Plug-in solar and your home insurance
The specification makes checking your cover your responsibility, and then nobody tells you what the answer is. Here is what is actually established, what is not, and the questions to put to your insurer in writing.
Nobody has told you, and the documents are careful not to. The specification makes it your job to check — including cover on the building, not just your own policy — and then stops.
Your legal position is narrower than the scare stories suggest: since 2012, a consumer’s duty is to “take reasonable care not to make a misrepresentation to the insurer”, not to volunteer everything. But that is a floor, not an answer. Whether your policy requires notification is a question about your policy, and the only reliable answer comes from your insurer in writing.
What the specification actually requires
Version 2 of the Interim Product Specification puts the duty on you, and requires the manufacturer to tell you so in the product information:
Users are responsible for checking, before installation, whether the product may affect any relevant insurance arrangements, including their own insurance and, where applicable, insurance covering the property or building
Two things are worth pulling out of that sentence.
It says before installation. The check is framed as a pre-purchase step, not something to sort out afterwards.
And it says the property or building, separately from “their own insurance”. That is the flats-and-balconies case: the policy covering the structure is typically the freeholder’s or the managing agent’s, arranged under the terms of the lease. Attaching a device to a wall or balcony can engage a policy you are not the customer of and cannot amend.
What your legal duty actually is
This is where most coverage goes wrong in the other direction, implying you have an open-ended obligation to disclose anything that might matter.
For consumer insurance, the Consumer Insurance (Disclosure and Representations) Act 2012 replaced the old duty to volunteer material facts. Section 2 sets the duty as:
It is the duty of the consumer to take reasonable care not to make a misrepresentation to the insurer
and provides that this duty “replaces any duty relating to disclosure or representations by a consumer to an insurer which existed in the same circumstances before this Act applied”.
So the shape of it is: answer the questions you are asked, accurately and with reasonable care, when taking out the policy or varying it. Failing to respond to an insurer’s request to confirm or amend information you have already given can itself amount to a misrepresentation.
What that section does not do is tell you whether a mid-term change to your home needs reporting. That comes from your policy’s own terms — most home policies contain a condition about notifying material changes — and those terms vary between insurers.
What the government did and did not do
The government engaged insurers directly during the consultation. The response records “a meeting with insurance providers” and “further meetings with the building industry, the fire service, insurance companies and housing industry representatives”, and lists insurers among the stakeholders whose views were gathered.
Respondents raised it too. Tenants, the response notes, may be deterred by opposition from landlords and freeholders and by “insurance uncertainty”. In its closing summary the government acknowledges that respondents “highlighted issues relating to battery storage, landlord and leaseholder consent, planning, building safety, insurance, market surveillance and longer-term standards development”.
And then nothing. The response commits to regulatory amendments, consumer guidance, G98 arrangements and enforcement engagement. On insurance specifically, we could not find any commitment, resolution or forthcoming guidance in the document.
That absence is the honest headline of this page. Insurance was raised, insurers were in the room, and the framework shipped without an answer.
What to ask your insurer
Since the answer has to come from them, ask precisely, and keep the reply.
- Do you need to be notified that a plug-in solar device compliant with the Plug-in Solar Device Interim Product Specification has been connected to a standard socket at the property? Use that phrasing — it distinguishes the device from a wired-in rooftop system, which is what “solar panels” will otherwise be taken to mean.
- Does it affect the buildings cover, the contents cover, or neither?
- Is the device itself covered as contents, and is it covered while mounted outside — on a balcony, wall or garden? Outdoor items are commonly limited or excluded.
- Does the answer change if it is fixed to the structure rather than free-standing or ballasted?
- Does anything turn on the G98 notification to the network operator having been made?
Ask by email or through a channel that produces a written record, and keep it with your policy documents. If you are a leaseholder or tenant, you will likely need the freeholder’s or landlord’s position as well — the government’s own guidance intention is that renters and leaseholders “should obtain any permissions that may be required before installing a device”.
What we could not confirm
Any published insurer or ABI position on plug-in solar. Searched and not found. If you have one — a policy document, an underwriter’s statement, a written reply from your own insurer — please tell us. This is a page we would very much like to be able to make more definite, and a single sourced insurer statement would improve it substantially.
Whether the forthcoming consumer guidance will cover insurance. The government committed to guidance on compliance, installation, circuit identification, G98, mounting and when to seek professional advice. Insurance is not in that list.
Sources
- Plug-in Solar Device Interim Product Specification, version 2
- Plug-in solar: Regulatory amendment and interim product specification — Government Response
- Consumer Insurance (Disclosure and Representations) Act 2012, section 2
Contains public sector information licensed under the Open Government Licence v3.0.
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