Consultation: Consumer Scotland Draft Work Programme 2025/26

Thank you for the opportunity to comment on the Consumer Scotland Draft Work Programme 2025/26 consultation. In this response we have provided:

• Section 1: Introduction to the Trust Alliance Group
• Section 2: Our Response to Consumer Scotland’s Draft Work Programme 2025/26

Section 1: Introduction to the Trust Alliance Group

Trust Alliance Group (TAG) was established in 2002 and runs a range of discrete national Alternative Dispute Resolution (ADR) schemes across different sectors, including the Ofgem-approved Energy Ombudsman and the Ofcom-approved Communications Ombudsman. In 2022, The Internet Commission was acquired by TAG to continue its work promoting ethical business practice, counter online harms and increase platform accountability. TAG’s purpose is to build, maintain and restore trust and confidence between consumers and businesses.

Section 2: Our Response to Consumer Scotland’s Work Programme 2025/26.

We support Consumer Scotland’s Draft Work Programme and the focus on four overarching outcomes for consumers: Fair and Affordable Markets; Investing for the Future; Trustworthy, High Quality Products and Services; and Consumers at the Heart of Scotland’s Economy and Society.

We believe Consumer Scotland’s proposed Draft Work Programme and associated work streams strike the balance between variety and targeted analysis and successfully places focus on existing issues, whilst also positioning Consumer Scotland ahead of emerging disruption in essential markets. These are not insignificant challenges and we commend Consumer Scotland for achieving this in the development of the Draft Work Programme.

Trust Alliance Group – and the businesses within our group – look forward to working with Consumer Scotland in delivering this Work Programme. In particular, we would be happy to support on:

Heat Networks

We support Consumer Scotland’s role as the statutory consumer advocacy body for Heat Networks in Scotland. As this function outpaces regulation, we look forward to working with Consumer Scotland, DESNZ, Ofgem and Citizens Advice to ensure Heat Network consumers benefit from effective advice, advocacy and redress services.

We welcome the proposal to establish a Heat Networks Intelligence Group and will be happy to play our part in contributing to this – ensuring market data, insights and consumer experiences are captured and used to deliver better consumer outcomes and help achieve the target of 8% of Scotland’s energy supply provided from Heat Networks by 2030.

Future Energy and Energy Efficiency Markets

We support Consumer Scotland’s decision to focus on a ‘future energy retail market designed for consumers’ and ‘energy efficiency markets that deliver for consumer’ – two issues which are inextricably linked.

Improving Scotland’s housing stock, to make it warmer and easier to heat, would deliver the immediate dual benefit of reducing household energy costs and reducing carbon emissions. However, it is increasingly critical that consumers have confidence in the energy efficiency of their home before making important decisions about changing how they power their heating system.

We therefore support Consumer Scotland’s desire to see action taken to “streamline and improve the consumer journey, raising the standards of advice, protection, and redress, thereby elevating overall consumer confidence”.

We welcomed and benefited from the publication of Consumer Scotland’s report on ‘consumer perceptions of and engagement with the transition to net zero’ and look forward to the publication of your first investigation into ‘consumer protections in the green home heating market’. Both pieces of work bring much-needed attention to the consumer’s perspective of the energy transition and the importance of building trust and confidence in the energy systems of the future.

Energy Ombudsman is acutely aware of the changing energy landscape in Great Britain and continues to develop thinking with regards to ensuring consumer protections are robust and consumers are able to access redress when they need to. We share Consumer Scotland’s view that - along with advice and advocacy - these are essential pillars in building the consumer trust and confidence needed to increase uptake of new energy technologies and reach Net Zero.

Markets that Deliver for Small Businesses

We agree with Consumer Scotland’s analysis that “small businesses can face similar challenges to domestic consumers in how markets work for them” and that this extends to “difficulty in securing effective redress”.

In December, Energy Ombudsman extended its remit, allowing our service to accept cases from small businesses with 50 employees or less. Prior to this, Energy Ombudsman could only accept cases from micro-businesses with 10 employees or less. By securing this remit extension, access to Energy Ombudsman now extends to 95% of all UK businesses – whose only option until now was to take their dispute to the civil justice system.

We will be happy to share our experiences of handling enquiries from small business consumers and share any insight, both as to how this produces better outcomes for small businesses and how this could be applied to more essential markets.

Improving Pathways to Redress

In 2024, we were pleased to participate in a sub-group of the Consumer Network – along with colleagues from SPSO and SLCC – to explore improving access to redress. The opportunity to learn from other ADR providers and to receive feedback from the wider Network (including advice agencies) was valuable to us.

We look forward to participating in any projects related to ‘Improving Pathways to Redress’, and to explore the opportunities made available by technology to simplify the consumer journey.

We appreciate that many people do not have the confidence to approach our ADR services and we are working hard to identify and work with the communities of people who are under-represented in our data. While we want to ensure pathways to redress are simple, we also want to tackle misconceptions about accessing redress and ensure our service is fully accessible when consumers do seek our support.

We welcome Consumer Scotland’s outcomes focussed approach and the commitment to the Strategic Theory of Change – identifying issues, working with partners, gathering robust evidence, providing analysis and developing workable solutions which will have positive outcomes for consumers.

As part of the Consumer Network and the Energy Consumers Networks, we look forward to continuing to play out part in this strategic approach to your work and the positive policy proposals it generates.