🔴 Priority

Level 1 Actions

Authorisation

Metering

Billing

Complaints

Vulnerability & PSR

🔴 Priority Level 1

AUTHORISATION

Heat network suppliers and operators are now subject to Ofgem’s Authorisation Conditions. Existing relevant networks must complete registration by 26 January 2027 and demonstrate ongoing compliance with the conditions.

Registration

The digital Authorisation Portal is now available in beta. This allows heat suppliers to familiarise themselves with the registration process, understand the information required and begin preparing ahead of full implementation. Early preparation reduces the risk of delays, identifies evidence gaps sooner and gives organisations more time to strengthen their compliance arrangements.

What should you be doing now?

☐ Confirm who will act as the Authorised Party

☐ Review the Authorisation Conditions

☐ Identify any compliance gaps before registration opens fully

☐ Confirm contracts and Heat Supply Agreements are in place

☐ Confirm governance, reporting and record keeping arrangements

☐ Engage suppliers and contractors to understand their role

Watch Ofgem's video: Preparing to register your heat network Part 1. The Who, What and Why of heat network registration.

🔴 Priority Level 1

AUTHORISATION

Are your foundations in place?

✔ Resident Complaints Procedure

✔ Priority Services Register

✔ Vulnerability Policy

✔ Business Continuity Plan

✔ Heat Supply Agreements

✔ Metering & Billing Processes

✔ Governance and Audit Records

✔ Fit & Proper Person requirements

✔ Operational Policies and Procedures

Beta Portal - Why register early?

The current portal is now available for testing. While it isn't the formal authorisation process, registering now means it’s done and it also provides an opportunity to:

Understand the registration journey
Review the information Ofgem is requesting
Identify missing documentation
Familiarise internal teams with the process
Resolve issues before full registration begins

🔴 Priority Level 1

METERING

Under the new regulations, where meters are installed, bills must be based on actual consumption.

If meters are not communicating or are producing inaccurate data, billing may be non-compliant. Three questions to ask now:

Is metering installed?

✔ Generation meter - must be installed in the plant room.

✔ Building level meter - where energy enters the building.

✔ End user meters - installed in all apartments.

Are all of the meters working?

✔ Producing accurate, usable readings?

✔ Providing reliable data for billing and monitoring?

✔ What's the strategy to fix and replace broken/aged out meters?

Is the data being monitored?

✔ How frequently?

✔ By whom?

✔ How are faults identified?

🔴 Priority Level 1

METERING

If metering is missing or incomplete, start by understanding the gap and planning what will be needed to address it. Under the proposed HNTAS framework, existing networks will be brought up to minimum metering and monitoring standards over time, with older networks - including those not previously required to meter under the 2014 regulations - given a longer transition period.

Remote monitoring is good operational practice now because it helps identify faults and data gaps before they affect billing. Under proposed HNTAS requirements, monitoring is expected to become much more frequent, including half-hourly data for relevant meters and 5-minute data for bulk meters.

Pain Points & Common Failures

Meters not installed correctly, or there are meters but no data loggers.
Data collected but locked in unusable formats.

Bulk meters missing from registers.
Hardware failures – faulty meters, broken HIUs, or failed communication devices.
Billing agents using estimates rather than real consumption.
Lack of remote monitoring – no automated alerts when meters stop reporting.

🔴 Priority Level 1

BILLING

Billing must be quarterly (at a minimum), based on actual data and charges must be fair and transparent (including showing how bills are calculated).

Basic Billing Details

✔ Name and contact details of the supplier

✔ Billing period covered

✔ Date the bill was issued

Consumption Data

✔ Consumer’s heat consumption for the billing period

✔ Units clearly stated (e.g., kWh, MWh)

✔ Historic consumption available on request (referenced on the bill)

Charges

✔ Total amount due

✔ Breakdown of charges (e.g., unit charges, standing charges)

🔴 Priority Level 1

BILLING

Essential Billing Compliance

☐ Is the billing based on actual consumption?

