The blizzard of heat network consultations has now arrived as we count down to full regulation go-live in January 2026 – even Ofgem admits it’s an aggressive schedule but there is a lot to cover in what was previously largely unregulated sector. After 27 January 2026, regulatory conditions will apply on a whole range of areas and if these are not met then the housing provider will be non-compliant.

So where are we? *

• 1 April 2025: all heat networks deemed authorised, and the Energy Ombudsman and Citizens Advice/Consumer Scotland took up their consumer advocacy and redress roles. Citizens Advice launched their helpline, and are commissioning research and collating data to understand consumer detriment in the heat network world. Heat network operators and suppliers should also be registering with the Energy Ombudsman: complaints can be escalated if they’re not resolved within 8 weeks.

• 30 April 2025: Ofgem published the Fair Pricing Consultation. The most substantial consultation of the summer, the consultation laid out Ofgem’s approach to ensuring prices are ‘fair and not disproportionate’. As well as how prices might be benchmarked, the consultation introduced the six principles of fair pricing which all heat network suppliers will have to demonstrate. The consultation also expands on Ofgem’s thinking about unbundling heat costs from services charges and rent: this will be developed further through 2026.
  • Cost-reflective pricing: that heat prices reflect their component parts
  • Cost efficiency: that value for money is provided to consumers at the same time as an appropriate quality of service
  • Fair and reasonable returns: that heat networks can make a profit but their monopoly status should not be used to earn excess returns
  • Affordability: that heat network suppliers should strive for consumer benefit in their pricing decisions
  • Regulatory control: that oversight and control remains with the heat network supplier even when management is outsourced
  • Price transparency: that prices are communicated to customers in a way that is accessible and easy to understand

• 30 July 2025: draft Heat Network Technical Assurance Scheme (HTNAS) standards published. Although we’re still waiting for the full consultation, the Government did publish some draft technical specifications and processes for newbuild heat networks in July 2025.  It should be noted that these are not open for comment or feedback.

• September 2025: Ofgem consultations on consumer protection and fair pricing guidance. This guidance will become the ‘playbook and manual’ for implementing the heat network regulations and what needs to be done for your organisation to be compliant.  We understand that Ofgem is not expecting any material changes in them before January 2026 and is encouraging heat network operators and suppliers to use them now to support their preparation.

There’s also been important confirmation of the regulatory position. From 27 January 2026 all the Authorisation Conditions will go live. This means they become legally binding and failure to meet them means housing providers will be non-compliant from day one.

What to do next

Your next step is to fully register with Ofgem: you have until January 2027 to do this, but your regulatory reporting must be backdated to April 2026 so start getting your data in place as soon as you can.

It is also important to register with the Energy Ombudsman. Although most of those voting on our LinkedIn poll on the subject (57%) said they had already registered, Energy Ombudsman figures state only around 2,000 (14%) of the roughly 14,000 heat networks in the UK have currently signed up.

An Energy Ombudsman spokesperson said:

“Registering with our service is free and can be completed online via our website. It’s essential that each heat network provides us with contact details and information about their site or sites, as this will ensure they are notified as soon as a consumer raises a dispute and will provide them with maximum opportunity to respond and provide evidence before our decision is made.”

 

The spokesperson went on to note heat networks choosing to register with the service ahead of the proposed upcoming regulation changes are making a visible consumer-first commitment to improving their service.

The year ahead

Ofgem’s focus for 2026 will be on registration but they’re not ruling out enforcement: the number of formal complaints being escalated to the Energy Ombudsman are already ramping up. The key to all this is having a compliance plan place. Understand your heat network portfolio, plan your roadmap to compliance – then make it happen.

Find out more about how Chirpy Heat can help you on your compliance journey. Get in touch at [email protected].

*And this isn’t even the full list. For completeness we also want to share the following which were all also published in August 2025:

• Ofgem consultations on the nuts and bolts of regulation delivery:
  • Mitigating the risk and impact of financial failure
  • Enforcement guidance and penalty policy
  • Registration and notification of changes
  • Authorisation conditions
• And some responses:
  • Government’s response to the Consumer Protection Consultation
  • Ofgem’s response to the registration and notification of changes consultation
  • Ofgem’s response to the mitigating risk and impact of financial failure consultation