The National Audit Office reported that TrustMark only developed the analytical capabilities for identifying non-compliance trends in the latter half of 2024. Its funding model meant it did not have the free cashflow to develop these capabilities sooner.60 However, TrustMark told us it had been sharing the results of its audits with the Department in regular meetings since 2022, and started to identify the increased risk from 2023 into 2024, at which point it undertook more audits to better understand the level of risk.61 The Department believes that the Autumn and Winter of 2023–24 is also when the issues likely first became visible, after a ramp up of installations in the spring of 2023.62 UKAS and the Department also both told us that the intelligence that was available (for example data on installations, audit results and consumer complaints) was not being escalated or drawn together as it should have been to understand levels of 56 C&AG’s Report, paras 19 and 3.5 57 Qq 49, 52,55, 115, 116 58 C&AG’s Report, para 3.6 59 Q 89, 116, 117 60 C&AG’s Report, para 21 61 Qq 49, 52 62 Q 115 18 risk and non-compliance.63 Neither TrustMark nor DESNZ have been able to provide minutes of meetings which took place between 2022 and 2024, and the Department has written to us to say that it has no evidence that it was notified earlier than October 2024.