Introduction

This statement sets out Brighton & Hove City Council’s flexible eligibility criteria for the Energy Company Obligation (ECO4) scheme which has been extended to 31 December 2026.

The ECO4 scheme will focus on supporting low-income and vulnerable households. The scheme will improve the least energy-efficient homes, helping to meet the Government’s fuel poverty and net zero commitments.

The flexible approach for Local Authorities (LAs) to identifying fuel-poor and vulnerable households who may benefit from heating and energy-saving measures is referred to as “ECO4 Flex”. 

The council is publishing this Statement of Intent (SOI) on 8 April 2026 to confirm that each of the households declared will adhere to at least one of the four available routes outlined on the following page

Routes

Route 1

SAP Band D to G Owner-occupied and private rented sector households with a gross annual income less than £31,000. 

This cap applies irrespective of the property size, composition, or region. 

Route 2

SAP Band D to G Owner-occupied and private rented sector households that meet a combination of two of the following proxies: 

  • Proxy 1 - Homes in England in Lower-layer Super Output Area 1-3 (LSOA)
  • Proxy 2 - A person living at the premises is entitled to a Council Tax reduction on the grounds of low-income (excludes single person rebates).
  • Proxy 3 - A person living at the premises is considered to be vulnerable to the cold under the National Institute for Health and Care Excellence (NICE) Guidance NG6: Recommendation 2, for a reason other than their low-income. This includes:
    • people with cardiovascular conditions
    • people with respiratory conditions (in particular, chronic obstructive pulmonary disease and childhood asthma)
    • people with mental health conditions
    • people with disabilities
    • older people (65 and older)
    • households with young children (from newborn to school age)
    • pregnant women
  • Proxy 4 - A child living at the premises is eligible for free school meals due to low-income
  • Proxy 5 - A person living at the premises is supported by a scheme established by the LA/DA that is named and described within their Statement of Intent and established to support people living on a low-income and considered vulnerable to the cold under NICE Guideline NG6. This proxy is not being used.
  • Proxy 6 - A household referred to the LA for support by their energy supplier or Citizens Advice because they have been identified as struggling to pay their electricity and/or gas bills. 

Note that proxies 1 and 3 cannot be used together. 

Route 3

SAP Bands D to G owner-occupied and private rented sector households that have been identified by either a person registered in the General Practitioner Register, an NHS Foundation Trust, or an NHS Trust as vulnerable, with an occupant whose health conditions may be adversely affected by living in a cold home. 

These health conditions may be cardiovascular, respiratory, immunosuppressed, or related to limited mobility. 

This is because the Council have identified a positive correlation between households that suffer from long-term health conditions and living on a low-income, with living in poorly insulated homes. 

Route 4

Brighton & Hove City Council does not currently have a Bespoke Targeting route. 

Declaration and evidence check confirmation 

All potentially eligible households should apply through Brighton & Hove City Council to see if they can either benefit from the scheme or be assessed for eligibility under any other relevant programme. 

Residents can contact the council using the contact information below to get details of approved ECO installers that the council is currently working with. 

It should be noted that the final decision on whether any individual household will benefit from energy saving improvements or heating rests with obligated energy suppliers or their contractors.

Inclusion in a Declaration of Eligibility issued by the council to an installer will not guarantee installation of measures. The final decision will depend on: 

  1. Identification of measures eligible under ECO Flex.
  2. The supplier's assessment of the cost-effectiveness of installing measures in relation to achieving its obligation.
  3. Whether the supplier has achieved their targets or requires further measures to meet their Energy Company Obligation targets. 

A Brighton & Hove City Council officer will be responsible for checking and verifying evidence, and issuing declarations. For any general enquiries relating to this SOI, please contact:

CEO or dedicated responsible person mandatory signature

Brighton & Hove City Council will administer the ECO4 Flex scheme according to the Electricity and Gas (Energy Company Obligation) Order 2022 (ECO4 Order).  

Brighton & Hove City Council will administer the Great British Insulation Scheme Flex according to the Electricity and Gas (Energy Company Obligation) Order 2023 (ECO4A Order). 

The dedicated responsible person of the council will oversee the process of identifying eligible households under the ECO Flex. The council will notify Ofgem of households that declarations have been issued for via the declaration notification template.  

All personal data collected or processed by Brighton & Hove City Council for the purposes of ECO4 Flex will be processed and stored in accordance with the council’s obligations under UK GDPR and the Data Protection Act 2018, the council’s data protection policy, the Information Commissioner’s Office Data Sharing Code and other guidance, and Department for Energy Security and Net Zero guidance. 

Signature:   

Miles Davidson, Sustainability and Energy Manager (Housing)

Date of signature: 7 April 2026