Are you caught by the new
heat network regulations?

Ofgem opened its registration portal for heat network operators and suppliers in spring 2026. Every organisation caught by the regime must register — it's the primary gateway to authorisation. You'll need basic details about the network, its size, and your role. Registration is free. If you haven't done this yet it should be your first action.

Ofgem requires you to have a written policy committing to five core consumer principles: being honest and transparent, treating consumers fairly, providing accurate information, maintaining competency, and handling consumer data responsibly. You also need to document who in your organisation is responsible for heat network compliance. For most asset managers this means a short policy document and a named contact — it doesn't need to be complex.

Each separately occupied unit — flat, office, retail unit — must have its own heat meter measuring actual consumption. A single meter for the whole building with costs divided by floor area is no longer compliant. Heat Cost Allocators (HCAs), which were sometimes used as an alternative, are not accepted under the new regime in Great Britain. Meters must be MID-certified (EU Measuring Instruments Directive standard) and accessible for reading.

Bills must show actual consumption from meter readings as the default — not estimates or apportionments. They must also include a specific set of information: the tariff breakdown, unit rate, standing charge, the period covered, meter reading used, comparison to prior period, and contact details for queries. Estimated billing is only permitted in limited defined circumstances, such as when a meter is inaccessible for reading.

You must have a written complaints procedure that acknowledges complaints within a set timeframe, works to resolve them, and — if unresolved after eight weeks — tells the consumer they can escalate to the Energy Ombudsman. The procedure must be easy to find and written in plain English. The Energy Ombudsman publishes a model procedure you can adapt. Tick this if your procedure is documented, live, and includes the Ombudsman escalation step.

The Energy Ombudsman is the independent body that handles escalated complaints from heat network consumers. Registration is mandatory for all authorised persons — it's separate from having a complaints procedure in place. You need to have actively signed up with the Ombudsman scheme itself. There is an annual fee based on network size. Visit energyombudsman.org to register.

You must have a written policy explaining how you identify consumers who may be vulnerable — due to age, disability, illness, or financial difficulty — and what additional support you provide them. You also need to maintain a Priority Services Register (PSR): a list of vulnerable consumers who have opted in to receive extra support such as advance notice of outages or large-print bills. For social housing operators this overlaps with existing housing management obligations but must be specifically applied to the heat network context.

Because heat network consumers cannot switch supplier, Ofgem requires you to demonstrate that your tariffs are genuinely cost-reflective — meaning they cover your actual costs of generation, distribution, and administration, but are not excessive or profit-inflated beyond what a competitive market would produce. You need a written policy setting out your pricing methodology. Accurate consumption data from metering is essential to underpin this — you can't demonstrate cost-reflective billing without reliable metering records.

For planned outages (maintenance, upgrades) you must notify consumers in advance — the required notice period depends on the duration of the interruption. For unplanned outages (equipment failure, emergency) you must have a documented process for rapid response, consumer notification, and restoration timescales. Both procedures must be written down and actually followed. Remote monitoring tools that alert you to supply events in real time significantly help with the unplanned interruption obligation.

Every consumer must have a written contract specifically for their heat supply — not just a general tenancy agreement or lease. The contract must be in plain English, provided as a single document (not incorporating terms by reference to a website), and must contain prescribed content including tariff details, notice periods, dispute resolution, and your contact details. Many existing arrangements — particularly in BTR and social housing — rely on lease clauses or service charge schedules that do not meet this standard and will need to be replaced or supplemented.

A deemed contract automatically applies when a consumer starts receiving heat but has not signed a formal agreement — for example, a new tenant who moves in before paperwork is completed, or an existing tenant whose legacy arrangement doesn't meet the new contract standards. You must have a published set of deemed contract terms that apply in these situations. Charges under a deemed contract cannot exceed your standard variable tariff. This is a new concept for most heat network operators and one of the most commonly missed obligations.

Back-billing means sending a consumer a bill for energy used more than 12 months ago. This is prohibited except in specific circumstances — for example, where the consumer has deliberately prevented meter access. The 12-month limit is a hard rule. It's most commonly triggered where metering has been absent or unreliable and bills have been estimated, then corrected retrospectively. Accurate ongoing metering is the practical way to ensure this never becomes an issue.

Heat cannot be disconnected in certain circumstances — for example, during cold weather periods, or where the consumer is known to be vulnerable. Before disconnection can occur, you must offer a payment plan, give prescribed notice, and follow a defined process. You must have all of this documented. For social housing operators the rules are particularly strict given the mix of vulnerable consumers likely to be on the network.

Before increasing a tariff you must notify consumers in writing, in advance, with sufficient notice to allow them to raise any concerns. The notice must be a standalone communication — not buried in a newsletter or service charge pack — and must explain what is changing, why, when it takes effect, and what the consumer can do if they have concerns. It must also tell them about their right to complain. Tick this if you have a formal process for issuing these notices before every price change.

Ofgem requires network operators to prepare a financial resilience plan that demonstrates how heat supply would continue to consumers in the event of the operator's business failure — insolvency, administration, or similar. The plan must cover who would take over operation, how assets would be transferred, and how consumers would be protected. This is a new and often overlooked obligation for property companies and housing associations who have never previously had to think about their heat network in this way.

The physical infrastructure that delivers heat to consumers — pipework, heat exchangers, distribution equipment — must be legally structured so that it cannot simply be seized by creditors in the event of the operator becoming insolvent. This typically requires a review of how those assets are held and whether they need to be separated from the general asset pool of the business. This is primarily a legal structuring question and you should take advice from a solicitor familiar with the Ofgem guidance on this condition.