient evidence showing how energy efficiency programmes have reduced fuel poverty. Considerable financial support has been provided through winter heating payments, crisis funds and other support schemes to mitigate low incomes. However, we found little evidence demonstrating how these measures have reduced fuel poverty in the long term or contributed to achieving the fuel poverty targets. High energy prices are the primary cause for the increase in fuel poverty since the Strategy was published and the Scottish Government has worked to set out principles for a social tariff. How Energy Is Used in the Home is the least developed and least understood of the fuel poverty drivers.

IV. Are there changes which should be made to the fuel poverty strategy?

Looking forward to the revised Fuel Poverty Strategy due to be published in December, we made recommendations for delivering the following priorities:

Accelerating the rate of improvements to the energy efficiency of the housing stock is a prerequisite for meeting the statutory targets. It will require increased investment, strong leadership and taking stock of current delivery frameworks.
An increased awareness of challenges around how energy is used in the home and review advice models, their funding arrangements, and what works best.

A fuel poverty delivery plan should include how to increase low household net income as related to the attainment of the fuel poverty targets, should cover a consideration of taxation levers, a cash first versus fuel bills first approach,

and the balance of support for major policy actions, including the flexible energy discount mechanism and development of minimum income guarantee.
With the transition to decarbonised domestic heating, affordable and stable long-term electricity pricing is essential. A clear vision is needed for how the GB energy market could operate and the Scottish Government should advocate for the reforms which are not only in the best interests of consumers in Scotland but will also benefit those in, and at risk of, fuel poverty.
Island and remote rural communities should have a specific, more focused and co-ordinated, approach for tackling fuel poverty with clear leadership and enhanced resources.

2. Explore solutions to rural and remote fuel poverty – building on last year’s work

Our plan

Insights from our scrutiny of the Scottish Government’s periodic report, and our previous work on rural and remote fuel poverty, shaped our work to identify and explore solutions to fuel poverty in rural and remote communities. We planned to:

❖ Build on our previous work, exploring what different solutions are being deployed across rural and remote Scotland to mitigate fuel poverty, what issues these unearth and how effectively they are addressing fuel poverty in their local communities.

❖ We will, explore with a range of rural and remote stakeholders, solutions to rural and remote fuel poverty. Following our postponed visit to na h-Eileanan Siar (the Western Isles) last year, we will consider how and where a rural visit could best support this stakeholder engagement.

What we did

We held 6 meetings with the 3 island local authorities and the 3 local authorities with islands in their jurisdiction, in the final quarter of this year’s workplan – January–March 2026. In these individual meetings we explored the drivers of fuel poverty in island communities and how they can be mitigated ensuring that any local drivers were understood. We produced a findings’ report mapping drivers and mitigations to the 4 drivers of fuel poverty, plus an additional driver – the remote and rural factors which exacerbate fuel poverty in island communities. We brought all these local authorities together in an island fuel poverty roundtable on the 17th of March to explore further the priorities for tackling island fuel poverty which emerged from our individual discussions. Our reflections on what we heard at the roundtable form the basis for advice which we will be giving over the summer to Scottish Ministers as they work to revise the Fuel Poverty Strategy.

What we concluded

Island communities in Scotland suffer the worst fuel poverty in Scotland and beyond. Fuel poverty in island communities is systemic and linked to the wider energy system. Fuel poverty in these areas is not incidental but structural. Our findings and recommendations have yet to be published but our recommendations to Scottish Ministers focus on 5 areas where change would shift the endemic fuel poverty suffered by island communities:

I. Improved funding support – a holistic multi-year investment approach to improve the energy efficiency of housing stock.

II. Support for local advice services – multi-year core funding directed through local authorities.

III. A stronger role and greater resources for local authorities to tackle fuel poverty – resourcing for local heat and energy efficiency strategy delivery plans.

IV. Champion energy market reform by ensuring UK energy policy works for Scotland’s island communities, there is no deficit to communities as a result of the energy transition and modernisation (smart meter roll out, radio teleswitch switch off) and prioritise islands for energy innovation funding.

V. Facilitate community wealth building through renewable energy generation by leveraging opportunities to reduce energy costs and fuel poverty.

