Rejected Application
13. Mr L complains that Ofgem wrongly rejected an application he and his wife made for the Boiler Upgrade Scheme (BUS). The couple had written to Ofgem to say they were concerned that Ofgem had wrongly rejected the application, and then once they raised this, that Ofgem simply tried to find other (also invalid) reasons to reject it.
14. They had explained in a letter to Ofgem (dated 23 July 2024) that: “The address is correct - ‘The Farm’ is a group of buildings with a single postal address. It is not a related property - the planning permission and conversion create it as a separate dwelling and our installer has received many vouchers for similar conversions”
15. Ofgem’s first complaint response came on 19 August 2024 and noted that there had been some issues with the UPRN. It apologised for any confusion caused by this (though did not say what the issues were).
16. Ofgem explained that the application property (The Farm) is an existing registered property and separate from the ASHP installation address (The Barn).
17. It went on to say that the BUS team were unable to amend the installation address on the portal after receiving consent from the property owner, and that it would be necessary for the complainants to resubmit the application with the correct installation address of the ASHP provided.
18. Ofgem notes this was stated in an email to the installer on 23 May 2024, in which it wrote:
19. “During our review it was identified that the property owner consented to the incorrect installation address. We are unable to amend the address once consent has been received so we have made the decision to reject the application in accordance with regulation 15(7).” A review of this regulation in the UK Government legislation ‘The Boiler Upgrade Scheme (England and Wales) Regulations 2022’ shows that it states:
20. “The Authority must refuse to issue a boiler upgrade voucher— (a)where it considers that the grant application does not comply with regulation 14(1), (b)where it is not satisfied that the conditions in regulation 14(2) are met in relation to the grant application, or (c)after 31st December 2024”
21. The additional regulations referred to their state:
“.—(1) An installer may make an application to the Authority for a boiler upgrade grant (a “grant application”) in relation to the installation of an eligible plant— (a)for an eligible property, or (b)in a property that— (i)meets the requirements in regulation 5(1)(a), (b) and (c)(ii), and (ii)does not meet the requirements in regulation 6 because the valid energy performance certificate for the property includes a recommendation report which recommends that loft insulation or cavity wall insulation or both be installed, and where the reasons set out in regulation 6(2) do not prevent such insulation being installed, provided that the conditions in paragraph (2) are met.
The conditions in this paragraph are that— (a)the owner of the property— (i)consents to the installer making the grant application, (ii)will become the owner of the eligible plant on completion of the installation, (iii)has not received a grant from public funds in respect of any of the costs of the purchase or installation of the eligible plant, and (iv)in the case of an application falling within paragraph (1)(b) (property not eligible at the time of the grant application), intends to— (aa)install any loft insulation and cavity wall insulation recommended in the recommendation report, and (bb)obtain a valid energy performance certificate for the property which demonstrates that that insulation has been installed, by no later than the date on which the application to redeem the boiler upgrade voucher is made, (b)the installation of the eligible plant is not a measure promoted by an electricity or gas supplier for the purpose of achieving their home-heating cost reduction obligation under section 41B of the Electricity Act 1989(1) or section 33BD of the Gas Act 1986(2), (c)a boiler upgrade grant has not previously been paid to an installer in accordance with regulation 16(6)(b) in relation to the installation of any eligible plant in the property, and (d)if the installer is paid the boiler upgrade grant in accordance with regulation 16(6)(b), it will be used by the installer solely to fund the installation of the eligible plant.”
22. Ofgem explained that this does not mean that the property is ineligible (although this would be subject to a review of full application), but that the couple would need to reapply for the correct installation address in the first instance.
23. Ofgem went on to say that this is not a guarantee of eligibility, and that a new application would be subject to the rules and regulations that govern the scheme.
24. A further response was provided on 25 September 2025 and discussed the issue with the UPRN. Ofgem explained that a UPRN check is an internal control used when reviewing an application to ascertain that the correct property has been applied for. It said that in this instance the installation address and UPRN number were for the main property at the Farm.
25. When reviewing the provided funding evidence, Ofgem says it became aware that the works appeared to be for a barn conversion. A further investigated and additional evidence (including planning permission maps) confirmed that the installation address given (the Farm) was a separate building to the actual installation address and therefore required an application specifically for that property.
26. Before we decide if we should conduct a detailed investigation of a complaint, we look at whether there are signs the organisation has got something wrong. We do this by comparing what should have happened with what did happen. We have done this and have not found any indications that something has gone wrong. [Give specific detail on your decision below. Please remember to refer to a standard to explain what should have happened for each complaint component]
27. During our investigation we wrote to Ofgem to request policy documents and to ask for it to provide further information about the reasons the application was rejected.
28. Ofgem directed us to its policy document ‘Boiler Upgrade Scheme: Installer Guidance V4.2). The document contains guidance for installers who want to benefit from the BUS.
