Citizens Advice Response to Ofgem’s consultation: Heat networks regulation: Fair pricing protection guidance
Citizens Advice welcomes the opportunity to reply to Ofgem’s consultation on fair pricing guidance for heat networks. The Fair Pricing Framework is a major pillar of the new regulatory system starting in January 2026, and because heat networks are natural monopolies, standards of fairness and transparency in pricing need to be even stronger than in the gas and electricity market. Heat network consumers can’t switch suppliers or shop around to get a better tariff - so regulation, not market competition, must drive better outcomes for consumers.
Guidance should be designed to ensure heat network providers aim for good outcomes, rather than meeting the minimum standard of compliance. Guidance should also support heat network providers with less experience of energy regulation, limited resources or overlapping regulatory frameworks to navigate their new responsibilities effectively.
We’re broadly supportive of the proposed fair pricing guidance, particularly where it provides illustrative examples and clear distinctions between rules and best practice guidelines. However, there are several weaknesses and areas of confusion we think Ofgem should address:
Interactions with other regulatory frameworks
Fair and reasonable returns guidance
Price transparency guidance
Unmetered properties
Legacy arrangements