3. Look forward to exploring the benefits of a public health approach to fuel poverty in 2026-2027 by setting the groundwork for this in the final quarter (January – March 2026)

Our plan

In exploring the benefits of a public health approach to fuel poverty across to workplan years (April 2025-March 2026 and April 2026 to March 2027) we set out to:

Engage with Public Health Scotland to understand their data collection and evidence base.
Put out a call for evidence on where fuel poverty interventions have led to positive health outcomes.
Engage further with Energy Catapult Systems WHP, attending their Community of Practice event in September, and learn more about the new possibilities that healthcare and housing data linkage are opening up at the Homes and Healthy Kids Study interdisciplinary event on May 1st.
Connect with Scottish Government policy officials to explore their work in this area.

What we did

We hosted a PhD intern, Vanessa Kleinheinz, for 3 months to look at the interactions between fuel poverty and public health policy within the Scottish Government.

The Secretariat attended the Energy Catapult Systems Warm Home Prescription knowledge exchange event in October 2025. This event focussed on examples of how enabling health and energy sectors are working together on retrofit, how local authorities are delivering positive health outcomes through retrofit, and innovative retrofit technologies delivering positive health outcomes. This proved a useful source of contacts for our health case studies.

Our Social Researcher conducted research to look at what can be learned from UK case studies beyond the warm homes prescription model which have targeted both health and fuel poverty directly.

Both the fuel poverty and health policy mapping, and the case study research involved discussion with Public Health Scotland and relevant Scottish Government officials.

What we concluded

There is significant scope to strengthen fuel poverty and health policy connections in the Scottish Government to improve health outcomes as a result of fuel poverty mitigation. More effective use of data would improve the evidence base for the impact of cold and damp homes on health. Training and awareness to educate the public and practitioners working with those in or at risk of fuel would also be beneficial.

Health-focused fuel poverty support should be embedded within existing NHS services, local partnerships and community networks, ensuring assistance is offered through routine healthcare contacts such as GP appointments, vaccination clinics and hospital admissions rather than through separate referral routes. To maximise impact, sustainable long-term funding is needed to support not only pilot projects but also their expansion and implementation at scale, alongside robust evaluation to measure outcomes, inform continuous improvement and strengthen the evidence base for future policy development^[1].

Our public health fuel poverty policy mapping and health and fuel poverty case studies’ reports are yet to be published. The Panel will be using findings from these to advise Scottish Ministers on how the revised Fuel Poverty Strategy could bring a much stronger emphasis to health and the role which warm homes play in preventing poor health outcomes. We will be drawing together a set of recommendations for Scottish Ministers to inform the revised Fuel Poverty Strategy on health.

Scrutiny

We have continued to fulfil our scrutiny role of assessing the Scottish Government’s progress in tackling fuel poverty as set out above under priority 1 – Respond to the Scottish Ministers’ Periodic Report.

Advocacy and Influence

We have this year continued to advocate for a flexible energy discount mechanism (also known as a “social tariff”) – taking every opportunity to promote our recommendations. We believe that a well-defined and flexible discount mechanism offers a real opportunity to at the least mitigate and at the best eradicate fuel poverty.

We continued our participation in Scottish Ministers’ Social Tariff Working Group, advocating for a discount mechanism automatically delivering a unit rate discount for vulnerable consumers at the point of use, and which is flexible enough to take account of changing circumstances, contributing these ideas to the final report of this group.
We maintained our focus on advocating for an energy discount mechanism by responding to relevant consultations. In response to the Department for Energy Security and Net Zero’s (DESNZ) consultation on expanding the Warm Home Discount (WHD), we supported WHD’s continued expansion and the principle of automatic payments. We recognised WHD’s potential, with sufficient funding and redesign, to help reduce fuel poverty, while noting that the £150 rebate is insufficient for many households in fuel poverty in Scotland. We highlighted the opportunity for regional variations in rebate levels to better reflect differing needs and deliver greater impact where fuel poverty is most acute. We reiterated that we would like to see the WHD, as a precursor of a fully-fledged flexible energy discount mechanism, funded through general taxation in responding to DESNZ’s consultation on WHD cost recovery where we rejected the idea of moving the WHD levy from standing charges to the unit rate. Earlier in the year, we set out principles for energy system cost allocation and recovery to Ofgem in response to their consultation on this. We noted the key role energy prices play in driving fuel poverty in Scotland, argued that energy costs should be structured to minimise fuel poverty (e.g. levies energy efficiency schemes and discounts should be funded through general taxation) and that energy cost reform must be accompanied by stronger targeted support for vulnerable households, including a flexible energy discount mechanism.

