HUG closure

Wet central heating, which includes the plumbing and radiators installed throughout the house for heating, is a measure on the HUG2 automated batch system (ABS) and can be broken down across MCS and PAS 2030 measures, but it is not a distinct measure within TrustMark lodgement. When lodging on TrustMark, the wet central heating system (i.e. pipes, radiators etc) connected to or upgraded is assumed.

However, if other PAS 2030 measures are installed i.e. other components of a heating system such as heating and hot water controls, that are not part of the air source heat pump (or an alternative heating system), then these measures should be logged separately as they will require suitable certification under PAS 2030.

The data dictionary, which is publicly available for all registered businesses, lists all measures that can be lodged against. The data dictionary can be found on the TrustMark website.

For example, if a project has installed an air source heat pump with associated pipes and radiators, alongside heating controls, the retrofit coordinator would need to:

1.    select the appropriate measure type for the air source heat pump:
a.    this could be “first time central heating” or “upgrade - no pre-existing heating controls”  or “replacing broken boiler – pre-existing heating controls” dependent on any pre-existing heating system
b.    lodge this as measure one
 

2.    select the appropriate heating control(s):
a.    for instance, “smart thermostat (no pre-existing programmer and room thermostat)” or “smart thermostat (pre-existing programmer and room Thermostat” dependent on any pre-existing heating system
b.    lodge this as measure two
 

3.    include additional heating control(s) measures:
a.    for instance, thermostatic radiator valves (TRVs)
b.    lodge TRVs as measure three.

Repair and maintenance are assumed and not typically lodged due to their enabling type of nature and are not PAS measures in themselves.

This process ensures that each installed component is accurately recorded and certified.
 

The department has received queries on whether batches can be amended to replace homes that have dropped out of receiving HUG2 upgrades with new homes. 

• the policy for HUG2 where a home drops out of a batch is that a new home cannot be added to replace the missing property and any new properties must be added to a new batch
• as the new batch deadline has passed it is now not possible to add new properties to replace homes that have dropped out. This includes substitution of a dropped-out home for one on a wait list
• any costs associated with a home that has dropped out of a batch and not received any upgrades under the scheme should be categorised as abortive A&A costs
• where you have new homes available to be upgraded these could form part of your pipeline for Warm Homes: Local Grant if you are intending on participating in that scheme, and if the new homes meet all eligibility requirements

As part of grant recipient internal assurance assessment(s), you will need to determine the level of assurance/audit that is required. If an audit is undertaken, the department will require sight of the final agreed report. If reconciliation activities, closure activities or fraud risk assessment highlights any issues, the department, in consultation with the grant recipient, may ask for an audit or assurance to be conducted.

The department will invite a small number of grant recipients to be input into its own assurance and evaluation processes. These are planned during spring to autumn 2025 and the department or their contractors will contact those grant recipients directly during this period. 
 

While all funding provided to grant recipients is capital for accounting purposes, HUG2 grant recipients are required, as set out in the MoU and scheme guidance, to report costs incurred in delivering their project against the three categories below:

• administrative and ancillary costs: these are costs such as resource, administration, reporting, data, search costs and ancillary costs include loft clearance, piping, radiators, old boiler removal, insulation removal where not covered by guarantees/insurance
• capital costs: these are costs relating specifically to the installation of a measure (including labour and transportation), e.g. energy efficiency upgrades and low carbon heating
• additional capital costs: which are costs that that do not relate to a specific measure but relate to the entire house, can be recorded as ‘additional’ capital

Please see below detailed guidance on what should be recorded against category.

Costs reported as admin and ancillary (A&A) must be kept to within 15% of HUG2 total spend. 

Grant recipients wishing to re-categorise spend, e.g. from A&A into ‘additional capital’, must do so via the monthly data submissions not by amendments to batches. Any adjustments of this nature must be made in the next monthly report.
 

Managing agent costs

If local authorities want to record some of their managing agent costs as ‘additional capital’ this must be split out from costs that we have advised come under A&A. Managing agent costs relating to activities such as project management, reporting and governance costs; project resourcing; and search costs associated with resident recruitment, low-income verification and sign-up including communication and marketing activities must be recorded as A&A costs as set out in guidance.

Responsibility for decisions on application of the guidance lie with the local authority. 
 

Following discussions between the department, BSI, the UK Accreditation Service (UKAS) and TrustMark, as well as consideration of industry’s comments in response to BSI’s public consultation on PAS 2035/2030:2023, a transition period of 18 months was initiated following publication of the documents to allow time for industry to adopt changes to the PAS 2035/2030 documents.

This transition period will end on 30 March 2025, after which BSI will withdraw the previous versions and retrofit projects must be carried out in accordance with 2023 version.

Any HUG2 funded work complying with PAS 2035/2030:2019 must be completed by Sunday 30 March 2025 and lodged in TrustMark’s data portal before no more than twenty working days thereafter. Where providers anticipate work on a property will continue beyond this, the department has strongly advised the use of PAS 2035/2030:2023 to avoid disruption related to the withdrawal of PAS 2035/2030:2019.

Therefore, the department asks you to prioritise delivery before the Sunday 30 March and ensure that any pre-assessments delivered under PAS 2035/2030:2019 are lodged before this date.

We are aware that there may be projects where this will not be possible, and we are exploring whether there are options for those - an update will be provided on this as soon as possible. If you do have projects that were assessed under PAS2019 that can’t be completed by Sunday 30 March you should inform your SPOC as soon as possible.

Retrofit installers with questions regarding their PAS 2030 certification should contact their certification bodies who will be able to advise further.