A practical guide to the registration process, what information is required, and how to ensure your organisation is ready to use Ofgem's open digital service.
All operators and suppliers of relevant heat networks in Great Britain must register with Ofgem under the Heat Networks (Market Framework) (Great Britain) Regulations 2025. Ofgem's digital registration service opened in April 2026 and is open now, with a registration deadline of 27 January 2027. Operating after that date without registration is a criminal offence.
This guide explains what registration requires, what information Ofgem will ask for, and the steps operators should take now to ensure they are ready to register without delay using the open service.
Registration under the 2025 framework is not a simple data exercise. It is Ofgem's mechanism for assessing whether an operator is fit to hold authorisation and has the consumer protection arrangements in place that the Authorisation Conditions require. When you register, you are not just providing technical data about your network — you are demonstrating to Ofgem that you are operating compliantly.
Previous registration does not carry over. Networks registered under the Heat Network (Metering and Billing) Regulations 2014 must re-register under the new framework. The previous register and the new Ofgem authorisation register are entirely separate.
Deemed authorisation — granted automatically to all operating networks on 27 January 2026 — allows continued operation during the registration period. It does not reduce compliance obligations. Consumer protection conditions were enforceable from 27 January 2026 regardless of registration status.
Registration is required by every person who operates or supplies heat through a relevant heat network in Great Britain. A relevant heat network is one that supplies heat to two or more premises not all owned by the same person. This captures:
Where a network has both a person carrying on the regulated activity of operating and a separate person carrying on the regulated activity of supply, both may need to register as authorised persons depending on their respective roles and obligations under the Authorisation Conditions.
Ofgem's Registration Guidance (January 2026) sets out the information required. Registration involves two broad categories of information:
Information about the legal entity applying for authorisation:
Technical and operational information about each heat network:
Critically, registration will require operators to confirm that their consumer protection arrangements are in place. While Ofgem's digital service will determine the precise attestation and evidence requirements, operators should expect to demonstrate that they have documented policies covering:
Documentation first, registration second. Operators who arrive at the registration portal without completed, compliant documentation will face delays and risk missing the January 2027 deadline. The time to prepare documentation is now — not once you have started registering.
The digital service is not a single form. A handful of early answers determine which questions you are asked afterwards, and you will not be shown the ones that do not apply to you. That is convenient until one of those early answers is wrong, at which point you complete a registration that looks finished while answering a different question set from the one that applies to your scheme.
The answers that do the routing:
None of these is a data-gathering question. Each is a determination about your scheme. Resolve them before you open the service rather than in it.
Ofgem's published guidance answers the general questions well. The digital service asks several that it does not. The positions below come from written correspondence with Ofgem about a specific district scheme, and are set out here because the questions recur. They are Ofgem's position on the facts they were given — not published guidance, and not a rule of general application. A scheme with different facts may get a different answer.
The positions in this section come from Heat Network Compliance's own correspondence with Ofgem on a live district registration.
A block divided into two cores, with two entrances and two addresses, is commonly recorded as two buildings. If it is one physical structure it is one building. The count drives the rest of the registration, so an error here propagates.
A communal heat network is one that supplies a single building divided into separate premises, and it may be a standalone building with its own energy centre or a network embedded in a district scheme from which it is supplied heat. Nothing in that definition requires plant at the building.
Asked directly whether a block with no plant room, no heat exchanger, no building-level meter and no separate management arrangement could still be an embedded communal network, Ofgem's position was that the absence of those things does not necessarily prevent it. The key consideration is whether the building contains separate premises supplied through the network. Where such a building is supplied by a wider district network, they generally expect it to be an embedded communal network.
Most operators assume that plant at the building is what creates a separate network. It is not.
Where a relevant heat network is connected to another relevant heat network, each network must be individually authorised — and the guidance says this applies even where a single entity undertakes both operation and supply for both networks. A district network serving multiple qualifying blocks therefore produces one district registration plus one embedded communal registration for each qualifying building. The registration form asks for the number of embedded communal networks and who is responsible for them.
The ongoing consequence is the part worth planning for. Each registration generates its own confirmation and unique reference, and carries its own regular data reporting under condition A9, its own continuity plan confirmation and its own complaints procedure confirmation. A scheme with seventeen qualifying blocks does not have one set of ongoing obligations. It has eighteen.
