The countdown is on for existing heat network operators and suppliers to register with Ofgem by 26 January 2027. Landlords, developers and management companies will need to review existing portfolios with heat networks to determine whether registration is required. With less than 100 days to go, this article examines Ofgem's registration requirements and what you need to do to prepare.
Heat Network Regulation
The Heat Networks (Market Framework) Great Britain Regulations 2025 introduced the regulatory framework for heat networks, covering single building "communal" heating systems and multi-building "district" heating networks.
Any person undertaking the regulated activities of "operation" or "supply" must be authorised by Ofgem and comply with minimum requirements set out in Ofgem's Authorisation Conditions.
For existing heat networks, all operators and suppliers are automatically deemed authorised, although these entities will need to register their heat networks with Ofgem by 26 January 2027. Ofgem authorisation will be required for any new heat networks or regulated activities commencing after the initial registration deadline.
Are you an "operator" or "supplier"?
From 1 April 2025, "operation" and "supply" became regulated activities:
- The operator is the heat network asset owner or entity with significant control over network infrastructure, with the ability to invest and direct repairs and maintenance. This is the entity responsible for the day-to-day operation and maintenance of a heat network and its infrastructure.
- The supplier is the entity with a heat supply contract (or equivalent) with customers for the supply of heating, cooling or hot water.
In most cases, the regulated operator and supplier will be the building owner (unless an Energy Services Company ("ESCO") has been appointed to supply customers directly and has significant control over the heat network assets).
Who needs to register?
All operators and suppliers of existing heat networks will need to provide organisational-level details and register their existing heat networks via Ofgem's digital platform by the deadline of 26 January 2027.
The operator is responsible for starting the registration process. The supplier will need to register organisation-level details so that the operator can invite each supplier to register their heat network supply activity against the relevant heat network.
Where there are connected district and communal networks, each relevant heat network must be individually authorised with Ofgem. If your heat network is connected to other heat sources or the heat network ownership/operation is split, it is important to identify who will be the nominated point of contact.
What information do you need to register?
- Regulatory contact – Each operator/supplier must nominate a regulatory contact that will act as the primary point of contact with Ofgem and remain ultimately responsible for ensuring that all submitted information is accurate and complete.
- Organisation-level information – Each operator and supplier must provide details about their organisation, including type, company details, and ownership structure. Ofgem will also require financial resilience information, unless the operator/supplier is subject to social housing regulations.
- SMRI (Significant Managerial Responsibility or Influence) – The regulatory contact must complete a declaration confirming that individuals in SMRI roles meet Ofgem's fit and proper criteria under Authorisation Condition A08. This includes confirming that your organisation has policies and procedures to assess and monitor the suitability of those individuals.
- Operator-specific information – Organisations with multiple heat networks will need to register each heat network separately. Operators must provide detailed technical data for each heat network including location, heat source, capacity, number of buildings and embedded networks. Operators will also need to prepare a Material Asset Register detailing the condition and function of critical infrastructure.
- Supplier-specific information – Suppliers must provide customer data for each heat network including the number of domestic and non-domestic consumers and whether any non-domestic customers are microbusiness or small business consumers.
- Policies/procedures – During registration, both the operator and supplier must confirm that a complaints procedure and a fit-for-purpose Continuity Plan are in place. The supplier must also confirm whether a Priority Services Register is operational (for networks supplying domestic customers), which provides details of any customers in a vulnerable situation.
How to prepare
Collating the relevant data will require coordination within your organisation – with input required from customer services, operations, finance, technical, and asset management teams.
Where heat network ownership and/or operation is shared between multiple parties, parties must act early to agree responsibilities and the nominated Regulatory Contact.
Registration is not the finish line: it is the starting point for an ongoing regulatory relationship with Ofgem. Once registered, authorised persons will be required to submit monitoring data on a regular basis.
Relevant stakeholders should take stock of existing heat network arrangements, assign clear ownership of the registration process and start assembling the data you will need, both for registration and ongoing compliance.
If you are concerned about any of the issues raised or how regulation may impact you, please get in touch with a member of our Energy and Sustainability team.
For more information, our Heat Network Regulation topic page brings together our latest updates, insights and events.