Advice

We have advised Scottish Ministers, Scottish Government officials and the Poverty and Inequality Commission on the following:

We wrote to the Cabinet Secretary for Housing on the delay to the Heat in Buildings Bill, advocating that the delay should not slow progress on tackling fuel poverty and noting that it was unclear how the new bill, Buildings (Heating and Energy Performance) and Heat Networks (Scotland), would contribute to reducing fuel poverty and meeting statutory fuel poverty targets as well as helping to accelerate energy efficiency improvements. We expressed concern about the lack of reference to fuel poverty or the fuel poverty targets in the draft bill. We also noted that, as yet, it was unclear how the heat decarbonisation strategy envisaged in the Bill would align with the fuel poverty strategy, due to be revised by December 2026, and that effective implementation would require close alignment between the governance and delivery arrangements for both strategies.
We offered the following reflections on the Scottish Government’s developing Theory of Change and associated outcomes framework for the Strategy at our meeting in March 2026. The fuel poverty targets and drivers need to be embedded within the Strategy, as its central purpose is to make progress towards achieving the statutory targets and addressing the underlying drivers of fuel poverty. While the Scottish House Condition Survey (SHCS) provides a valuable long-running time series, it is not designed to directly attribute the impacts of programmes such as Warmer Homes Scotland or Area Based Schemes. We pointed to international approaches, highlighting New Zealand’s focus on energy hardship and the methods used there to measure and understand household experiences. On the fuel poverty driver, how energy is used in the home, qualitative measures are needed to capture lived experience. This information cannot currently be attributed within official fuel poverty statistics – the SHCS question database is constrained by overall survey design and cost considerations. We noted that other datasets may help strengthen the evidence base and complement existing survey findings. It is important the assumptions underpinning the Theory of Change for the revised Strategy should be clearly articulated to ensure transparency and support a robust assessment of how proposed interventions are expected to contribute to reducing fuel poverty.
We engaged with Scottish Government officials on eligibility criteria for the next round of Warmer Homes Scotland (WHS). We advised retaining broad eligibility criteria rather than tightening thresholds to match available funding. If thresholds are tightened, funding should first be fully allocated to demonstrate demand and strengthen the case for increased future budgets. If demand falls, the Scottish Government should promote WHS more actively to address declining uptake despite continued need. We noted that prioritising SAP over EPC appears inconsistent with the Fuel Poverty Strategy and may be less clear to consumers. WHS funding decisions should also be made earlier, as delivery partners and fund administrators cannot manage demand effectively until funding levels are confirmed.
We contributed to the Poverty and Inequality Commission’s advice for the Scottish Government’s new delivery plan – Bringing Hope, Building Futures: Tackling child poverty delivery plan 2026-2031 – recommending the introduction of a flexible energy discount mechanism.

Collaboration and Engagement

We have collaborated across Scottish and UK governments, and with parliamentary groups, public bodies, 3^rd sector organisations, and energy companies. Specifically:

