Our response to DEFRA consultation on proposed reforms to the WaterSure support scheme
WaterSure is a support scheme that caps bills for low-income households on means-tested benefits who need to use high levels of water because they have either a qualifying medical condition or three or more children in the household.
In December 2024, CCW submitted recommendations to UK and Welsh Government for improvements to the WaterSure scheme. The Department for Environment, Food and Rural Affairs (DEFRA) subsequently issued a consultation on proposed changes to WaterSure in July 2025.
Our consultation response
Section 2.1: Extend the list of qualifying benefits to include non-means tested disability benefits for those claiming through a qualifying medical condition
Strongly agree
Additional information:
We strongly support this proposal, which was one of our key recommendations to government from our review of the WaterSure scheme.
Strongly disagree
Additional information:
In recommending that the qualifying benefits for WaterSure be expanded to include disability benefits we concluded that an upper income threshold should apply. This was on the basis of ensuring that support from the scheme goes to households who are in need of the financial support, and to help avoid the risk of cross subsidies flowing from lower-income households to significantly higher income households. However: the threshold should be set at a level which would exempt only more exceptional applications where it is clear there is no risk of financial vulnerability.
We do not agree to a threshold which might see companies have to deny support to a higher proportion of lower income applicants.
During our review some companies raised concerns that setting an upper income threshold at a low level could lead to significant additional administrative scrutiny being required in a significant number of cases in order to validate entitlement.
Higher income households are less likely to apply for support and would be easier to rule out in avalidation process. However a lower income threshold would see companies having to undertake more significant validation checks to identify on which side of the income line an applicant falls, particularly given many lower income households can have quite variable income patterns from month to
month.
In considering the appropriate level of the threshold we would encourage government to take account of SCOPE’s latest estimate of the additional costs faced by disabled households (Disability Price Tag 2025 | Disability charity Scope UK) . They have calculated that, on average, disabled households need an additional £1,095 a month to have the same standard of living as non-disabled households.
For these reasons we believe the government should set the income threshold closer to median income level, and potentially at or above the median level if disability benefits are included in the calculation of income.
Four water companies have already successfully expanded their schemes to include disability benefits in their qualifying criteria. Three of those companies do not have an upper income threshold in place.
The fourth has an income threshold of £22,500 after housing costs and excluding disability benefits. None of the companies have been overwhelmed by applications from this group. This indicates that it is possible to successfully extend the scheme to include non-means tested benefits without having to apply a low-level upper income threshold.
Disagree
Additional information:
On balance we favour an approach which disregards disability benefits in the calculation of income. We believe this would help ensure that disabled consumers on lower incomes are not at risk missing out on support due to their disability benefits being higher to recognise their higher living costs.
Section 2.2: Update the WaterSure bill cap to be the amount of the average metered bill or the average bill, whichever is lower
Strongly agree
Additional information:
We strongly support this proposal, which was one of our key recommendations to government from our Review of the WaterSure scheme
Section 2.3: Cap bills for single occupiers to the average bill for a single occupier
Strongly agree
Additional information:
We strongly support this proposal, which was one of our key recommendations to government from our Review of the WaterSure scheme.
Section 2.4: Remove the option for water companies to require a medical practitioner’s note in respect of health conditions not specifically listed in the WaterSure Regulations
Strongly agree
Additional information:
We strongly support this proposal, which was one of our key recommendations to government from our Review of the WaterSure scheme.
Section 2.5: Specifically listing more potentially qualifying medical conditions
Strongly agree
Additional information:
We strongly support this proposal, which was one of our key recommendations to government from our Review of the WaterSure scheme.
Section 2.6: Data-sharing
The main challenge which water companies have highlighted to us is the requirement on them to seek data only in relation to those consumers they already anticipate are financially vulnerable. This potentially excludes some households from benefitting from support where they are not already on the companies’ radar as being likely to need help based on where they live or other available sources of intelligence. This barrier to offering support needs to be unblocked.
Government could undertake a public information campaign to raise awareness of WaterSure and other support which is available with water bills (such as social tariffs) and services (such as the priority services register). Alternatively CCW could be additionally resourced to undertake paid media or press promotional activities, supplementing the work we already do to raise awareness of support through our media and press communications.
A further option would be for DWP to provide benefit recipient with information about the financial support options available to help them with water bills. A similar initiative with the NHS might target raising awareness of WaterSure amongst patients with medical conditions which require significant additional water use.
We would welcome the opportunity to work with government departments to help develop and support such initiatives.