Citizens Advice response to Ofgem’s Heat networks regulation: consumer protection guidance consultation.

Heat networks regulation: consumer protection guidance consultation 279 KB

Citizens Advice welcomes Ofgem’s consultation on Consumer Protection Guidance for the heat network sector. With new regulations set to take effect in January 2026, guidance will play a crucial role in ensuring fair outcomes for the estimated 1.1 million people connected to heat networks.

Heat network consumers have no choice of supplier - it’s essential that guidance supports suppliers to meet their obligations and ensure consumers receive fair outcomes. 

There are key areas of the guidance which must be addressed: 

• There is an inconsistency between the guidance and authorisation conditions around separate billing and lease requirements. This should be clarified to avoid inconsistent outcomes for consumers.  

• Ofgem should clarify how the back-billing rules interact with existing case law, as the current approach could expose consumers to unfair, long-term catch-up bills.

• Suppliers should be required to update contracts within 12 months of the deadline to register with Ofgem, ensuring consumers can challenge unfair charges and poor service without unnecessary delay.

• Ofgem should clarify how protections for vulnerable consumers under housing law interact with its regulatory framework, helping suppliers understand their responsibilities and provide appropriate support.

Overall, Citizens Advice supports the intent of the guidance but urges Ofgem to provide clearer instructions, practical examples, and evidence-based expectations. This approach will help ensure suppliers aim for good consumer outcomes - rather than meeting the absolute minimal standard to be considered compliant.