Heat network compliance: what operators and suppliers must do

Who is regulated

Ofgem regulates two roles. The operator runs the network: the plant, the pipes and the security of supply. The supplier sells heat to the people on it: contracts, bills, complaints and support for consumers in vulnerable situations. One company often does both, and then it carries both sets of conditions. Where they are different companies, each is authorised separately and each must co-operate with the other.

Ofgem authorises a legal entity. A managing agent, billing company or maintenance contractor can do the work, but the responsibility for compliance, and any penalty, stays with the authorised operator or supplier.

Step one: register by 26 January 2027

Registration is condition A4. Every heat network in Great Britain must be registered with Ofgem on or before 26 January 2027. Registration is per network, the operator registers first, and a separate supplier is invited to register once the operator has submitted. The registration deadline guide covers who must register and what registration asks for, and the registration checker tells you in four questions whether your network is in scope. For how registration itself works, see how to register a heat network with Ofgem.

The 29 authorisation conditions

The conditions are the rules you are held to once authorised. There are 29, in three sections. A1 to A3 set out how the conditions apply and what their terms mean, and A15 sets out when Ofgem may revoke an authorisation. The full text of each is on its own page:

Which conditions apply to you

Not every condition applies to every network. It depends on three things:

• Your role. Section A applies to everyone authorised. Section B applies to suppliers. Section C applies to operators.
• Who the network supplies. The supplier standards of conduct (B1) protect every consumer. Most other Section B conditions protect homes and small or micro businesses. The Priority Services Register, payment difficulty and disconnection, prepayment, self-disconnection and social reporting conditions (B8 to B12) protect homes only.
• The kind of network. Sections B and C do not apply to industrial or self-supply networks. A local authority or an Excepted Company does not carry A12 to A14, and A5 only applies where a network has more than one operator.

Pricing and financial responsibility

Charges must be fair and not disproportionate (A6), and structured and attributable to costs (A7), read with Ofgem’s fair pricing and cost allocation guidance. You must also have the resources, including financial resources, to carry on each regulated activity properly and meet your obligations (A13).

Reporting to Ofgem

Compliance is ongoing, not a one-off. Once registered you report to Ofgem in four ways: the registration data itself, kept up to date; regular data returns on a quarterly and annual cycle; notifications when particular events happen; and information you must give to consumers. Ofgem can also ask for information at any time (A9) and require independent audits (A11).

Consumer protection in practice

For suppliers, most of the day-to-day work sits in Section B:

• Clear heat supply contracts, and notice before they change (B2, B3)
• Information, and an enquiry service, that help consumers manage their supply (B5)
• A complaints procedure that meets Ofgem’s timescales (B4)
• Accurate, transparent bills, and limits on back-billing (B6, B7)
• A Priority Services Register for consumers in vulnerable situations (B8)
• Support for consumers in payment difficulty, and strict rules on disconnection and prepayment (B9 to B11)

Operators must make sure consumers are treated fairly (C1), and carry the security of supply (C2): planning for interruptions and restoring heat, with priority for consumers on the register.

The evidence to keep

Ofgem expects you to be open and co-operative (A10) and to be able to show how you meet each condition. In practice that means a documented policy or procedure for each condition that applies, records showing it is followed, a continuity plan with your key service providers (A14), and a fit and proper declaration for everyone with significant managerial responsibility (A8).

A compliance checklist

1. Confirm each network is in scope, and whether you are its operator, supplier or both.
2. Register every network by 26 January 2027.
3. List the conditions that apply to each network.
4. Put a policy, a procedure and an owner against each one, and keep the evidence.
5. Set up a reporting calendar for returns and notifications.
6. Make sure contracts with managing agents and contractors let you meet your obligations, and record them in your continuity plan.

Common questions