The Skidmore Review and the 25 by 2025 Framework

30 January 2023

One of the actions of the Truss Government was to commission a net zero review by the Rt Hon Chris Skidmore MP, a former interim climate minister (the Review). The terms of reference encouraged the Review to find the swiftest and most efficient ways to reach the government’s target of net zero by 2050.

The Review delivered its 340-page report Mission Zero on 13 January. Overall, the Review has made a compelling argument to reframe this as both an economic challenge and an economic opportunity, calling the energy transition a “new economic reality” and net zero “the growth opportunity of the 21st century”. In contrast to previous reports authored by government (rather than for government, as is the case here), the Review sets out how the net zero target can be delivered through practical, targeted actions, rather than discussing the target at a high level.

The Review makes 130 recommendations and confirms the High Court decision of July 2022 that the UK government is not on track to meet its own target of net zero by 2050, and risks falling behind further if action isn’t taken swiftly. In particular, the Review sets out the “25 by 2025 framework” – 25 policies that it considers could be realistically delivered by 2025.

The Review focuses on structural elements such as the planning system and government regulation rather than changes to be made by individuals. The key headlines in relation to the built environment are as follows:

1. Planning reform – a rooftop revolution

According to the Review, current ambitions to reach a fully decarbonised power sector by 2035 are “at risk due to the time required for developers to go through securing planning permissions, environmental permitting and grid access”. The Review suggests reforming the planning system at a local and national level to ensure it properly supports net zero. “One of the starkest messages form hundreds of organisations and individuals is that the planning system is undermining net zero and the economic opportunities that come with it”, the Review states, and it is key to ensure wide-ranging planning reform ensures the system is aligned with the net zero future. In particular, the intention with a reformed system should be to introduce a net zero test, and a rapid review of the bottlenecks for net zero and energy efficiency projects in the planning system should be undertaken.

The Review also states that there should be no planning permission required to install domestic or commercial solar panels on rooftops, with this particular policy recommendation described as a rooftop revolution.

2. Cleaner, greener homes

In recognition of the need for a shift to implementation, the Review calls for a number of policies that are already in the pipeline to be brought forward. The Review recommends providing certainty by 2024 on the new and replacement gas boiler phase out date to drive industry and investor confidence, and also recommends bringing the date for the ban on gas boilers forward from 2035 to 2033. The Review also suggests bringing forward all consultations and work to mandate the Future Homes Standard by 2025; currently, this will mandate greater energy efficiency measures in homes built after 2025, but new homes built before then will not need to meet these standards. This is despite the fact that retrofitting a new home to meet high energy efficiency standards could cost a household an average of £26,000, according to Climate Change Committee data, which is over five times more than it would have cost to meet the standard when a property was first built. The delay to 2025 to enforce the Future Homes Standard will create “a missed opportunity in making new builds more efficient and require costly retrofits”. It is suggested that this should include a consultation on mandating new homes to be built with solar and deliver the Net Zero Homes Standard, ensuring the planning system is flexible enough to enable this.

3. A new circular economy taskforce

The circular economy is a model of production and consumption, which involves sharing, leasing, reusing, repairing, refurbishing and recycling existing materials and products for as long as possible.1 A new report assessing the environmental benefits of a circular economy recently revealed that only 7.2% of the 100 billion tonnes of virgin natural materials used each year make it back into the economy after their first use.2 The Review suggests that a task force should be launched to work alongside industry to identify barriers and enablers and develop sector-specific circular economy business models for priority sectors.

4. An infrastructure strategy by 2025

The Review states that infrastructure is the key that will unlock net zero and commented that it heard from “hundreds of innovative companies eager to bring new technologies to market but being hampered by slow, ponderous bureaucracy and an antiquated approach to grid connections not suitable for a modern 21st century electrified economy”. It is the recommendation of the Review that a cross-sectoral strategy is put in place by 2025, to allow the infrastructure for hydrogen, electricity, other liquid and gaseous fuels and CO2 networks to support the green economy. The Review insists this must be a structural piece, given that the scale and breadth of this challenge is “too much to be left to the whims of individual projects”. The Review comments that net zero drives UK energy security, which is essential to a growing economy, and this has evidently struck a chord with industry, as SSE’s chief executive spoke to the Financial Times on 17 January arguing that there were too many blockages holding up the UK’s progress, saying “we just need to see more urgency behind efforts to clear the barriers, greenlight projects and get clean infrastructure built”.3

