Communal heating and Ofgem registration: a managing agent's checklist

Last checked against Ofgem's published guidance on 15 September 2026. Not legal advice; see disclaimer and sources.

Since 27 January 2026, existing heat networks have been “deemed authorised” by Ofgem and must register on its Heat Networks Digital Service. This is the checklist for a managing agent, RMC or RTM director, or freeholder with one or more blocks on communal heating.

1. Work out how many networks you have

Each heat network registers separately. A building with its own plant room is one network. An estate with one energy centre feeding five blocks is one district network plus five communal networks, so six registrations. Registration count for district networks is as described by compliance providers; confirm on Ofgem’s registration guidance for your own layout. The regulation start date and the deemed-authorisation approach are verified: Ofgem, heat networks regulation is now live.

2. Decide who is supplier and who is operator

• Operator: runs and maintains the network.
• Supplier: contracts to supply heat to consumers.

For a self-managed block where the management company pays the gas bill and recovers it through the service charge, the management company is usually both. Where a facilities contractor runs the plant under contract, the roles may sit with different organisations. Suppliers can only register once invited by the operator, and where several operators exist a “nominated operator” is the first point of contact. Verified for nominated operators: regular data reporting guidance, para 2.17. The invite flow is as described in Ofgem’s registration guidance; check the current version.

3. Register by 26 January 2027

Registration opened in April 2026 on Ofgem’s digital service, “Comply with heat networks consumer protection regulations”. Existing networks must register by 26 January 2027. Verified: Ofgem blog on the digital service and reporting guidance para 2.14.

Compliance providers say operating unregistered after that date is a criminal offence with penalties of up to 10% of turnover or £1m. We have not confirmed this in the Regulations. Treat the deadline as hard regardless.

4. Join the Energy Ombudsman scheme

Authorised networks are bound by the Energy Ombudsman scheme. Ofgem’s reporting asks each quarter how many complaints you signposted to the Ombudsman at eight weeks or deadlock, so you need to be a member and have that step in your complaints process. Verified that the data point exists: Table 7, p21. Membership deadline as described by compliance providers.

5. Start recording from April 2026

Ofgem’s regular data reporting asks for data from April 2026, backdated once you register. It will accept what you have for April–June 2026. The first submissions through the digital service are expected from autumn 2026. Verified: guidance paras 2.14–2.15; How to prepare for data reporting.

Per block, start now:

• A complaints log: category (Ofgem’s six), date received, date resolved, group complaint flag, Ombudsman referral date.
• A heat debt log: customers over £200 outstanding for three months or more, repayment plans, disconnections, reconnections.
• A Priority Services Register, or at least a count of residents in vulnerable situations, handled under UK GDPR as special category data.
• Your tariff or your heat-element method, in writing.
• Counts: dwellings supplied, meters, heat cost allocators, prepayment meters, smart metering.
• Annual figures: fuel cost, kWh generated, kWh delivered, heat revenue, running costs.

6. Organisation-level finance, once a year

Unless you are a council or a registered social housing provider, the authorised organisation reports eight finance points annually: continuity plan, 12-month resources, profit or loss, income, operating costs, liquid assets, whether assets exceed liabilities, and hedging. Due in the quarter your accounts are signed off, within 10 months of year end. Verified: Table 3 and para 2.6. For an RMC this is the RMC’s own accounts.

7. Diary the windows

Quarterly windows are the month after each quarter; the annual return is 1–30 April. Full table on our deadlines page.

What this checklist doesn’t cover

The other authorisation conditions: fair pricing, standards of conduct, supply contracts, back-billing limits, prepayment and self-disconnection protections, and continuity arrangements. Compliance providers describe about 29 conditions across sections A to C. Numbering unverified by us. Read Ofgem’s authorisation conditions directly for those.