Heat Network Complaints Handling

Why Complaints Handling Matters Under the New Regulations

Complaints handling is one of the most scrutinised areas of Ofgem's heat network regulation. The Authorisation Conditions set specific, detailed requirements for how operators receive, record, investigate, and resolve complaints from heat network consumers. Getting this wrong exposes operators to enforcement action, consumer redress orders, and reputational damage. Getting it right demonstrates the kind of proactive consumer protection that Ofgem has indicated it will view positively during the early years of regulation.

What the Authorisation Conditions Require

The Complaints Authorisation Condition requires operators to establish a documented complaints procedure that is clear, accessible, and fair. The procedure must include:

• Defined timescales for acknowledging and responding to complaints
• A structured escalation process including access to a senior decision-maker
• Accurate recording of all complaints including categorisation and outcome tracking
• Regular internal reporting on complaints volumes, themes, and resolution rates
• Clear information for consumers about how to escalate unresolved complaints to the Energy Ombudsman

Operators must make their complaints procedure available to all consumers in writing, and it must be easy to find — Ofgem's guidance is explicit that burying the procedure in lengthy terms and conditions is not acceptable.

The Energy Ombudsman

For the first time, heat network consumers have access to the Energy Ombudsman for dispute resolution. If a complaint remains unresolved after eight weeks (or earlier if the operator issues a "deadlock letter"), the consumer can escalate to the Ombudsman. Operators must inform consumers of this right at the appropriate point in the complaints process. The Ombudsman's decisions are binding on the operator but not on the consumer.

Common Gaps in Existing Procedures

Many heat network operators have some form of complaints process, often inherited from general housing management procedures. Typical gaps include:

• No specific timescales for acknowledgement and response
• No defined escalation path to a senior person
• No mention of the Energy Ombudsman
• No systematic recording or reporting
• No consumer-facing document that explains the process in plain language

The Authorisation Conditions require all of these elements.

How to Get Compliant

Operators need two documents: an internal complaints policy setting out the organisation's procedures, responsibilities, timescales, and reporting arrangements, and a customer-facing complaints leaflet that explains the process in clear, accessible language. Both documents must be consistent with each other and with the specific requirements of the Authorisation Conditions.

Our Policy Document Generator creates both documents as part of the compliance documentation suite, with every requirement of the Complaints Authorisation Condition addressed and cited at paragraph level.

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