☐ Are you issuing bills to an actual meter reading at least once a year?

☐ Is your billing information issued at least twice a year with every bill issued?

☐ Are you providing convenient ways and enough methods of payment?

☐ Do you have repayment plans available?

☐ Do you have proactive debt management processes in place?

Billing Transparency

Education and transparency are key for improving repayment.
Review all resident-facing communication regularly including tariff cards, welcome packs (upfront expectation setting, FAQs, how the network works), bill templates (simple wording, plain English, clear signposting)
Two-way dialogue so residents feel heard and supported: arrange regular resident meetings, drop-ins, Q&A sessions to have open conversations to remove fear, misunderstandings and misinformation
Your M&B provider should be actively involved in this engagement, helping to explain charges, support residents, and answer technical questions confidently and consistently.

🔴Priority Level 1

COMPLAINTS

This is a core requirement under Ofgem's Consumer Protection Framework. Every heat supplier must have a clear, fair and transparent complaints process that is easy for residents to access and understand.

Complaints must be acknowledged, investigated and resolved within defined timescales. Where a complaint cannot be resolved, residents must be informed of their right to escalate the matter to the Energy Ombudsman. Ofgem also expects complaints to be monitored, analysed and used to improve future service delivery - not simply closed and forgotten.

What should you be doing now?

☐ Publish a clear complaints procedure

☐ Define response and resolution timescales

☐ Make it easy for residents to raise a complaint

☐ Train staff to follow a consistent complaints process

☐ Signpost residents to the Energy Ombudsman where appropriate

☐ Record complaints, outcomes and lessons learned

☐ Review complaint trends to identify recurring issues

Can you trace a complaint from start to finish?

🔴 Priority Level 1

COMPLAINTS

Questions to ask your provider

How are complaints recorded and tracked?
Can you demonstrate your complaints process from start to finish?
How do you measure complaint response and resolution times?
Do residents receive regular updates during an investigation?

How do you identify recurring issues and implement improvements?
When are residents referred to the Energy Ombudsman?
Can you evidence complaint response and resolution times?

🔴 Priority Level 1

VULNERABILITY + PSR

Under Ofgem’s Consumer Protection framework, heat suppliers must be able to identify residents who may need additional support and make sure that support is reflected across day-to-day service delivery.

The Priority Services Register (PSR) sits within your wider Vulnerability Strategy.

Every resident on the PSR is vulnerable, but not every vulnerable resident will need to be included on the PSR.

Your Vulnerability Policy should explain how all vulnerable residents are identified, assessed & supported - not just those on the PSR.

KNOW IT

Know who needs support and how their needs are recorded.

BUILD IT

Embed vulnerability into every relevant resident process.

PROVE IT

Evidence needs identified, support provided and records reviewed.

🔴 Priority Level 1

VULNERABILITY + PSR

What you should be doing

Governance

☐ Vulnerable Residents Policy published

☐ Priority Services Register maintained

☐ GDPR-compliant data collection

☐ Regular review of resident records

☐ Reporting available to demonstrate compliance

Customer Journey & Customer Service

☐ Residents can easily tell you they need support

☐ Communication preferences recorded

☐ Reasonable adjustments & additional support documented

☐ Alternative contacts available where required

Debt Management

☐ Affordability reviewed before escalation

☐ Vulnerability checked before recovery action

☐ Independent affordability assessment

☐ Supply suspension treated as a last resort

Billing & Communications

☐ Bills available in accessible formats

☐ Tariff changes communicated appropriately

☐ Payment reminders adapted where required

☐ Support information included

Complaints

☐ Vulnerability considered throughout investigations

☐ Alternative communication methods offered

☐ Escalation reflects resident circumstances

Engineer Visits

☐ Engineers aware of additional support needs

☐ Attendance passwords available

☐ Safe access arrangements recorded

☐ Reasonable adjustments considered before visits