The guidance presents its network diagrams as examples. Asked whether they were determinative, Ofgem's position was that they are illustrative and not determinative in isolation — the accompanying text governs. Operators reasoning from the diagrams alone should read them against the paragraphs they sit with.
Individual houses on a district network stay inside the district registration. They do not generate separate registrations.
The communal definition covers buildings whose communal system supplies non-domestic customers in separate premises within that building. A shop, surgery or community facility inside a residential block therefore sits within the building already counted. It does not add to the building count; it appears as separate premises in that building's communal registration, and its occupier is a non-domestic consumer for the supplier's customer information.
Ofgem's guidance illustrates thermal substations, and for schemes with them the substation is often the first thing an operator looks to record. On the district registration path there is nowhere to do it: the summary runs the energy centre directly to the connected buildings, with nothing represented in between. That is not a gap in the guidance — the guidance frames a physical boundary as delineating regulatory responsibility between separate entities, so where one entity operates throughout, the substation is not a boundary. But operators arriving with a substation-shaped mental model of their scheme should expect the form not to share it.
Where primary and backup plant cannot run together at full output, Ofgem's position was that they want the actual operational output of the plant, not the sum of the nameplate ratings. Heat imported from off site is included if it passes through the energy centre and forms part of its supply capacity.
The question asks for the technology providing the largest proportion of heat within the energy centre — not across the scheme, and not the original source of the heat. A free-text option exists for arrangements the list does not fit, and Ofgem pointed to it for imported-heat cases. Third-party waste heat producers such as data centres and wastewater sites are generally not carrying on regulated activity, so an off-site producer is not an upstream relevant heat network.
This is the deemed-authorisation question under regulation 27. A network already operating or supplying before 1 April 2025 answers No. Deemed authorisation also covers activity commenced during the first part of the initial period.
An operator is generally expected to have substantial control over key decisions on the long-term reliability, efficiency and compliance of the network, including authority or influence over significant investment decisions such as major upgrades, expansions or fundamental changes to the infrastructure. Ownership of the assets may indicate substantial control but does not necessarily determine the role — the operator is the entity with sufficient control over the material assets needed to comply. In the leasehold sector this is typically the freeholder, though a Right to Manage company or residents' management company may hold it instead.
Everything in this section is from Ofgem's published registration guidance, and several points run against what operators commonly assume.
Registration is a notification, not an application. It does not involve an assessment or approval process. Once submitted, registration is complete and no further action is required unless Ofgem says otherwise. You receive an email acknowledgement with a unique reference, and each heat network generates its own confirmation.
Declaring non-compliance does not block you. Ofgem uses registration to establish a compliance baseline, and declaring non-compliance will not prevent an authorised person from completing registration. Operators who assume they must be fully compliant before registering have the sequence backwards.
The operator goes first. Where operation and supply sit with different entities, the operator initiates and must complete their submission before the supplier is invited to complete theirs. Under condition A4, the supplier's obligation is treated as not having arisen until at least one operator has discharged theirs. The supplier must co-operate with the operator, including by providing relevant information, to allow the obligation to be discharged in time. If a supplier cannot register by the deadline because the operator has not completed their component, they should contact Ofgem.
Organisation details are entered once. Organisation-level information is submitted once during registration and is not repeated for each network. Network-level information is per network.
The regulatory contact carries the accountability. The account requires a regulatory contact, ideally the most senior person responsible for the network's operations and regulatory compliance. They control user permissions and can invite others, and they remain ultimately responsible for the accuracy and completeness of everything submitted.
The fit and proper declaration lasts three years. You complete a declaration confirming compliance with the ongoing fit and proper obligation under condition A8 unless a current one is already on the account. Declarations expire after three years. Significant managerial responsibility or influence can extend to advisers and consultants with effective decision-making authority, not only employees. Ofgem may follow up if you declare that you lack robust assessment procedures, that you do not reassess regularly, or that not everyone in such a role is fit and proper.
A continuity plan must be in place by the deadline. Both operator and supplier confirm whether one is in place and fit for purpose, and it is required to be in place by the end of the first part of the initial period.
There is no bulk upload. Ofgem confirmed in its January 2026 decision that bulk upload will not form part of the registration service, and that it will be considered for later services such as regular data reporting. Portfolio operators should plan accordingly.
Your registration becomes public. Ofgem is required to publish a list of authorised persons showing the activities they undertake and the geographical location of the network, updated as registrations complete.
