Do I need a Priority Services Register for a heat network?
Last checked against Ofgem's published guidance on 30 October 2026. Last updated 30 October 2026. How we check. Not legal advice; see disclaimer and sources.
Yes. If you are the supplier of a heat network with domestic customers — which includes a management company recovering heating through the service charge — Ofgem’s authorisation condition B8 requires you to “establish and maintain” a Priority Services Register of residents who may need extra support because of their personal characteristics or a vulnerable situation, to promote it, to offer to add people to it, and to provide the priority services free of charge. The condition has applied since 27 January 2026. Once a year you also report to Ofgem how many people are on it. Verified: Ofgem, Heat networks regulation: authorisation conditions — decision, 13 January 2026, Appendix 2, Section B Condition 8 (pages 104–105) and the notice that the conditions come into force on 27 January 2026 (page 1).
The register is a list of people, so it is personal data — and often health data. Keep it small, keep it secure, and report only the count.
Who has to keep one?
Section B of the authorisation conditions applies to any authorised person carrying on “the regulated activity of supplying heating, cooling or hot water” to consumers, except industrial and self-supply networks. Condition B8 is about “Domestic Consumers” and occupants of “Domestic Premises”. So:
| Your situation | Priority Services Register required? |
|---|---|
| You supply domestic customers (a block of flats, heat billed or in the service charge) | Yes |
| You are the operator only, and a different organisation is the supplier | No — it falls on the supplier |
| Industrial or self-supply network | No |
| Non-domestic customers only | The condition is written around domestic consumers |
Verified: authorisation conditions decision, Section A Condition 1 (application of Section B) and Section B Condition 8.
What must the register contain?
Condition B8 requires the supplier to:
- “establish and maintain a register (the ‘Priority Services Register’) of persons who are either a Domestic Consumer who, and/or an occupant of Domestic Premises which, the authorised person supplies and who may, due to their Personal Characteristics or otherwise being in a Vulnerable Situation, require Priority Services”;
- “take all reasonable steps to promote the existence of the Priority Services Register”;
- take all reasonable steps to identify such consumers “in the course of interactions” and “offer to add any or all of the Minimum Details to the Priority Services Register during interactions”;
- add the Minimum Details, and share them “using the Relevant Industry Mechanisms”, in so far as data protection law permits.
Verified: Condition B8, paragraphs 8.1–8.3.
Minimum Details means “the names of relevant persons, details of any relevant Personal Characteristics and/or Vulnerable Situation, and such other details… as the Authority may from time to time publish in guidance”. Verified: Condition A3 definitions (Appendix 2, pages 58–60).
Who counts as needing priority services?
Two defined terms decide it:
- Personal Characteristics: “the person being of Pensionable Age”; “the person being chronically sick, or having an impairment, disability, or long term medical condition (including a visual, auditory or mobility impairment)”; or other characteristics the supplier identifies as relevant to the priority services.
- Vulnerable Situation: where a person’s circumstances and characteristics make them “significantly less able than a typical person to protect or represent their interests” and/or “significantly more likely than a typical person to suffer detriment”.
Verified: Condition A3 definitions (Appendix 2, pages 58–60).
What do you have to offer people on the register?
Free of charge, “such of the Priority Services as such person may reasonably require”. The condition lists what those services enable, including:
- extra support to identify anyone acting on the supplier’s behalf (for example, a password scheme for callers);
- a nominated person receiving communications about the account;
- meter reading at appropriate intervals where the consumer cannot read the meter and has no one to do it;
- safe, practicable functioning of any prepayment meter;
- communications in an accessible format suited to the person’s needs.
Verified: Condition B8, paragraphs 8.4–8.5.
What do you report to Ofgem?
Two things:
- Annually, in the regular data return: the number of consumers in vulnerable situations, which Ofgem expects to match the Priority Services Register count — see the data point. Verified: regular data reporting guidance, Table 6.
- Social obligations reporting (Condition B12): information Ofgem specifies about dealings with domestic consumers, which “may, in particular, include… the services offered by the authorised person to persons on its Priority Services Register and the number of persons who are listed on that register”, provided to Ofgem, Citizens Advice, Citizens Advice Scotland and Consumer Scotland in a statistical form and at intervals Ofgem sets. Verified: Condition B12.
Neither asks for names. Report counts.
Running a register in a small block
This is our practical suggestion, not Ofgem’s text:
- One sheet, six columns: flat, name, contact, what applies (pensionable age / health or mobility / other), which services they want (nominated contact, accessible format, meter reading, caller password), date added and date last confirmed.
- Ask everyone once a year, in the same letter that sends your complaints procedure (Ofgem’s complaints condition already requires that annually), and whenever someone contacts you.
- Treat it as special category data under UK GDPR: health information needs a lawful basis and a condition for processing, access limited to the people who need it, and a retention rule (remove people who move out). Keep the count separately so reporting never means opening the register.
- Tell your operator and any plant contractor that vulnerable residents are on the network, so a planned outage is handled with that in mind — Ofgem’s decision document states its “expectation that communal suppliers ensure their bulk supplier is aware there are vulnerable consumers on the heat network”. Verified: decision document, Ofgem’s response on self-disconnection (page 41).
If in doubt about the data protection side, that is a question for the ICO’s guidance or a data protection adviser, not for this site.
Which of these apply to your network?
The free checker gives you the list in three minutes, with a collection template. Nothing leaves your browser unless you ask for the template by email.
Related guides
- Every Ofgem heat network data point, Tables 3 to 8 — The full list from the March 2026 guidance with plain-English explanations.
- Does the Energy Ombudsman cover heat networks, and when does the Housing Ombudsman apply? — Which ombudsman, the 8-week and 12-week clocks, and what your complaints procedure must contain.
- All 9 guides to Ofgem heat network reporting
What changed on this page
- 30 October 2026
- Re-checked against all sources; every quote still matches. Corrected references: the definitions are in Condition A3, not Condition 2, and page numbers now point to the conditions in force (Appendix 2), not the marked version. The bulk-supplier point is Ofgem's own stated expectation, not respondents' point.
- 16 September 2026
- First published, checked against Ofgem's authorisation conditions decision (13 January 2026), Section B Condition 8 and Condition 12, and the regular data reporting guidance (10 March 2026), Table 6.
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