Tackling Fuel Poverty in Scotland - periodic report 2021-2024: Scottish Fuel Poverty Advisory Panel's response

Part 1: Progress, Targets and Drivers

Part 1 sets out the Panel’s view on the progress towards and likelihood of reaching Scotland’s fuel poverty targets, how the Strategy is supporting this and the extent to which the four drivers of fuel poverty are being addressed.

We begin with our assessment of progress on the fuel poverty targets before setting out our analysis on the framing of the Strategy and its impact on the periodic reporting. We then review each fuel poverty driver in turn in relation to the evidence given in the Scottish Government’s Periodic Report.

The Fuel Poverty Targets

The ambition of Scotland’s fuel poverty targets and its robust definition of fuel poverty demonstrate laudable national commitment. Scotland’s other statutory targets also help to set the tone for a strategic direction which has the potential to reinforce the work to tackle fuel poverty, namely the child poverty, climate change and heat network targets.

Figures 1 and 2 show levels of fuel poverty and extreme fuel poverty from 2019 to October 2025, compared to the statutory targets.

The first interim target sets out that by 2030, no more than 15% of households in Scotland are in fuel poverty, no more than 5% of households in Scotland are in extreme fuel poverty, and the median fuel poverty gap is no more than £350.

However, the latest statistics suggest rates far in excess of this (34%) and significantly increased from the recorded level of fuel poverty in 2019. When the fuel poverty targets were set, fuel poverty rates stood at 25%. Implicit in the target milestones is achieving an annual average 1%+ reduction in fuel poverty levels sustained over a 20-year period.

Fuel poverty time series 2019 to October 2025, with statutory targets

Extreme fuel poverty time series 2019 to October 2025, with statutory targets

The Panel considers that in setting ambitious interim targets and a target for 2040, the ScottishGovernment did not set out a clear vision for progress - or monitoring and evaluating thereof - in improving energy efficiency, increasing income levels or assumptions on energy mix and costs.

There is little evidence in the Periodic Report to suggest that the current Strategy is meeting or can meet these statutory targets.

The Periodic Report does not contain any self-reflection on how far the Scottish Government’s policy actions between 2021 and 2024 have taken it towards meeting the 2030 interim target date.

It also does not contain any assessment of what additional measures are needed (if any) to achieve either the interim or the 2040 targets.

Based on the best available evidence, the Panel’s view is that given current levels of fuel poverty, the 2030 interim fuel poverty targets are extremely unlikely to be met.

The Fuel Poverty Strategy

The Strategy was published before the appointment of the Statutory Panel. We acknowledge that the Scottish Government consulted key stakeholders in its development. In previous advice to the Scottish Government between 2022 and 2024, the Panel identified weaknesses in the Strategy and explained that as it was developed in response to the prevailing circumstances at the time, it did not respond to the challenges that were now presenting in Scotland.

The Panel also highlighted that the wider policy landscape was evolving, and that some of the actions in the Strategy did not address fuel poverty specifically.

It is the Panel’s view that the Scottish Government should fulfil its statutory commitment to revising the Strategy by December 2026. We previously made a recommendation for an interim update to the Strategy, as well as bringing forward the revised Strategy date to May 2026.

We stand by this advice but given that no interim update has happened, we would reiterate the statutory requirement for the Strategy to be reviewed by December 2026 and Scottish Ministers’ previous commitment to the Panel.

We also note that the Periodic Report makes no reference to revising the Strategy.

It is the Panel’s view that since the Act and the statutory fuel poverty targets which it brought in were established under a broadly similar devolution framework to that which exists now, the resulting Strategy and targets should have been developed in full cognisance of reserved and devolved powers.

This should have been supported by a strong evidence base that the targets were obtainable based on Scottish Government action. As such, it is the Panel’s view that it is difficult to use the scope of reserved powers to explain missing the targets.

Any revised fuel poverty strategy developed should reflect the current view of devolved and reserved powers.

In Scotland, a household is in fuel poverty once it has paid for its housing if a) it needs more than 10% of its remaining income to pay for its energy needs, and b) if after paying for its energy the household is left in poverty (as defined by the Minimum Income Standard).

There is no standardised fuel poverty definition across the UK and the Scottish definition, based on the energy costs as 10% of a net income ratio, is recognised as a competent technical and comprehensive definition of fuel poverty giving an accurate depiction of levels of fuel poverty. The definition is critical not only as the measure by which fuel poverty levels are assessed but also as the underpin for any strategy to tackle fuel poverty.

One of the identified shortcomings of the Strategy is that it does not discuss the relative impact of each of the fuel poverty drivers on fuel poverty in Scotland.

The Periodic Report does recognise the significance of higher energy costs on fuel poverty levels but not its relative impact.

It also does not provide any assessment of the impact of the different actions set out in the Strategy on fuel poverty levels as measured by the Scottish definition, or the lived experience of fuel poverty, modelled or otherwise.

This makes it challenging to understand which drivers the Scottish Government considers most pressing to address and which actions are working, or not.

There is also a strategic question about how Scottish Government’s other statutory targets for child poverty, climate change and heat network development connect to the delivery of the fuel poverty targets given the intersectionality that exists between these policy areas.

The Panel notes that the Periodic Report makes no assessment of the relationship between the 2030 child poverty target, 2045 climate change target, the 2030 heat network target and the fuel poverty targets. This not only highlights a weakness in reporting but potentially in the management of pan-government strategic programmes.

When the Strategy was agreed, it was the Scottish Government’s plan to have a monitoring and evaluation framework in place before the Periodic Report was produced. The failure to develop an appropriate monitoring and evaluation framework makes the efficacy of actions and progress hard to assess.

It also makes it extremely challenging for the Panel to objectively assess the policy and funding impacts set out in the Periodic Report and to fulfil our statutory role of scrutinising the Scottish Government’s progress towards delivering Scotland’s fuel poverty targets and the extent to which the four drivers of fuel poverty are being addressed.

In the Panel’s view the Strategy and Periodic Report fail to develop the links between the definition, targets, drivers and actions.

The lack of clear accountability or responsibility for delivery and monitoring and evaluation of the Strategy, insufficient assessment of weighting and prioritisation of the drivers and actions, and a lack of assessment of the impact of the actions on fuel poverty levels, undermines the Strategy and therefore the Periodic Report.