Ofgem Heat Network Rules: A Guide for Property Managers

What Actually Changed in January 2026

Until 2026, heat networks sat in an unusual gap. Residents on a communal system could not switch supplier, had no price cap, and — unlike customers of a gas or electricity supplier — had no sector regulator to escalate to. On 27 January 2026, Ofgem formally became the regulator for heat networks across England, Scotland and Wales.

Heat networks are now a licensed-style sector. Rather than a licence, operators hold an authorisation, and the rules attached to it are called authorisation conditions. Ofgem has powers to investigate and to take enforcement action where those conditions are not met.

The practical shift for a London managing agent is this: the communal heating system in your block is no longer just a building service you maintain. It is a regulated utility, and somebody has to be formally accountable for it.

Does This Apply to My Building?

If your building supplies heating or hot water to separate dwellings from a shared source — a central plant room, a CHP unit, a district heating connection, a communal heat pump — then it is almost certainly a heat network, and it is in scope.

That covers the great majority of London blocks built in the last twenty years with heat interface units in each flat. It does not matter that the block is private leasehold, that the network is small, or that it has only ever been treated as a landlord service charge item. Scale affects the detail of what you report, not whether you are regulated.

Who Is the Regulated Party?

This is the question that causes the most confusion, and it is worth resolving early. The obligations fall on the heat network operator and the heat supplier — not automatically on the managing agent who administers the building.

In a typical London leasehold block, the regulated party is usually the freeholder, the resident management company or the landlord entity. A managing agent acting under a contract is generally performing the work rather than holding the obligation. But the arrangement varies, and Ofgem's interest is in there being a clearly identified accountable person — not in how your contracts are structured.

Registration: Deemed Authorisation and the 2027 Deadline

If the network was already operating before regulation began, you do not need to apply for permission to continue. It is deemed authorised automatically. That is the good news, and it is why nothing appeared to happen on 27 January for most buildings.

You do, however, have to register the network with Ofgem. Registration runs through Ofgem's Heat Networks Digital Service, which opened in 2026, initially in a private beta. Networks registered during the beta do not need to register again at full launch.

The deadline is the end of the first part of the initial period, which Ofgem gives as 26 January 2027. After that date, any new regulated activity has to be authorised by application rather than deemed — so a block that misses the window is in a materially worse position than one that registered in good time.

A note on the date: Ofgem's own published material is not perfectly consistent, with its January 2026 registration guidance referring to 27 January 2027 while its service pages and authorisation consultations give 26 January 2027. Plan around 26 January 2027 as the working deadline and confirm the exact cutoff with Ofgem for your network.

The Material Asset Register — and Where HIUs Come In

Alongside registration, authorised persons must have a Material Asset Register in place by the same date. This is a documented record of the assets that make up the heat network. For a residential block, that realistically means:

• Plant room equipment — boilers or heat pumps, CHP, pumps, pressurisation units, buffer vessels, plate heat exchangers
• The distribution network — primary and secondary pipework, isolation and commissioning valves, insulation
• In-dwelling equipment — the heat interface unit in every flat, and the heat meter serving it

This is where many blocks discover a problem. Plant room assets are usually documented because they sit in an O&M manual from handover. The HIUs very often are not. A 94-flat block may have three generations of HIU across four manufacturers, fitted over a decade of refurbishment, with no central record of what is behind each cupboard door.

Building that record is a site survey, not a paperwork exercise. If you are commissioning block-wide HIU servicing anyway, the sensible move is to capture the asset data in the same visit — make, model, serial, installation date, meter serial and meter reading, flat by flat. You pay for one round of resident access instead of two, and residents are disturbed once.

What the Consumer Protection Rules Require

The authorisation conditions that took effect in January 2026 focus on how customers are treated. Ofgem's stated expectations cover four areas:

There is also a complaints route. Residents are expected to raise an issue with their heat supplier first; if it is not resolved, it can go to the Energy Ombudsman. Ofgem has encouraged suppliers to join the Energy Ombudsman's heat network scheme so that unresolved disputes are handled promptly.

The operational consequence for a managing agent is that your complaints and fault logs now matter in a way they did not before. If a resident escalates a six-week hot water outage, the question will be what you did and how quickly. A documented response — attended within a stated time, fault diagnosed, part ordered, supply restored — is a very different position from no record at all.

HNTAS: The Technical Standards Still to Land

The consumer protection rules are about how you treat customers. A second scheme deals with how the network is built and run: the Heat Network Technical Assurance Scheme, or HNTAS.

HNTAS is expected to set mandatory technical standards covering design, installation, commissioning and ongoing maintenance — with heat interface units explicitly in scope as the consumer connection. The government consultation closed on 15 April 2026.

Be careful what you act on here. At the time of writing the final scheme had not been mandated, and a number of specific requirements circulating in the trade press — including particular servicing intervals for direct and indirect HIUs — come from secondary commentary rather than confirmed scheme documents. Treat the consultation material as directional, and check the current DESNZ and Ofgem position before writing anything into a maintenance contract.

What is reasonably clear is the direction of travel: commissioning evidence aligned to CIBSE CP1, return temperature performance treated as a measurable indicator, and documented maintenance of in-dwelling equipment. In early 2026 MEHNA published a national guide to HIU installation, commissioning and maintenance under the HNTAS banner, aligned to TS1, the BESA HIU Test Regime and BS 7593.

A block that already has annual HIU service records and commissioning data will absorb HNTAS without much drama. A block with no records will be starting from zero under a deadline.

A Practical Checklist for the Next Three Months

1. Confirm scope. List every building in your portfolio with communal heating. Assume it is in scope unless you have a clear reason otherwise.
2. Settle accountability in writing. Agree with each freeholder or RMC which entity holds the operator and supplier roles, and who the nominated regulatory contact is.
3. Register. Create the organisation account on Ofgem's Heat Networks Digital Service and complete registration well before 26 January 2027. Do not leave it to January.
4. Build the Material Asset Register. Plant room first from the O&M manual, then the in-dwelling HIUs and heat meters. Combine this with a servicing round if you can.
5. Review billing and complaints. Check that heat charges can be explained line by line, and that you have a documented fault and complaint log.
6. Identify vulnerable residents. Start a priority services record now — it is relevant to the fair treatment conditions and it is useful operationally during an outage.
7. Get maintenance evidence in order. Annual HIU servicing with written reports gives you an auditable record ahead of HNTAS, and reduces the outages that generate complaints in the first place.

Where Collide Group Fits

We are HIU and heat network engineers, not compliance consultants — we are not going to file your Ofgem registration for you. What we do is the part of this that happens on site: surveying and recording every HIU and heat meter in a block, servicing them to a documented standard, and giving you written reports you can put in front of a regulator or a resident.

If you are facing the asset register deadline across a portfolio, block-wide servicing with asset capture built in is usually the most efficient way to get there. We cover all 26 London boroughs and work with managing agents, RMCs and housing associations across the capital.

Sources & Disclaimer

This guide is based on Ofgem's published material on heat networks regulation, including its registration guidance of 23 January 2026, its authorisation conditions consultation, its guidance on complying with heat networks consumer protection regulations, and the government's heat networks technical standards consultation. Regulation in this area is still developing and the position may have moved since publication. This is general information for property professionals, not legal advice — confirm your own obligations with Ofgem or a qualified adviser.

Last reviewed: 1 November 2026.