Recommendation 23

We asked the witnesses whether they had analysed the guarantee policy wording to ensure they did not include excesses or complex issues that render them useless in practice, or had reviewed the balance sheets of the 39 Q 64 40 C&AG’s Report, para 16 41 Qq 59, 60 42 FEE023 43 Q 151 44 Q 58; C&AG’s Report, para 15 45 Letter from TrustMark, dated 25 November 2025 46 Q 82 47 Q 68 48 Letter from the Department of Energy Security & Net Zero, dated 2 December 2025 15 cover providers. TrustMark and the Department told us that TrustMark’s financial protection panel, which consists of external independent members, had initially reviewed all guarantees to ensure they were fit for purpose, and that TrustMark had also been looking at the policies again over the last 12 months to ensure the affected homes were covered.49 In written evidence provided after the oral evidence session, the Department explained that to invoke a guarantee where the installer is still trading but has failed to rectify the problem, consumers must first work through TrustMark’s dispute resolution process. This includes escalating the dispute to the Dispute Resolution Ombudsman (DRO). If the DRO rules in the consumer’s favour, and the installer still fails to rectify the problem, the guarantee provider will at that point step in to remediate the property, assuming the guarantee in question has a “failure to rectify” clause.50 We are concerned that these processes will take too long especially where there are serious defects causing health issues of the occupants.