Running on Empty: Why Scotland’s Heating Oil Consumers Deserve Better Protection
I’ve a song running through my head and I can’t quite shake it but that’s a small problem indeed as winter approaches, hundreds of thousands of people across Scotland are once again facing uncertainty about the cost of keeping warm. For around 140,000 households in Scotland that rely on heating oil or LPG as their primary source of heating, that uncertainty is often greater than for households connected to the gas grid.
Heating oil is not a luxury. It is an essential fuel that provides warmth, hot water and comfort for families, older people and those with health conditions across much of rural and remote Scotland. Yes there are people in more central and urban locations similarly affected but the depth of this crisis is amplified by more rural location. Despite its importance, heating oil remains outside the consumer protection framework that applies to gas and electricity.
For many years, Energy Action Scotland and others have argued that this needs to change.
The Reality of Living with Heating Oil
The experience of an oil-heated household is fundamentally different from that of a household connected to mains gas.
When your gas or electricity meter is running low, you can continue to access energy through a range of regulated protections, payment arrangements and support mechanisms. When your heating oil tank runs dry, the situation is much more stark.
An empty oil tank means no heating and no hot water.
Unlike other fuels, consumers cannot simply buy a small amount to get them through a difficult week. Suppliers require a minimum order, typically around 500 litres. Today, that can cost more than £700 in a single transaction, creating a significant barrier for households already struggling with the cost of living.
For many consumers, particularly those on fixed incomes, pensioners, disabled people and families already facing financial pressure, finding hundreds of pounds extra at short notice is simply not realistic.
A Market with Limited Choice
Scotland has about 25 heating oil suppliers, with perhaps seven major operators accounting for much of the market.
While this may appear competitive on paper, the reality in many rural and island communities is very different. Households may only have one or two suppliers from whom they can realistically purchase fuel. And many are loyal to companies they have built relationships with over many decades. I know this from personal experience where my parents have been buying heating oil from the same family owned business for over 50years.
Distance, geography and delivery logistics all affect consumer choice. In some areas, consumers cannot easily shop around or switch supplier in the way that gas and electricity customers can.
Delivery times can also present challenges. Standard deliveries may take days or even over a week during busy periods. Consumers who need fuel urgently often face additional charges for priority delivery.
The combination of limited choice, lengthy delivery times and high upfront costs leaves many rural consumers exposed.
A Lack of Transparency
Another challenge is the lack of transparency within the heating oil market.
Consumers purchase heating oil by the litre, but the final price incorporates a range of different elements including wholesale fuel costs, transport costs, delivery charges and supplier margins.
Unlike energy bills in the regulated gas and electricity market, there is no clear requirement for suppliers to explain these costs or demonstrate how prices are being determined.
Prices can also be volatile. Consumers may obtain a quotation for fuel only to find that the price charged on delivery differs from the price originally quoted. Imagine that your online shopping order arrives only to find that you can have it but only if you pay more that day, if you’ve the money then you might but what if your budget is already at bursting point?…
The Competition and Markets Authority concluded that there was no evidence of widespread profiteering in the sector. However, consumers should not have to rely on exceptional events, such as a global energy crisis or war, to trigger scrutiny of market practices.
Good regulation should provide ongoing transparency, confidence and accountability long before a crisis occurs.
Fuel Poverty is a huge rural issue
Fuel poverty remains one of Scotland’s most significant social challenges. Something that isn’t getting any better despite legislation, strategies and plans.
Around one in three Scottish households are estimated to be living in fuel poverty, with rates much higher in rural and island communities.
Those communities are also disproportionately reliant on heating oil and LPG.
While gas and electricity prices have risen significantly since February 2026 when the war in the middle east began, heating oil households have often experienced some of the most dramatic increases in energy costs. Many have seen the cost of filling a tank almost double compared to historic norms.
This creates a particular challenge because fuel poverty is not simply about income.
Scotland’s definition of fuel poverty rightly recognises a range of factors including household income, energy prices, housing efficiency and the energy required to maintain a healthy indoor temperature.
For many disabled people, older people and those with long-term health conditions, energy requirements are higher than average. They may need to keep their homes warmer for longer periods, increasing their exposure to fuel costs regardless of whether or not they receive means-tested benefits.
The Case for Regulation
The UK Government has announced its intention to introduce regulation of the heating oil market in future.
That is welcome.
