Registration is an opportunity for organisations to better understand their heat networks and get on the front foot.
Blog by Chloe Jenner, Compliance Team at FairHeat
Today (19th of October) marks 100 days until the deadline for all heat networks to register with Ofgem to comply with new regulations.
Any heat networks not registered by the end of 26th January 2027 will be in breach of the new regulations and may face enforcement action and financial penalties from Ofgem. Right now, I suspect that the number of heat networks which have registered with Ofgem so far is low.
Challenges
Change is intimidating for anyone in any industry, that and the fact that many heat networks may not have yet established answers to all Ofgem’s registration questions is causing some operators & suppliers to feel nervous. Ofgem’s questions include:
- How many vulnerable customers does your heat network supply heat, cooling or hot water too?
- Do you have a priority services register?
- Do you provide information on how customer bills are calculated?
- Are customers provided year-on-year consumption data on their bill?
- Are customers provided contact numbers for organisations which can provide energy efficiency advice on their bill?
The lack of immediately available information at the outset to these questions may be putting organisations off from registering. However, these are all valid and important questions which a supplier of energy should be able to answer.
From experience I know that the challenge many heat network suppliers and operators have stems from the fact that the sector has been unregulated for so long. This means that many heat networks have incomplete information on the performance and condition of their heat network, on their customers and their customer processes.
Getting started
To answer some of these questions, I would recommend a site visit and/or a customer survey, in part, to establish whether any customers still have vulnerabilities or whether any new health conditions have been diagnosed which haven’t previously been declared. This is vital, especially considering the English Housing Survey which states: Around three in five households (61%) in the social rented sector had one or more household members with a long-term illness or disability.
Data on social housing lettings in England tells us that almost half (46%) of households (97,000) with a new letting in 2024/25 included at least one person who had a physical or mental health condition or illness lasting or expected to last for 12 months or more. These residents are likely to need to be included on your priority services register, so it is important to understand who they are and keep the register up to date. We recommend reviewing and updating this information at least once a year.
As well as understanding who may be vulnerable on your network for consumer protection purposes, it’s important to know how many residents are living with a health condition in light of the second phase of Awaab’s Law.
The new Awaab’s Law Phase two regulations will apply from the 30th November. The phase two guidance for landlords’ states: “To enable landlords to categorise and triage hazards they should take reasonable steps to understand the circumstances of the tenant, including any vulnerabilities of the household which could worsen the potential impact of the hazard such as age, health conditions or disability.”
It’s also important to review the policies and processes you already have in place, including areas such as tariff calculation, billing, complaints handling and customer communications, and to understand the services you are offering to vulnerable consumers. If you’re unsure where to start or need support with any aspect of compliance, FairHeat can help you assess your current position, identify any gaps and put a practical plan in place to achieve compliance.
How we are supporting our clients
My team and I, at FairHeat, are helping landlords and managing agents register a varying number of heat networks with Ofgem, from large portfolios which include hundreds of heat networks to those with a handful.
When we are helping clients to fill out the questions, and where there are gaps, put a plan in place to fill them.
I have heard some landlords express hesitancy about submitting information if they know they are in the process of transitioning to a new heat tariff and billing system or if they will need to change how they currently approach this area to improve service delivery. For example, where customers being provided with bills once a year but not being provided with information on their consumption data as there is no metering in place to do so and there is currently no year-on-year comparisons or information on energy efficiency advice.
It is more important to be honest about where you’re at and showing that you’re making a real effort to get where you need to be. It’s much better to acknowledge the gaps, be upfront about them, and show that you’ve got a plan in place to address them and keep moving forward, but you will need to have many of the requirements in place by the January deadline.
Conclusion
Heat network registration may feel challenging, particularly while landlords are managing wider regulatory pressures, limited capacity and gaps in existing information. However, registering accurately and transparently creates a valuable baseline for both landlords and Ofgem. Used as a gap analysis, it can help organisations understand their networks, customers and processes, prepare for future requirements including the now draft Heat Network Technical Assurance Scheme (HNTAS), identify investment needs and strengthen the case for further HNES funding.
Registration is therefore more than a compliance exercise: it is an opportunity to get on the front foot and build a clearer, stronger plan for improving heat network performance.
With just 100 days to go now is the time for heat network owners, operators and supplier to seek expert advice to accelerate their work on heat network registration. Get in touch with me to start your journey toward compliance chloe.jenner@fairheat.com