There is no notification of changes authorisation condition. Ofgem consulted on one in November 2025 alongside registration and nominated operator, but it does not appear in the final general authorisation conditions.
What applies instead is condition A10, the open and co-operative principle. An authorised person must disclose to Ofgem, in writing or orally, any circumstance relating to them of which Ofgem would reasonably expect notice in order to perform its statutory functions — particularly acts or omissions that give rise to a likelihood of detriment to heat network consumers. That disclosure should be made as soon as the circumstance arises, or as soon as the authorised person becomes aware of an increased likelihood of it arising.
There is no defined trigger list and no fixed window. That is a broader duty than a notification condition would have been, and it requires a judgement each time rather than a checklist.
Condition A5 applies where multiple authorised persons control different parts of the physical heat network infrastructure. Regulation 13 sets out when multiple parties may be identified as the operator for a relevant heat network. Where that happens, they must use reasonable endeavours to agree which of them acts as the contact point with Ofgem on behalf of the others, and must ensure Ofgem is notified of the agreed nominated operator. Ofgem expects practical and proportionate steps — communicating, cooperating, and making genuine efforts to resolve differences.
The nominated operator relays information and notifications between Ofgem and the other operators in both directions, without undue delay, and provides reasonable co-operation and coordination as the single point of contact. The other operators must promptly provide the nominated operator with information and notifications as may reasonably be required.
What it does not do. The nominated operator's responsibilities are limited to their role as the primary point of regulatory engagement. They do not adopt any regulatory liability for the actions or inactions of the other operators. Each operator keeps its own obligations.
Where the nominated operator has registered on behalf of the others, Ofgem expects those other operators still to engage with the digital service directly for ongoing matters such as financial resilience and the ongoing fit and proper requirement.
Ofgem decided not to reserve a power to nominate an operator itself where the parties cannot agree, and the guidance does not extend to decision-making or dispute resolution between operators. This is the answer for a local authority or housing association that has outsourced operation and is unclear who registers: it is agreed between the operators, not assigned by the regulator.
No application is needed to invoke an exemption. Three cases are set out in the guidance.
Separately, self-supply, industrial and shared ground loop heat networks are within scope but carry reduced obligations. They must register, but provide less information at registration and in regular data reporting. For self-supply and industrial networks, the Section B and Section C authorisation conditions do not apply.
List every heat network you operate or supply. Each relevant network will need to be registered separately.
Determine whether you are the operator, the supplier, or both for each network. This determines which Authorisation Conditions apply.
Collect technical information for each network: fuel source, capacity, consumer numbers, metering arrangements.
Draft and adopt all required policies covering the applicable Authorisation Conditions. Consumer-facing documents must also be in place.
Identify key personnel and complete AC A8 ongoing fit and proper assessments. Document the process and outcomes. Local authorities should read the Fit and Proper (A8) for Local Authorities guide for a worked analysis of who holds SMRI in a council.
Submit your registration application via Ofgem's digital service.
You've just read what the service asks of you. The Pre-Audit Checklist breaks the authorisation conditions into 38 checkpoints across 11 policy areas, so you can mark off what you already hold before you start the registration. Check your documents against all 38
Regulations commenced. All Authorisation Conditions enforceable. Deemed authorisation granted to all active operators.
Ofgem's digital registration service opened. Operators can submit registration applications.
Registration deadline. All operators must have submitted a complete registration application. Operating without registration after this date is a criminal offence.
Housing associations and local authorities that operate heat networks must register in the same way as any other operator. Ofgem estimates that around 66% of existing heat networks are owned or managed by social landlords — making this sector central to the registration process.
Where a local authority or housing association has outsourced network operation to an ESCO or SPV, it is important to establish clearly which entity holds the regulatory obligations. The exemptions in AC A12 and A13 for local authorities acting as landlord apply only in specific, defined circumstances. ESCOs and SPVs are not covered by these exemptions.
Operators with multiple networks register once as an authorised person and then register each relevant network separately. There is no per-network pricing for the authorisation regime — authorisation is held at the entity level. Documentation requirements under the Authorisation Conditions similarly apply at the organisation level: one complaints procedure, one vulnerability policy, one Standards of Conduct policy — adapted where necessary to reflect the characteristics of individual networks.
The Heat Network Compliance platform generates operator-specific policies and consumer documentation for registration, mapped to the applicable Authorisation Conditions and built against Ofgem's January 2026 final guidance.
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