29. Section 3 of the document covers ‘Eligibility requirements’ which includes outlining the need for a UPRN, which a specific sub-section for separate dwellings. The guidance explains:
• “If a building (such as a converted barn or existing annex) is on the same land as a main property but has since been separated, and is considered a legally separate dwelling, it may be eligible on BUS as an existing dwelling or self-build property.
• One of the factors involved in determining whether a property is legally separate is whether it has or will have its own EPC (for existing dwellings). We may request a combination of available evidence such as a UPRN, council tax liability, planning documents or mapped evidence to confirm a property’s eligibility as a separate dwelling.
• An extension on a property would not be classed as a self-build or considered a legally separate property and thus would not be eligible for the BUS. However, the entire property may be eligible to apply as an existing dwelling.”
30. It would be helpful here to provide clarity the use of UPRNs on the BUS scheme for additional context. UPRNs are used here by Ofgem as an internal control to ensure the correct property has been applied for and consented to by the property owner.
31. In an instance where the installation address is not available as a pre-populated option on the portal (e.g. in situations where construction is still underway, the property has not yet been registered or when the name of the property is being changed) the installation address can be entered manually and a dummy UPRN assigned to it within the BUS Operations team.
32. To back this up, Ofgem referred us to its ‘Boiler Upgrade Scheme: Installer guidance v2.6, which states:
33. “If the eligible self-build does not yet have a confirmed address, we will accept a temporary address given by the local authority, approved planning reference number or the coordinates of the property, provided that these details are used consistently throughout the process.”
34. Ofgem advised this is to ensure that there is a record for each property and to avoid situations such as where for example a farmhouse has already had a heat pump installed but a subsequent application for a different building on the same farm e.g. a barn conversion is rejected as the named building has already received grant funding and would be ineligible.
35. We reviewed email conversations between the complainants and Ofgem’s BUS Team. On 9 May 2024, Ofgem noted that there were 3 titles mentioned in the Title Deeds to the property and asked whether all 3 comprise the Farm. It explained it was unable to location the planning permission for the Barn conversion that matched the UPRN provided.
36. The complainant’s replied on 10 May 2024 to explain that there are three deeds that comprise the Farm:
• The actual farm buildings • The land on the east side of the farm • The land to the Northwest of the farm
37. They provided Ofgem with the original scheme and planning approval.
38. We can see from later emails that the complainants noted that Ofgem had asked for an address in the application, not a building identifier, and that Ofgem was effectively asking them to make up an address because it had rejected the actual one. Mr L had also advised they had been told the UPRN in the application could not be amended to the correct one, and that a new application must be begun. We approached Ofgem to ask the reason for this (if it was indeed the case), and requested it provide a copy of any policy document that outlines this.
39. Ofgem explained the given installation address can be amended before consent from the property owner has been received. It said that if an error in the installation address is reported after the consent from the property owner has been received, the BUS team are not able to amend the address on the portal as the consent would no longer be for the initially named property and thus would no longer be valid. It said that in this instance, a new application for the correct installation address would need to be submitted and new consent for the new installation address would need to be given.
40. Ofgem noted that Regulation 14(2)(a) of the UK Government legislation ‘The Boiler Upgrade Scheme (England and Wales) Regulations 2022’. This shows a requirement for the owner of the eligible property to consent to the installer making the grant application.
41. Ofgem says that during the review process, the BUS team noted that the funding evidence provided referred to ‘a barn conversion’, as opposed to works done on the given installation address. It says that further investigation by the reviewer confirmed that the heat source was being installed in a separate building on the farm and not the farmhouse itself, as stated on the BUS portal.
42. This was confirmed by the property owner, who also provided the planning permission information for the installation address. Once it became apparent to the BUS team that the installation address was not ‘The Farm’ but rather ‘Barn at The Farm’, the installer was required to reapply for the correct address.
43. Mr L had told us that the UPRN which was used and resulted in the application being rejected was actually provided by Ofgem, not by him. We approached Ofgem for comments on this, and asked it to confirm whether this was correct, and, if so, why this UPRN was provided if it was not the correct one for the building.
44. Ofgem explained that “when entering the installation address on the portal the installer can select a pre-populated address within the system, which then populates the UPRN that corresponds to the given address on the BUS portal provided on the application form. Each property has a unique UPRN which identifies it on maps and websites such as Geoplace and FindMyAddress, both are used by the BUS team to confirm the address which has been applied for. The UPRN (associated with the installation address given by the installer) is then used to confirm the given installation address against the actual installation address as confirmed by the property owner.”
45. Mr L had also told us that Ofgem has refused to let them reapply, even though their application would be valid. We asked Ofgem to confirm whether this is accurate, and if so, what the reason is for this.
46. It explained that the Air Source Heat Pump was commissioned on 5 January 2024, and the voucher application was subsequently submitted a few months later on 7 May 2024, which was only one day prior to major changes in the Regulations on the BUS scheme, following a consultation by DESNZ.
47. Ofgem advised that these changes came into force on 8 May 2024 and introduced a requirement that the commissioning date of the heating system has to be no more than 120 days prior to the voucher application being properly made (i.e. when consent has been received from the property owner, along with all additional information required to fully process the application and reach a decision on its eligibility). If the installation was commissioned more than 120 days prior to an application being properly made, the heating system would not be eligible.
