Broader Group application process in Scotland proposed for replacement by data matching from winter 2026/27

The Warm Home Discount (WHD) in Scotland would move from an application-based Broader Group to a data matched broader Core Group under Options 2 and 3 of a Department for Energy Security and Net Zero (DESNZ) consultation, according to a response from Consumer Scotland published on 21 November 2025¹. Consumer Scotland, the independent statutory body accountable to the Scottish Parliament, said it prefers either Option 2 or Option 3 for the next scheme period in Scotland¹.

The body said the application-based design of the Broader Group in Scotland between 2022 and 2025 "created additional access barriers for eligible Scottish households compared to those in England and Wales"¹. It also warned that "some consumers who received the Warm Home Discount in previous years may no longer receive it if the Government adopts Option 2 or Option 3"¹.

The discount has risen from £120 to £150 since it was introduced in 2011, an increase of 25%, while typical annual bills rose from £1,118 to £1,755 over the same period, an increase of 57%, Consumer Scotland said¹. It added that the discount "is not indexed in any way"¹. Under the current proposals, the WHD is due to increase to an average cost of £37 a year for a typical dual fuel billpayer¹.

Consumer Scotland cited its 2025 Energy Affordability Tracker, which found 16% of respondents, equivalent to 393,000 households, find it difficult to keep up with their energy bills, and that the proportion in energy debt rose to 15% from 9% in 2024¹. It said the impact assessment for the proposed scheme expects it to reach only 45% of fuel poor households from scheme year 2025/26 onwards¹.

On delivery, Consumer Scotland said automatic data matching offers the chance to pay support during winter, whereas under the current Broader Group suppliers can provide support as late as March¹. It recommended payments between November and January¹. It also supported a centralised WHD helpline for partially matched Scottish consumers, noting that in England and Wales 96% of consumers receive the rebate without taking any action, while the remaining 4% "may still include vulnerable households"¹.

Why it matters for households

The change would affect working-age households in Scotland who currently receive the discount through the Broader Group, which is the part of the scheme for consumers who do not qualify through the Core Group. Under Options 2 and 3, eligibility would be determined by data matching rather than an application, and Consumer Scotland states that some people who received the discount in previous years may no longer receive it¹. The consultation sets out limited data on the impact on Scottish consumers, and Consumer Scotland has called for further detailed impact analysis of Options 2 and 3 before a decision is taken¹.

Consumer Scotland also raised targeting concerns. It said neither option fully aligns with the Scottish definition of fuel poverty, and that Option 2 risks excluding households that are fuel poor and on means-tested benefits but do not meet prescribed vulnerability criteria, such as rural households or those reliant on electric heating¹. It noted that the most recent Scottish House Condition Survey, in 2023, estimated 31% of fuel poor households would not be considered income poor¹. On higher essential energy use, it cited an associated £124 in additional annual energy expenditure for disabled consumers whose activity limits them a lot, and research by Marie Curie showing bills can rise by as much as 75% after a terminal diagnosis¹.

The benefits hub sets out how means-tested support is structured, and the guide to Pension Age, Child and Winter Heating Payments in Scotland covers devolved payments north of the border.

What happens next

The consultation covers continuing the scheme beyond 31 March 2026, with the next scheme period running from 2026/27¹. Consumer Scotland has recommended that governments publish further impact analysis of Options 2 and 3 before any decision, and that any automatic data matching include a commitment to pay between November and January¹. It also recommended periodic reviews of the WHD every 12 to 18 months¹. No decision on which option will be adopted has been reported.