Background

The Heat Networks (Market Framework) (Great Britain) Regulations 2025 will appoint Ofgem to regulate Heat Networks in a similar way to energy companies. They have been introduced to improve Heat Networks’ performance, operation, and customer satisfaction. The first set of requirements start in 2026, and the remaining ones will be introduced in phases, following consultation on the remaining requirements. The NHMF is working with The Heat Network to help landlords prepare for and comply with the new requirements.

What is already in operation?

On 1^st April 2025, the Consumer advice services were launched with the appointment of:

• The Energy Ombudsman (EO) to provide an independent dispute resolution service for heat network customers. EO is an established organisation, set up in 2006 to deal with customer disputes with energy suppliers. It knows the sector because it’s been working with the Heat Trust for 10yrs.
• Citizens Advice has also been appointed from 1^st April to provide advice to heat network customers in England & Wales. In Scotland this service will be run by Consumer Scotland.

When will these Regulations start?

These Regulations start on 27 January 2026 and Ofgem’s role as regulator begins with the authorisation regime coming into effect. Heat networks that began operating or supplying a heat network before 1 April 2025 are automatically authorised (‘deemed authorisation’), and may continue these activities. They will be required to register their heat networks through Ofgem’s digital service by the end of the first part of the initial period ((any time before Jan 2027).

Ofgem will have the ability to intervene in egregious cases of non-compliance.

2027 onwards Ofgem will begin industry-wide compliance activity, with more protections coming into force.

DESNZ is currently sourcing providers for the following three functions Technical Assurance Scheme Operator, Training Provider and Certification Body, which are integral to the operation of the new regulations. DESNZ is also developing a new technical standard - TS1, based on CP1 (2020) to align with HNTAS technical requirements. It is being developed with the input of multiple technical industry experts.

There will be additional consultations in 2025 before all the new regulations are published. Landlords can register with DESNZ to be kept informed of consultations and developments.

What will change from 27 January 2026?

Heat Supplier reporting. From 27 January, Heat suppliers in Great Britain (excl. Northern Island) will no longer need to submit Heat Network (Metering & Billing) notifications to the Office of Product Safety and Standards. They will instead need to submit registration and compliance data to Ofgem once Ofgem’s digital service launches, which is planned for Spring 2026. Meter installation and accuracy obligations remain in place for Heat Suppliers, unless exempt, until the Heat Network Technical Assurance Scheme is in effect.

What is out for consultation now?

Ofgem is consulting on:

• Heat network registration process and its draft guidance (deadline 15 Dec 2025), and
• Heat networks regulation: regular data reporting guidance (deadline 12 Jan 2026).

Even if you do not intend to respond to these consultations, landlords are encouraged to read both guidance documents (fairly short).  In particular, the ‘regular reporting’ guidance has an excellent table showing what the reporting requirements will be (what and how often).  Regardless of when you register, your reporting will have to be backdated to April 2026 so landlords are advised to be thinking now about how they will have everything required.

What does this guidance cover?

Heat network registration guidance sets out the roles, responsibilities, and obligations for authorised persons that are operating or supplying a relevant heat network during the first part of the initial period, as set out in regulation 26 of the Heat Networks (Market Framework) Regulations 2025 (the regulations), and are therefore required to complete heat network registration.

Heat networks regular data reporting guidance will support heat network suppliers and operators to submit data to Ofgem to help it monitor their performance. It provides:

• details of the data that must be reported to Ofgem
• the segments who must report data
• the reporting periods and timings for submission

What should social landlords do now?

Landlords should register now with the Energy Ombudsman so they can be informed of how the Ombudsman operates its independent dispute resolution service. Once registered, landlords (HN operators) will receive an information pack and a set of FAQs.

Read both of the draft guidance documents (see above) so that they can be prepared for their new responsibilities, especially reporting requirements and ensure they will have all the information required.

They should register with DESNZ for updates and study what is being proposed by reading the consultations and responding where the proposals are not suited to the sector. Landlords should read DESNZ’s December newsletter for the latest updates and grants.

How can social landlords prepare?

Register with the Energy Ombudsman, study its guidance, and establish clear record-keeping for Heat Network enquiries, complaints and how they are dealt with. This will enable landlords to comply with the new requirements and ensure they have all the evidence they need to demonstrate compliance.

They should study the new regulations to understand what is required and assess any areas that need to be improved or introduced. For example, consumer protection should be less of a concern for social landlords because they are already required to do this but they may want to ensure that customer service staff can record when enquiries or complaints relate to a heat network so they can keep records of how they have dealt with them. Good record keeping will also help demonstrate compliance with Awaab’s Law.

It will also be important for social landlords to check whether their definition of vulnerable customer adequately covers Ofgem’s definition. Landlords should consider updating tenancy documents and inform all new tenants when they are supplied by a heat network. Landlords will need to be more proactive to avoid the risk of tenants falling into fuel poverty, debt, etc.

Landlords need to ensure they have all the information they need to comply and identifying any gaps in their data. They will also need to understand the new Technical Standards that heat networks will have to meet (when they are published).

Sign up to receive DESNZ’s Newsletters, which keep landlords up to date and notify them of webinars, training and other help that the Government is providing to help the sector understand and comply with the new Heat Network Regulations.

What help is available?

The Heat Network is a forum to discuss and share good practice about district and communal heating within social housing.  It brings together its own communal heat experiences, shares lessons and some short guidance documents to help colleagues across the sector.  It also acts as a conduit for social housing input into national heat network policy.

The NHMF promotes best practice in social housing maintenance and is committed to championing innovation to deliver excellence in maintenance and asset management. An organisation automatically becomes a member when it subscribes to the M3NHF Schedule of Rates and selected modules. Its Best Practice website publishes briefings on asset management and repairs and maintenance, including links to all the relevant legislation and guidance. Heat Network Regs workshop at last year’s NHMF Conference.

DESNZ awards grants, such as Heat Network Efficiency Scheme (HNES). Round 11 of funding is open for applications until Friday 6^th February. There will be a HNES Application Seminar and Q&A for Round 11 Tuesday 13^th January (register to attend). DESNZ’s Newsletters keep landlords up to date and notify them of webinars, training, and other help that the Government is providing to help the sector understand and comply with the new Heat Network Regulations.

The NHMF acknowledges the help and advice from Rachael Mills, The Heat Network.