Warm Homes: Local Grant Grant Recipient - Fraud, Error & Non-Compliance Assurance
Introduction
RISE is working with recognised fraud experts, Deloitte, to support the delivery of the Fraud, Error & Non-Compliance Assurance (FENC) workstream. As part of their work on Grant Recipient Assurance, Deloitte have worked with DESNZ to develop the following guidance.
Through September to November 2025, the Grant Recipient (GR) FENC Assurance team at Deloitte has undertaken reviews focused on applicant eligibility checks performed by GRs in the Local Grant Scheme. All GRs should consider the below guidance to help strengthen the Scheme’s overall defences against FENC.
Contents
Eligibility checks
we are aware that some GRs may be applying their own additional eligibility thresholds (such as restricting access to the Scheme for applicants with assets over a certain threshold) on top of those required under Scheme rules. While GRs do have discretion to prioritise applicants under certain eligibility pathways, please DO NOT apply any additional eligibility thresholds on top of those required by the Scheme rules. Please only apply the Scheme rules. The Scheme rules were carefully considered during design and applying additional eligibility thresholds risks restricting the overall success of the Scheme.
Park Home ownership
Please ensure you are verifying ownership of Park Homes. Whilst not listed on the Land Registry, Park Home owners typically have a contract with the owner of the site, which can be collected to verify ownership.
Tenant checks
For applications relating to the private rented sector, please ensure that you perform both income and address checks on tenants to ensure that:
- They reside in the relevant property.
- They meet the income eligibility criteria.
Expired documentation
Please only accept in-date documentation to perform eligibility checks. A valid, in-date EPC is necessary prior to sign-off of any retrofit works and if any out-of-date documentation (e.g. an expired driver’s license) is presented, please request alternative in-date documentation.
Photograph ID
To reduce the risk of impersonation fraud, we recommend that GRs routinely collect photographic ID from applicants.
Rolled-over HUG2 Scheme applicants
Where applicants are rolled over from the HUG2 Scheme, please obtain refreshed applicant information, to ensure that the applicant’s circumstances have not changed such that they are no longer eligible. Information used for eligibility checks should have been obtained in the past six months.
Delivery partners
While Delivery Partners can create efficiencies, we remind GRs that they must be able to demonstrate active oversight of the Delivery Partner’s work, and have access to the eligibility checks performed by their Delivery Partner. A GR remains accountable for the work that has been undertaken by a Delivery Partner.
Timing
To enhance efficiency, we recommend that GRs perform property checks prior to income eligibility checks, as property checks are quicker, and may disqualify applicants early and avoid an unneeded income eligibility check.
Income eligibility - lodger income clarification
Regarding what income should count towards income eligibility thresholds, please note the following:
- The income of every adult member of the household counts towards the gross household income threshold, other than those in full-time education.
- The income of lodgers, who are not considered members of the household, should not count towards the income threshold, however, where the household is in receipt of any rental payments from lodgers, this should be counted towards the household income.
Phishing attempts
Be vigilant against phishing attempts during the holiday season, as cybercriminals often exploit this time with fraudulent emails and links. Always verify the sender's identity and avoid clicking on suspicious links or sharing sensitive information without verifying who it’s going to. Red flags to look out for include:
- Time-sensitive requests for payment.
- Unexpected contact from unfamiliar email addresses.