Energy Ombudsman accepting heat network complaints since 1 April 2025 — your procedure must be in place

Heat Network Complaints Handling

By Hamish McDonald, Director — Heat Network Compliance — Sorted-IT (UK) Ltd — heatnetworkcompliance.co.uk — published 28 May 2026

What Ofgem requires from heat network suppliers for complaints handling. Timescales, recording, reporting, and escalation routes.

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 suppliers receive, record, investigate, and resolve complaints from heat network consumers. Getting this wrong exposes suppliers 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.

Who this guide is for. The Complaints Handling duty under AC B4 sits on the supplier in the regulated activity of supply. On most heat networks the operator and supplier are the same legal entity, so this guidance applies to operators in that capacity. Where operation and supply are split between different entities, the duty sits on the supplier. References to "the supplier" below should be read as "the supplier — who on your network may also be the operator".

What the Authorisation Conditions Require

AC B4 (Complaints Handling) requires the supplier to establish a documented complaints procedure that is clear, accessible, and fair. The procedure must include:

Suppliers 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.

Escalation Routes

The Energy Ombudsman is the Qualifying Redress Scheme for heat network complaints under the Authorisation Conditions. Where a complaint remains unresolved eight weeks after it was made — or sooner if the supplier issues a deadlock letter — the consumer can escalate to the Energy Ombudsman. Suppliers must inform consumers of this right at the appropriate point in the complaints process. The Ombudsman's decisions are binding on the supplier but not on the consumer.

Heat network complaints may also fall within the jurisdiction of:

Consumers may also seek free independent advice from Citizens Advice (England and Wales), Advice Direct Scotland, or Consumer Scotland depending on jurisdiction.

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:

The Authorisation Conditions require all of these elements.

How to Get Compliant

Suppliers 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, addressing the key requirements of AC B4 with paragraph-level citations.

Generate Your Complaints Documentation

Internal complaints policy and consumer-facing leaflet — key AC B4 requirements addressed and cited.

Generate your complaints documentation
Start free today →

Also see: Vulnerability and Priority Services Guide — how PSR obligations interact with your complaints procedure.

Related Guides

Last checked against official sources: 28 May 2026.