In early 2025, the Financial Ombudsman Service (FOS) ruled in favour of a consumer complaint regarding a mis-sold solar PV and battery system. Despite EPVS compliant documentation, the case revealed key learnings around usage estimates, system performance, and battery configuration – reinforcing EPVS’s commitment to continual improvement.
This case study illustrates how a more thorough pre-contract validation process, focusing on realistic energy consumption estimates, could have helped a finance lender avoid a costly Financial Ombudsman Service (FOS) ruling.
Background & Complaint
A finance lender funded a solar PV and battery system for Mr. B, who purchased the system with the expectation that it would pay for itself. Mr. B later complained to the FOS, claiming he was misled at the point of sale regarding the system’s benefits.
Though initial complaints were dismissed due to signed documentation and estimated performance metrics, Mr. B’s appeal focused on the mismatch between his estimated and actual energy usage. He used significantly less electricity than the figures used in the savings estimate, resulting in overstated benefits and fuelling his mis-selling claim.
FOS Findings
While the performance estimate was calculated in line with SAP 2012 methodology, and Mr. B had signed to confirm an estimated 6,000 kWh of annual usage, the FOS noted:
- His historic energy usage was closer to 3,600 kWh.
- The battery had not been configured for overnight charging.
- During a post-sale call, he referenced a lower bill that should have raised questions.
Ultimately, the contract was unwound, and the lender was ordered to refund all payments – with costs expected to exceed £25,000.
EPVS Insight
The core issue was the installer’s reliance on an unrealistic energy consumption estimate of 6,000 kWh per annum. While Mr. B signed documentation agreeing to this figure, a more critical analysis would have revealed its discrepancy.
While documentation was in place and correctly validated, several refinements could strengthen consumer protection:
- Mandatory Usage Verification: If an electricity bill isn’t available or shows consumption below the Ofgem average, EPVS now requires a compliance call to verify the reasonableness of the usage estimate.
- Emphasis on Transparent Communication: Updated compliance scripts confirm consumers understand that performance estimates are illustrative and dependent on personal usage patterns.
- Battery Configuration Check: Future validations will ensure that performance assumptions (e.g., overnight charging) align with system capabilities at the point of sale.
This case study underscores the value of EPVS’s independent validation and its agility in evolving safeguards based on real-world outcomes. By responding to FOS decisions with proactive process enhancements, EPVS continues to drive transparency, accuracy, and trust across the renewable energy sector.
Do you have an opinion, or have you had an experience, relating to the above?
Let us know by emailing info@epvs.co.uk
