Pillar 1: Compliance Health Checks

Know Where You Stand. Understand Your Risks. Close the Gaps.

Phase 1:

Initial Regulatory Compliance & Operational Review

Establish your baseline. Reduce your risk.

Before you can move confidently towards full Ofgem compliance, you need clarity on where you stand today.

Phase 1 provides a structured, independent review of your heat network’s current regulatory position and operational readiness. It establishes a clear baseline, highlights immediate risks and ensures your scheme is correctly positioned before progressing into detailed compliance implementation in later phases.

This is not a full future-framework audit. Instead, it is the essential first step. We confirm what’s in place, what’s missing and what needs to be addressed - so you can move forward with confidence rather than assumption.

Establish a baseline to avoid risk, cost and delay. Phase 1 ensures:

Clear regulatory positioning
Early risk mitigation
Defined responsibilities
Evidence-led decision making
A stable foundation for detailed compliance mapping in Phase 2

It is the first controlled step in your journey towards full regulatory readiness.

Phase 1 Deliverables

1. Regulatory Positioning & Licence Preparation

Clarity on your obligations. Confidence in your structure.

We carry out a structured review of your scheme against current Heat Network (Metering & Billing) Regulations and the emerging Ofgem licensing framework to establish clear regulatory positioning, giving you clarity before committing to full implementation. We'll:

Review information provided against existing heat metering and billing regulation, and licencing framework.

Confirm licencing structure, including identification of the appropriate authorised person(s) e.g. operator, supplier and legal licence holder.

Prepare an Expression of Interest to operate a licensed network.

Support with Ofgem engagement and early dialogue to test interpretations, assumptions, and completeness of submission materials.

2. Heat Metering & Billing Compliance Review

Are your metering and billing arrangements regulator-ready?

Using a structured compliance framework - including site visits where required - we assess these elements to give you a clear view of where you meet requirements - and where improvements are needed:

Heat metering arrangements (installation, accuracy, replacement planning, and operational data capture).

Data collection and telemetry systems, including meter connectivity, data export capability, and fault monitoring.

Billing arrangements against regulatory conditions, including billing frequency, template compliance, PAYG requirements, and transparency standards.

Registration and consumer protection measures, including Energy Ombudsman registration.

Phase 1 Deliverables

3. Technical & Operational Evidence Review

Is your scheme operationally aligned with regulatory expectations?

To support regulatory readiness, we'll undertake high-level technical and operational review aligned with regulatory expectations, including:

Network efficiency indicators and monitoring practices.

Controls strategy, operational performance and asset health checks.

Building safety and manufacturer compliance considerations.

Availability and completeness of key documentation (O&M manuals, schematics, commissioning records, maintenance logs, etc.)

At the end of Phase 1, you'll have:

A structured compliance assessment covering:

Metering
Billing
Consumer protection
Operational readiness
Clear identification of regulatory gaps and risks
Defined ownership and licensing positioning
A documented baseline to inform Phase 2

You'll know exactly where your scheme stands - and what must happen next.

Phase 2:

Regulatory Scoping & Ofgem Compliance Mapping

From baseline clarity to structured compliance planning.

Once your regulatory position has been confirmed in Phase 1, Phase 2 moves into detailed compliance scoping.

This is where we translate regulation into practical, scheme-specific requirements.

We undertake a structured review of your heat network(s), supplier and operator arrangements to identify all applicable obligations under the Ofgem framework and map these against your current level of compliance.

This phase does not involve a line-by-line rewrite of documents. Instead, it establishes what must exist, what currently exists and what is missing - providing a clear, evidence-based roadmap to full compliance.

Authorised persons must demonstrate compliance across multiple sections of the regulatory framework. These apply to:

All Authorised Persons
Operators
Suppliers

What We Assess

Section A: Conditions for All Authorised Persons

These are the core Standards of Conduct. They set the foundation for how operators and suppliers must behave.

We assess alignment with expectations around:

Fair treatment of consumers

Transparency and accessibility of information

Prepare an Expression of Interest to operate a licensed network.

Governance and accountability structures

Section B: Conditions for Authorised Suppliers

This section focuses on the supplier-consumer relationship and service delivery standards.

We assess readiness across:

Billing accuracy and transparency

Back-billing controls

Heat supply contract structure and clarity

Service standards and performance monitoring

Protections and processes for vulnerable consumers

What We Assess

Section C: Conditions for Authorised Operators

This section centres on security of supply and operational responsibility to ensure your operational model is not only functional, but defensible under regulatory scrutiny.

We assess:

Heat supply contract compliance and transparency

Continuity of service arrangements

Asset maintenance accountability

Outage prevention and escalation procedures

Consumer redress and dispute routes

At the conclusion of Phase 2, you'll have:

A scheme-specific scoping note and structured gap analysis
A regulatory applicability matrix covering all relevant requirements
A clear view of current compliance levels
Identification of required documents, processes and governance controls
A prioritised draft compliance plan
Defined allocation of responsibilities across your organisation and delivery partners

This gives you a practical, structured route towards implementation - not just a regulatory summary.

Phase 2 Deliverables

The Compliance Evidence Landscape

Our experience indicates that a compliant heat supplier/operator may require in the region of 170+ structured documents and records to evidence full compliance. These typically span:

Standard Operating Procedures
Governance and accountability frameworks
Pricing and tariff models
Audit and assurance documentation
Consumer communication templates
Vulnerability policies
Reporting mechanisms

Phase 2 identifies which of these exist, which require development, and which require structural revision.