48. Often explained that as further information and clarification was required on the application a decision was not made on the application until 23 May 2025, which means that the application and any subsequent re-applications for this property would be subject to the 120-day commissioning rule. As the date was outside this timescale, any new application would not be eligible.
49. Ofgem said that it normally recommends installers wait until a voucher application has been made and the voucher has been successfully issued before commissioning the eligible system at a property. However, it explained that it understands in some circumstances commissioning may occur prior to submitting a voucher application and said that in these situations there is additional risk incurred by the installer and property owner.
50. Mr L had advised us that the application form did not ask for a UPRN (or any building identifier), just the address. We approached Ofgem and requested a copy of the information entered in the application form, which it provided, and so we were able to review the information entered by the couple online:
51. Ofgem explained that “Regarding the UPRN value you can see on the initial application form, when the installer puts an application through, they have to enter the installation address on the BUS portal and select a pre-populated address. This in turn then populates the UPRN that corresponds to the given address on the BUS portal provided on the application form.
52. For clarification on the encoding on the application form data entered by the couple (which PHSO has viewed), "1" indicates "yes" and "0" indicates "no".”
53. We asked Ofgem for clarification that this means that the customer wouldn’t choose the UPRN number that is entered themselves. Ofgem confirmed that this is the case, and that the customer wouldn't know if the correct UPRN had been entered, as it would be populated based on the installation address provided by the installer on the application
54. While we understand that there is a difference between a UPRN and a postal address, Ofgem’s argument that it rejected the couple’s application due to them supplying the wrong UPRN number seems unreasonable given it has confirmed that they did not supply this.
55. However, rather than being an incorrectly rejected application, it seems rather that this is an unclear explanation of the reason for rejection. While the couple were not rejected to supply the UPRN themselves, we can see that Ofgem would have required the application to be for the barn conversion specifically and would have needed evidence including planning permission maps to confirm that the installation address given (the Farm) was a separate building to the actual installation address.
56. While we appreciate the couple’s frustration with this process, ultimately Ofgem was not incorrect to ask for a new application to be made. With this in mind, we will end consideration of this point here.
Complainant:
57. Mr L says that Ofgem’s complaint response gave incorrect reasons for the rejection, and the matter was not treated seriously.
58. Ofgem’s initial response (19 August 2024) explains that its complaints process covers complaints about Ofgem’s staff, policies, or customer service. Any dispute about an application decision would be handled separately either by the disputes team of a specific scheme, or by its Statutory Review team. It explained that complaints do not have the power to overturn a decision made in accordance with its Regulations.
59. After a further email from the complaints (25 September 2025), Ofgem provided a further response on 24 October 2024. This came from the Senior Engagement Manager for Complaints.
60. Ofgem explained it had reviewed the previous response and was satisfied that the information provided regarding the ineligibility of the voucher was correct. It also reiterated the position from the previous response that it does not have the power to overturn a decision made in accordance with the Regulation.
61. To begin, we must be clear in explaining PHSO’s function here. With this point, we are not examining whether the answers provided following the investigation were correct (where relevant, this has already been reviewed in the previous point).
62. When investigating a complaint that an organisation’s complaint handling was not carried out correctly, our role is simply to examine whether the organisation’s complaints process was correctly followed.
63. As part of this investigation, we reviewed Ofgem’s online guidance ‘Complaining about Ofgem’. This outlines Ofgem’s complaint policy, and how customers can expect their complaints to be handled. Part of this includes a list of the steps involved, and the timeline by which customers should expect to meet them. The steps listed are:
• “Within 2 working days - We will acknowledge your complaint.
• Within 20 working days - We will investigate and write to you with our response. If it is not possible to get back to you within this timeframe, we will update you on progress within the 20-working day period.
• Unhappy with the response - If you think our response is unsatisfactory, please tell us by email or letter at the address below. We will get back to you within 20 working days of you letting us know.
• Taking it further - If after this you are still not satisfied, you can refer your complaint to the Parliamentary and Health Service Ombudsman for an independent review.”
64. The initial complaint was made on 23 July 2024, and we can see that Ofgem provided its response in writing on 19 August 2024. This would be 20 working days in total and so is in line with the policy.
65. As the couple were dissatisfied with the response provided, they raised further concerns on 25 September 2025. A further response was given by Ofgem on 24 October 2024. This response came on the 21st working day. While this may be outside the expected window, it would be by a day at most, which we would not consider an unreasonable delay.
66. We can also see from the email trail records that throughout the period in question, there were quite a number of emails back and forth between Ofgem and the couple, with the complaint being discussed in detail.
67. While we appreciate that the couple are not happy with the responses provided to their complaint, we can see that responses were given, and the points raised were addressed. Ofgem also operated in a timely fashion in responding.
68. With that in mind, we are satisfied that Ofgem’s complaints handling was in line with its policy on this occasion and so will end consideration of this point here.