David Cowburn, Chief Operating Officer at NAPIT, reflects on the publication of findings by the Competition and Markets Authority and a current consultation to redevelop the Microgeneration Certification Scheme, the potential for these to impact on NAPIT and consumers.

Having previously blogged about the importance of consumer confidence, I want to focus in on consumer protection and reflect on some key developments taking place within our industry.

Over the last few months, my colleagues and I have engaged regularly with the Competition and Markets Authority (CMA) as they gathered evidence on consumer protection in the green heating and insulation sector. They have now published their findings together with some consumer guidance, but equally importantly they have set out a vision of what “standards setting bodies” should deliver to provide acceptable consumer protection. This has implications across all areas of work, because good practice in the area of green heating and insulation can apply equally to all areas of service work for consumers. All these documents can be found here.

The key areas of focus within the recommendations for standards setting bodies are set out within five good practice principles which cover:

1. Effective promotion: Standards bodies to actively promote their activities to help ensure consumers understand their scope and purpose and the benefits of using a member business.
2. Robust vetting and monitoring: Standards bodies to conduct robust compliance checks on applicants and, on an ongoing basis, their members, to ensure they meet (and continue to meet) requirements.
3. Smooth dispute resolution: Standards bodies to actively oversee and assist consumer complaints and dispute resolution to make the process as straightforward as possible and to help parties reach a resolution in a timely manner.
4. Effective use of sanctions: Standards bodies to ensure that any potential non-compliance is investigated and dealt with as effectively, impartially and quickly as possible. Where appropriate, a sanction decision will be communicated to consumers.
5. Strong financial protections: Standards bodies to ensure that consumer deposits and guarantees are effectively protected and the terms of these protections are made clear to consumers.

The Competent Person Schemes (CPS) for the Building Regulations cover almost all of the work done by NAPIT members and the Conditions of Authorisation covering the schemes includes provisions for consumer protection and address, to varying degrees, the five principles above. I believe the CMA Good Practice Principles now provides a benchmark against which these requirements need to be measured. At the beginning of April, responsibility for CPS transferred from DLUHC to the new Building Safety Regulator (BSR). Consumer protection shouldn’t be thought of as purely financial, performance, information or safety, but all of these things, and the BSR changes combined with the CMA guidance set the stage for a serious review of how we can collectively up our game.

Returning to green heating, the Microgeneration Certification Scheme (MCS) has been considering the performance of their scheme and have launched a consultation on reforming the scheme design. A large element of this consultation is focused on how to improve consumer protection, following research that found current consumer protections fall short of what consumers expect to be in place. The findings note that despite the reliable track record of small-scale renewable technologies, such systems are still unfamiliar to many people and investing in them may still be considered a financial risk. As such, the industry must adapt to deal with consumers’ concerns, especially those considering renewables for the first time. These proposals also need to be benchmarked against the CMA Good Practice Principles.

The MCS consultation is wider than consumer issues and also looks at increasing accessibility to the scheme for businesses and individuals. The consultation runs until 9 am on 17^th July, and while NAPIT will respond in detail we would urge members to take their opportunity to contribute to this significant development.

I welcome both these developments. The CMA work is thoughtful and thorough and carries great credibility. The MCS proposal is timely and NAPIT support the principles underpinning its core ideas.

I have previously stressed the critical importance of consumer confidence on the successful implementation of government plans and members’ business opportunities. Consumer protection is a basic building block for confidence, and I hope that we are able to make positive, pragmatic improvements in the coming months.