Response to Ofgem’s Heat networks regulation: authorisation conditions for registration, nominated operator, and notification of changes

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To properly regulate heat networks, a foundation of clear authorisation and robust regulatory oversight is essential. These conditions should ensure that only providers meeting high standards of fairness, transparency, and reliability are permitted to operate. A key challenge is clarifying accountability, as a single heat network often involves multiple parties like operators, subcontractors, and landlords. 

In a previous consultation response, Citizens Advice emphasised the need to make responsibility and accountability absolutely clear, particularly in cases of subcontracting or multiple operators. This includes ensuring proper monitoring and data-sharing agreements are in place between all sub-contracted entities. 

Ofgem's recent decision document  has helped address many of these requirements. It established an operator-led model, mandated a single-operator or nominated operator contact point for multi-operator networks, and introduced requirements for registration, reporting, pricing, and enforcement. While we support this progress, greater detail is needed on how responsibilities will be allocated in complex subcontracting relationships, and we anticipate seeing more on this in future guidance.