The Department of Energy Security and Net Zero (DESNZ) has published a reminder that two consultations on the development of the heat networks regulatory framework will close for responses on Friday 31 January at 11:59.

Heat networks are the collective name for district and communal heating, including supported and extra care.  Most social housing providers will have at least one heat network in their portfolio and so will be affected by the new Regulations.

Links to the consultations are below:

• In the heat networks regulation: implementing consumer protections consultation (published jointly with DESNZ) Ofgem is consulting on the consumer protection requirements that heat network operators and suppliers will need to comply with. This includes the first set of draft heat network authorisation conditions as an appendix, and they would like views on whether these reflect the intended policy intent.
• The heat networks regulation: authorisation and regulatory oversight consultation contains proposals on Ofgem’s approach to authorisation, market monitoring, compliance, and enforcement.

It is important to take this opportunity to tell the Government your views because most social landlords will be regulated as heat network operators. You are encouraged to provide any evidence you may have to support your views, especially in relation to any extra costs of complying and whether the implementation timescale is realistic.

Q. When will the Regs come into operation?

A. These Regulations will be laid in Parliament in 2025, with different commencement dates for each aspect. The consumer advocacy, advice and redress services will come into effect in April 2025. These will be provided by Citizen’s Advice in England & Wales and Consumer Scotland in Scotland. A Consumer Redress scheme will be run by the Energy Ombudsman.

January 2026: the Regulations commence and Ofgem’s role as regulator begins with the authorisation regime coming into effect. Heat networks will be deemed to be authorised from the outset in April 2025, and will be given until early 2027 to complete registration through Ofgem’s digital service. 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.

There will be additional consultations in 2025 before all the new regulations are published.

Q. What are some of the key issues?

A. While social landlords are likely to support the proposed regulations, The Heat Network has identified the following areas as needing careful consideration to ensure the sector will be able to comply without unnecessary burdens. Landlords should consider what might be involved in complying with these new requirements and include this as practical evidence in their responses.

• Landlords should strongly welcome and support the principles of consumer protection because they align with their social objectives. However, costs for regulation ultimately fall on customers and so investment has to be carefully considered and balanced against other regulatory demands building safety and damp/mould/condensation. These new regulations must be realistic in order for them to be successful and deliver what their objectives of affordable, reliable, and low-cost heating and hot water.
• Since social housing is already regulated by the Regulator for Social Housing, it is critical that these regulations should complement how they are already evidencing consumer protection. They should not create unnecessary administrative costs by duplicating RSH requirements. Ofgem’s approach must be proportionate.
• While social landlords manage around two-thirds of all heat networks in the UK, their awareness of the regulations is still low and they would benefit from support to develop compliance plans. This is compounded by the sector having to manage legacy schemes that have been poorly designed, developed, and commissioned. These operate with poor efficiency and reliability. The reality of these heat networks needs to be taken fully into account as regulation is developed to make sure it works for the end consumer and does not lead to higher costs.
• While most landlords are both willing and able to deliver consumer protection, there are significant concerns about the Heat Network Technical Assurance Scheme (HNTAS) due to be the subject of a separate consultation. What little is known about HNTAS indicates it will add significant costs, be hugely complex and make heat networks more expensive for customers. This could undermine the long-term aim of making heat networks a key tool for the delivery of net zero by 2050.

Q. What should social landlords do?

A. Respond to the consultations and provide clear evidence on what is practical, what the costs (and other challenges) are for implementing these new regulations. It is important that as many landlords as possible respond to support the key messages and to highlight any proposals, such as consumer protection or complaint handling that are already covered by existing regulations in social housing. For landlords that have not analysed the detailed questions in the two consultations, there are a few simple options to respond. For landlords who are members of The Heat Network (THN), they can:

• Copy/paste sections of the THN’s response they support.
• Send a letter saying they support the THN response and include some of the key points (see THN key points on p1).

All landlords can respond via the Government’s Citizenspace portal, which goes through each question and landlords can tick to say if they agree/disagree. There is space to add further detail for each question as required.

Q. How can social landlords prepare?

A. You should start by studying the new regulations and assessing what areas need to be improved or introduced to comply with them. For example, compliance with the consumer protection requirements should be less complex because social landlords already have many systems in place.  Areas that will require further investigation include how customer service staff record enquiries relating to a heat network; whether your definition of vulnerable customers adequately covers Ofgem’s definition; if and how tenancy documents and customer communication processes need updating. Landlords will also need to be more proactive to avoid the risk of tenants falling into fuel poverty, debt, etc, to be proactive in improving their data, and engage fully with the Technical Standards that heat networks will have to meet (consultation expected shortly).

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.

Q. What help is available?

A. 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 organised a workshop at its Conference dedicated to the Heat Network Regs and these consultations with presentations by The Heat Network, DESNZ, FairHeat, and a social landlord. This workshop enabled social landlords to understand what will be required by these new regulations and will help comply and the slides can be found HERE.

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.

DESNZ also awards grants of up to £500 towards eligible Heat Network Training courses. These grants are available until April 2025. 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 it has received from Rachael Mills, The Heat Network.