However, it offers little comfort to households facing another winter of high prices and uncertainty. The timetable for implementation remains unclear, and consumers need protections now, not at some undefined point in the future.
A future regulatory framework should focus on several key areas.
Consumer Protection
Households that rely on heating oil should enjoy protections equivalent to those available in gas and electricity markets.
That includes clear standards of service, transparent pricing and defined responsibilities towards vulnerable consumers.
Priority Services for Vulnerable Customers
The energy and water utilities have long recognised the need for Priority Services Registers, for those with medical vulnerabilities, disabilities, are elderly or have very young children, and have been required to have them.
Heating oil suppliers should be required to identify and support vulnerable consumers, including older people, disabled people and those with serious health conditions.
Minimum service obligations during severe weather and supply disruptions should form part of that approach.
This should move from market leading voluntary practice to legislative requirement.
Fair and Responsible Credit
Many heating oil suppliers already offer forms of credit and payment support. Their efforts should be recognised.
The problem is consistency.
Support currently depends on the policies of individual suppliers rather than a common standard. Consumers should have access to fair, transparent and responsible credit arrangements regardless of where they live or who their supplier is at any given time.
Independent Redress
Consumers deserve access to an independent resolution process when things go wrong.
Gas and electricity consumers can access formal complaints procedures and Ombudsman services. Heating oil customers should have equivalent routes to redress.
Greater Transparency
Regulation should improve confidence in the market by increasing transparency around pricing structures, delivery practices and customer standards.
Consumers should be able to understand what they are paying for and have confidence that charges are fair and reasonable.
Looking Ahead to the Energy Transition
The argument for regulation becomes even stronger when we consider the long-term future of home heating.
Public policy is increasingly focused on helping households move away from fossil fuel heating towards low-carbon alternatives such as heat pumps.
That transition will take time.
Many rural households face significant practical and financial barriers to changing their heating systems. For some, heat pumps may not yet be affordable or technically suitable. Others may need costly fabric improvements before a transition becomes viable. The age of equipment is a significant factor in decision making, a recent investment in a oil combination boiler and a oil storage tank comes at considerable cost, much higher than a gas equivalent. If you’ve invested almost £7000 to replace an oil heating system how ready are you to change. Ideally change comes when equipment needs replaced but there is little known about the condition of equipment in the homes of those with heating oil.
As more households leave the heating oil market, the customer base for suppliers is likely to shrink.
- What does that mean for the households that remain?
- Will delivery costs rise?
- Will available suppliers reduce?
- Will delivery times become longer?
- Will the remaining consumers face even higher costs?
These questions matter because many households will not be choosing to remain on heating oil. They may simply be the households for whom alternatives remain least accessible or whose circumstances prevent early action.
No-one should be left stranded in a declining market without adequate protections.
Support Must Reach Those Who Need It Most
Both the Scottish and UK Governments have recognised the pressures facing off-grid households and have introduced targeted support.
That support is welcome.
However, assistance remains largely focused on those receiving means-tested benefits or those able to demonstrate severe financial hardship.
There is a strong case for broadening eligibility.
Households receiving disability-related benefits or social care support often have higher energy needs and face greater heating costs, regardless of whether they receive means-tested assistance.
Support should remain targeted, but the criteria should better reflect Scotland’s understanding of fuel poverty and the realities of living with chronic illness, disability and higher heating requirements.
The objective should not simply be to support those on the lowest incomes. It should be to support those most exposed to the harmful consequences of living in a cold home. Expediency drives support rather than what is right.
Conclusion
Heating oil remains an essential source of heat for around 140,000 Scottish households.
These consumers face high upfront costs, limited market choice, price volatility and fewer protections than households using gas or electricity.
Many suppliers work hard to support their customers, and voluntary initiatives have an important role to play. But voluntary arrangements are no substitute for consistent consumer protection.
Whether the issue is transparency, credit, vulnerability, complaints handling or future energy transition planning, households that depend on heating oil deserve the same level of protection as every other energy consumer.
The question is no longer whether regulation is needed. It is about how many more winters policymakers are prepared to allow to pass with vulnerable households carrying all of the risk and far too many paying the ultimate price through health and wellbeing declines.
There is rightly so much discussion about the future of home heating and the move towards low-carbon alternatives. But while policymakers focus on the destination, we cannot forget those still making the journey. To borrow from Jackson Browne, too many households are already Running on Empty.
Frazer Scott
CEO, Energy Action Scotland