The Former Permanent Secretary told us that while the Department was “acutely conscious” of the fraud risks within the schemes, it thought that the design of the energy support schemes meant that the risks of fraud were much lower than those for loan schemes introduced during the pandemic. They explained that “universal schemes, by their nature, are much less fraud-prone” because there was no application process, and there were fewer opportunities for money to be passed onto people who do not qualify for the schemes. They further explained that the schemes relied on existing infrastructure and customer relationships, by requesting energy suppliers to deliver benefits to existing customers. The schemes therefore did not have any of the new-to-bank customers issues faced by schemes to support businesses during the pandemic, such as bounce-back loans. Some schemes, such as the EBSS Alternative Funding route and AFP for consumers who are fully off-grid, do require consumers to apply for the scheme. They told us that fraud and error risks were much more substantial for these schemes but that the Department had sought to implement processes that would cross-check applications with other data sources.40