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Compliance

Do you still need RECC or HIES under the new MCS scheme?

SSolar Engine
··6 min read

Your Consumer Code fee arrives once a year. RECC or HIES. You pay it, it goes in the folder next to the certification body renewal and the public liability, and you get on with the day. It has never been a decision. It has been a condition of selling solar to a homeowner under MCS.

Under the redeveloped MCS Installer Scheme, it stops being a condition.

The sentence

The IAA, one of the bodies that certifies MCS installers, states it plainly on its page about the redeveloped scheme:

Once you have transitioned, Consumer Code membership becomes voluntary.

The same page, on timing:

The transition is being rolled out in phases throughout 2026 and into 2027. It affects every MCS certified installer in the UK - and preparation needs to start now.

Two sentences on a certification body's guidance page. That is where the change currently lives. Depending on who certifies you and how carefully you read their updates, you could be transitioned before you notice.

What is actually happening

MCS set out the shape of the redeveloped scheme in November 2024. It comprises four families of document:

MCS is clear that the technical rules are not the story. In its own words, the technical requirements "aren't changing… but they have been restructured and streamlined to be more focussed as 'technical truths'".

The story is the second family. Read the four names together and the mechanism is hard to miss: consumer protection is being absorbed into the MCS scheme itself. A separate Code becomes optional once the scheme carries a Customer Commitment of its own. That is our reading of the structure, not a statement MCS has made. But it is the only reading under which "voluntary" makes sense.

Why installers will read this as a saving

Because it is one. Code membership is a fee, an audit surface, and a set of obligations that overlap with obligations you already carry. An installer posting as BXB on ElectriciansForums in July 2021, listing what it takes for a small firm to get into MCS, put Code membership in the middle of a pile:

join a consumer code of conduct (actually not a bad thing, I have found HIES to be very helpful and sensible but the RECC to be very slow), sort out deposit protection insurance, guarantee insurance and dozens of other jobs that just eat away at the time you could be spent doing something productive

One installer. Five years ago. That is his view of two organisations, not a finding about either, and both have had five years to change since he wrote it.

Quote it for the shape of the list, not the verdict. Code membership, deposit protection insurance and guarantee insurance are three separate lines. Dropping the first does not obviously touch the other two. Whether the new Customer Commitment picks any of them up is the question — and it is not yet answered.

The part MCS hasn't finished

MCS ran a consultation on financial protection in April 2025. It published the outcome on 19 August 2025, recording "over 30 detailed responses, including submissions from the Competition and Markets Authority (CMA) and the Department for Energy Security and Net Zero (DESNZ)".

That is a serious respondent list. It is also a respondent list that generates work. The outcome names matters still unresolved at that point, including:

Read the third one twice. In August 2025, the process for approving the products that protect a customer's money had not been settled.

As of July 2026 we can find no MCS publication finalising those financial protection requirements. If one exists, it is not where an installer would look for it.

This is not a scandal, and we are not presenting it as one. Consultations that attract the CMA and DESNZ take time, and taking time over the definition of "wear and tear" is better than not taking it. But it means something specific for you. Installers are being transitioned, in phases, onto a scheme whose financial-protection layer has not been published in final form. You are being invited to give up a known obligation in favour of one that is still being drafted.

Deposits and IBGs are not theoretical

The financial protection layer is not a filing exercise. It is the part that holds money.

Only Panels, a UK solar installer podcast, published an episode on 24 June 2026 titled "Are DNOs Forcing Installers to Break the Law?". Its description of the DNO backlog is that administrative delays are "actively risking customer deposits and causing Insurance Backed Guarantees (IBGs) to expire before tools even hit the roof".

Take that at face value and the picture is clear enough. Deposits are exposed and IBGs are timing out for reasons entirely outside the installer's control, today, under the arrangements that already exist. That is the machinery whose replacement has not been published.

Voluntary is not the same as pointless. It means you now have to work out, yourself, what your Code membership was actually doing — at a moment when the thing that might replace it is incomplete.

The family that lands in your quoting software

One of the four document families is Pre-sale Information and System Performance Estimate Standards. That is the rulebook for what a customer must be told, and shown, before they sign.

It is also the family that ends up inside whatever tool you generate quotes and performance estimates with, ours included. There is nothing to implement until it publishes. It is worth knowing which of your suppliers is watching for it.

Before you cancel anything

Nothing above says drop your Code. It says the choice is arriving, in phases, and the information you need to make it is incomplete. Four things worth doing.

  1. Find out where you are in the transition. Ask your certification body which phase you sit in and whether you have transitioned yet. "Voluntary" only applies afterwards.
  2. Ask what replaces the financial protection. Specifically: which Financial Protection Products your body will accept, and whether the approval process discussed in the August 2025 consultation outcome has since been published. If nobody can point you at a document, you have your answer about timing.
  3. Read your own schedules. Deposit protection insurance and guarantee insurance are separate contracts. Establish what is genuinely tied to your Code membership and what is not — before you find out by cancelling it.
  4. Check who else requires it. Code membership may be a condition of a finance provider's panel, a lead source's terms, or a framework you sit on. MCS making it voluntary does not make it voluntary for them.

The honest summary is short. Under the redeveloped scheme, Consumer Code membership becomes voluntary once you have transitioned. What that membership was doing for your customers' money has not yet been fully written down anywhere else. Verify before you cancel.

Sources

  1. MCS redeveloped Installer Scheme, IAA
  2. Update on the redevelopment of MCS, MCS
  3. Consultation outcome — proposed changes to MCS requirements for financial protection, MCS
  4. Sole traders/small firms and the MCS, ElectriciansForums (July 2021)
  5. Only Panels — Solar Installer Chats, Apple Podcasts

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