5. EPC ratings

The Review acknowledges that the UK’s housing stock is the oldest and least energy efficient in Europe, with over half of homes in England built before 1965 and almost 20% built before 19194; the age of a property is the single biggest factor affecting its energy efficiency.5

We explored the likely policy changes to EPC regulations in a recent article. The policy to make buildings unlettable unless higher EPC ratings are satisfied closed two years ago, however, and as our recent article stated, the UK government has yet to respond with its findings. The Review recommends that all non-domestic buildings should be EPC B by 2030 and all new non-domestic buildings to be EPC B by 2025. The Review stresses the importance of including both domestic and non-domestic buildings, stating that “the broader energy efficiency mission is not a complete package unless non-domestic buildings are considered”. The Review also suggests wholesale reform of EPC ratings, to create a more accessible Net Zero Performance Certificate for Households (NZPC), alongside mandating landlords to include an average bill cost alongside the EPC/NZPC rating when letting out a property.

6. Broader approach to nature-based solutions (NBS)

Our exploration of the opportunities, challenges and risks posed by NBS (Nature-based solutions for the real assets sector - Macfarlanes) echoes contributors to the Review, who stated that he inclusion of NBS in the government’s net zero plans could be broader than the current intended environments, including woodland creation and peatland restoration. A more ambitious programme of implementation is required if NBS are to play a significant role in delivering net zero by 2050

7. A trailblazer city

The Review recommends that the government fully back at least one trailblazer net zero city, local authority and community, with the aim for these places to reach net zero by 2030. The Review comments that local action is key to delivering net zero in the cheapest and most effective way possible. “Net zero devolution has been a success to date, and… it has enabled nations and regions to deliver more effectively”. The Review cites a case study relating to the Greater Manchester Combined Authority (GMCA), which in 2019 launched its five-year environment plan, setting a target for the area to be carbon neutral by 2038. The annual Green Summit seeks input from all stakeholders as to how the GMCA should accelerate action against its five-year plan. The devolution of powers in relation to transport has allowed Greater Manchester Mayor Andy Burnham to announce plans to deliver a fully integrated public transport system across buses, trams, trains and bikes, with fixed fares and weekly caps introduced, along with the delivery of new electric powered buses to provide the UK’s first zero carbon public transport system. These changes will support bus users with the cost-of-living, grow the use of public transport and support the shift to more sustainable transport.6

Next steps

The Review has received widespread industry support; for example, the UK Green Building Council has welcomed the recommendations in the Review but stated that “many of our members would even support going further in several areas, including legislating for net zero alignment through the Levelling Up and Regeneration Bill, requiring solar power on new homes, and an end date for new fossil fuel boilers in homes by 2028.”7

The message from the Review is clear – that “forty-two months on from the UK signing net zero into law, we are now in a net zero race. To stand still, delay or maintain the status quo is not an option”. A formal government response is expected, and given the 1800 responses, 52 roundtables and 150 hours of oral evidence given to the Review, any rebuttal would need to be substantiated. Many of the suggested actions could be implemented in the Budget, scheduled for 15 March (less than 8 weeks away), or by way of update to the Net-Zero Strategy (which the government must do by the end of March by order of the High Court).8 Time will tell whether the Mission Zero approach will be the one taken, but as the Skidmore Review comments in its conclusion, there is no time to waste.

1 Circular economy: definition, importance and benefits | News | European Parliament (

2 CGR 2023 (

3 SSE warns Britain ‘not moving fast enough’ on green economy | Financial Times (

4 UK must insulate homes or face a worse energy crisis in 2023, say experts | Energy bills | The Guardian

5 Homes built after 2012 are almost 200 times more likely to have a band A to C energy efficiency rating in England than properties built before 1982.

6 Destination: Bee Network | Transport for Greater Manchester (

7 UKGBC welcomes the Skidmore Review and urges decisive Government action - UKGBC - UK Green Building Council

8 Friends of the Earth -v- BEIS [2022] EWHC 1841 (Admin)