Our findings and recommendations from our scrutiny of the Scottish Government’s periodic report were presented by Panel member, Alister Steele, at the Energy Action Conference in November 2025, supported by our Secretariat who also attended the Scottish Federation of Housing Associations annual conference. Our Chair, Matt Cole, attended the inaugural Holyrood Energy Summit. He also participated in the Scottish Government’s Rural Energy Consumers and Vulnerable Energy Consumers’ Groups, the Scottish Leaders Forum on Family Support, and Alister Steele joined the Cabinet Secretary for Housing’s Roundtable on the Heat in Buildings Bill.
We have continued our support of fuel poverty research. Our Social Researcher co-chaired a research roundtable on 24^th March with Consumer Scotland involving academics and health practitioners, including Panel member Kirsten Jenkins and Scottish Government researchers, and 3^rd sector energy and poverty policy leads. Other Panel members have participated in research interviews in support of post-graduate fuel poverty research, and commented on a significant research piece on the challenge of fuel poverty in rural and island communities. As mentioned above, we hosted a PhD student as part of Scottish Graduate School of Social Sciences internship scheme. Towards the end of this workplan year, our Social Researcher began, with the help of other public bodies, third sector, advice and energy organisations, membership organisations and a think tank, to explore the most effective ways to provide fuel poverty support, focussing on the advantages and disadvantages of measures that reduce household energy costs compared with those that increase household income.
We have engaged with other public bodies where there is a connected interest in fuel poverty and its effects – the Poverty and Inequality Commission, Consumer Scotland and Public Health Scotland to deliver on our work priorities. Our Chair presented to the Cross-Party Working Group on older people, age and aging, exploring with them what SHCS data reveals about the higher prevalence of fuel (37%) and extreme fuel poverty (25%)[2] in older people and the vulnerabilities behind these figures. Our Secretariat attended the Scottish Human Rights Commission launch of its 2025 State of the Nation: Economic, Social and Cultural Rights in Scotland and the meeting of the joint Cross Party Working Groups, Islands, and Renewable Energy and Energy Efficiency.
We have engaged with the Department of Energy Security and Net Zero to hear more about the Fuel Poverty Strategy for England and its connection to the Warm Homes Plan and the potential implications for Scotland. Our Secretariat has met regularly with The Committee on Fuel Poverty Secretariat to support knowledge exchange and cooperation between the Panel and the Committee.

Governance

We published our Annual Report (April 2024 to March 2025).
We used a succession plan informed by our strategic goals and skills’ matrix in support of Scottish Ministers in their appointment of the two new Panel members in January 2026, our Chair was part of the recruitment panel. The Secretariat also ran an information session for potential applicants to give a flavour of how the Panel works and an overview of its work during its first 3 years.
We welcomed and inducted our two new Panel members.
Contributed to and reflected our thoughts on Public Service Reform requests.
We are required to report on the Consumer Duty and Biodiversity Duty –
As an advisory non-departmental public body, our direct impact on biodiversity is limited. However, we seek to minimise our environmental footprint by holding most meetings online, reducing travel[3], and using digital documents as the default rather than printing papers.
Under the Consumer Scotland Act 2020, we are a relevant public authority and must consider consumer impacts when making strategic decisions, publish information on how we meet the duty, and have regard to Consumer Scotland guidance. As an advisory body, we do not make strategic operational decisions and therefore do not undertake formal Consumer Duty impact assessments. Nevertheless, our entire role is focussed on how we can bring change to the lives of vulnerable consumers—those in or on the edge of fuel poverty – and how fuel poverty can be mitigated and, ultimately, resolved This Annual Report forms part of our commitment to transparency under the Consumer Duty.

Monitoring the Success of our Strategic Plan

In our Strategic Plan 2024-2027, we set out how we would produce annual workplans, rooted in the areas for action set out in our strategic plan and assess in our annual reports how effectively we are delivering on our strategic goals. Alongside our Strategic Plan, we produced and published a logic model – a visual representation of how we expect our strategic goals (inputs) to be achieved (outcomes) through our work (outputs), to accompany our Strategic Plan. We evaluate the effectiveness of our Strategic Plan and delivery by reviewing and assessing the effectiveness of our workplans. We also use some quantitative indicators on selected and readily accessible data on communication, media and engagement approaches. These are provided below to give a snapshot of Panel progress on these in the last full workplan year April 2025 to March 26:

Website and Media mentions

The Panel’s website, there were 19,650 active users, an increase of 64% on 2024/25[4]. There were 7,300 engaged sessions, an increase of 24%.
The Panel had 32 media mentions.
The Panel were invited to participate in 13 key groups, roundtables, and evidence sessions across the public sector, third sector organisations, and wider energy sector and regulator groups.