Breakpoint: Strategic Review Before Implementation

At this stage, you will have a complete understanding of:

Your regulatory obligations
Your current level of compliance
The scale of work required to achieve readiness
The resource implications across people, process and documentation

We recommend a structured pause here to confirm scope, priorities and delivery approach for Phase 3 and beyond.

The complexity - and therefore cost - of implementation will depend on your scheme’s current position. Broadly, we categorise this as:

Low Complexity

80%+ compliance

Limited intervention required

50–80% compliance

Targeted updates and structural refinement needed

Medium Complexity

High Complexity

Below 50% compliance

Significant document development, process redesign or remediation required

Phase 3:

Regulatory Readiness & Future-Proofing

From compliance planning to operational reality

Phases 1 and 2 provide clarity. Phase 3 delivers implementation and where regulatory obligations are translated into practical frameworks, documented processes and operational controls - ensuring your scheme is fully prepared for licensing, audit and ongoing regulatory oversight.

Our focus is not just achieving compliance at a point in time, but embedding a structure that is sustainable, auditable and resilient as regulation evolves.

This phase prepares your scheme for full Ofgem compliance and long-term operational resilience. Activities may include:

Developing a detailed compliance roadmap for licensing and HNTAS requirements.
Identifying systems/data gaps (billing, metering tech, operational data).
Environmental/decarbonisation readiness assessments.
Detailed review of existing documents to assessment compliance.
Drafting compliance governance frameworks and escalation protocols.
Preparing template compliance documentation.
Creating a compliance dashboard with KPIs and evidence logs.

What Phase 3 Delivers

1. Detailed Compliance Roadmap

A structured route to full licensing readiness.

We develop a comprehensive, scheme-specific compliance roadmap covering:

Licensing application preparation

HNTAS alignment and assurance readiness

Regulatory submission sequencing

Internal governance sign-off stages

Defined timelines and critical milestones

This ensures your route to compliance is controlled, phased and realistic.

2. Systems & Data Readiness Assessment

Compliance is only as strong as the systems behind it.

We assess whether your current systems can support regulatory expectations across:

Billing platforms and tariff controls

Metering infrastructure and data capture

Operational monitoring systems

Reporting and audit trail capability

Evidence retention and document management

Where gaps exist, we define the functional requirements needed to achieve regulatory robustness.

What Phase 3 Delivers

3. Governance & Accountability Frameworks

Clear ownership. Clear escalation. Clear evidence.

We design and formalise compliance governance structures, including:

Defined authorised person accountability

Escalation and breach reporting protocols

Vulnerability and consumer protection oversight

Internal audit and assurance mechanisms

Board-level reporting structures

This ensures compliance is embedded at the right level of your organisation - not left as an operational afterthought.

4. Documentation Development & Refinement

Turning regulatory requirements into defensible documentation.

Following the gap analysis in Phase 2, we:

Conduct detailed review of existing documentation

Redraft or strengthen policies and procedures where required

Develop missing Standard Operating Procedures

Prepare compliant contract and communication templates

Align tariff models and pricing transparency documents

The objective is to create a structured, regulator-ready documentation suite that evidences compliance clearly and consistently.

What Phase 3 Delivers

5. Performance Monitoring & Evidence Management

Compliance must be demonstrable - not assumed.

We design a compliance dashboard and monitoring framework, including:

Key regulatory KPIs

Service level tracking

Consumer protection indicators

Vulnerability reporting metrics

Evidence logs aligned to regulatory conditions

This provides ongoing visibility of compliance status and creates an audit-ready evidence trail.

6. Environmental & Future Regulatory Alignment

Preparing for what comes next.

We also assess readiness against emerging environmental and decarbonisation expectations, including:

Asset performance and efficiency monitoring

Carbon reduction trajectory alignment

Reporting capability for future sustainability obligations

This ensures your scheme is positioned not just for today’s framework, but tomorrow’s regulatory evolution.

What You Achieve in Phase 3

By the end of this phase, your scheme will have:

A structured and documented route to licensing submission
Defined governance and accountability controls
A compliant and defensible documentation framework
Systems aligned to regulatory reporting expectations
An embedded compliance monitoring structure
Greater operational resilience and regulatory confidence

You move from understanding compliance requirements to being demonstrably prepared to meet them.

If you're unsure where your scheme currently stands, start with a Phase 1 Health Check.

Find out more

Health Checks & Ofgem Readiness

Ofgem regulation has changed the expectations placed on heat network operators and Property Managers. Non-compliant or inefficient heat networks risk fines, poor resident experience and rising costs. Our Heat Network Health Checks help you get ahead - identifying risks before they become problems, protecting residents and proving your compliance. We offer flexible service tiers to meet your needs and support your operational goals.

Why have a health check?

Compliance:

Identify where your network is falling behind and stay compliant with all regulatory requirements.

Cost Efficiency:

Reduce running costs by improving network efficiency, saving your residents money.

Safety:

Ensure your network is up to building and manufacturer standards.

Future-proofing:

Protect the value of the assets on your network and demonstrate responsible management.

Service Improvements:

Increase resident satisfaction through fair, transparent billing and reliable heat delivery.

Many portfolios are operating with historic arrangements that were never designed for this level of scrutiny.

The purpose of our Compliance Pillar is simple:

Establish where you stand.
Define what must change.
Implement it properly.