Priority Services Register obligations in force from 27 January 2026 — proactive consumer identification required now

Vulnerability and Priority Services for Heat Networks

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

How to identify, support, and protect vulnerable consumers on your heat network. Ofgem requirements for Priority Services Registers.

Why Vulnerability Matters for Heat Network Operators

Heat is not a discretionary service. For many consumers, particularly the elderly, disabled, chronically ill, and those with young children, losing their heat supply or being unable to afford it has immediate and serious consequences for health and wellbeing. Ofgem's regulation of heat networks places significant emphasis on the identification and protection of vulnerable consumers, reflecting the approach established in the gas and electricity sectors over many years.

What the Authorisation Conditions Require

Operators must establish a Priority Services Register (PSR) to identify consumers who may be vulnerable due to age, disability, chronic illness, mental health conditions, language barriers, financial difficulty, or other circumstances. The PSR must be actively maintained, not simply a form that consumers can fill in if they happen to know about it. Operators are required to take proactive steps to identify consumers who may be eligible, offer tailored support measures, train staff to recognise and respond to vulnerability, and handle personal data relating to vulnerability with appropriate safeguards.

Support measures may include advance notice of planned supply interruptions, priority restoration during unplanned outages, accessible billing formats, additional support during billing disputes, and referral to external support services where appropriate.

The Difference Between a List and a System

Having a list of names is not the same as having a vulnerability policy. Ofgem expects operators to have documented procedures covering how consumers are identified and added to the register, what specific support measures are available, how staff are trained to recognise vulnerability indicators, how the register is reviewed and updated, how consumer data is protected, and how the effectiveness of the arrangements is monitored. This is a living system, not a one-off exercise.

Building Your Vulnerability Documentation

Operators need an internal vulnerability and PSR policy, a staff training framework, a consumer-facing guide explaining what support is available and how to request it, and data handling procedures specific to the sensitive personal information involved. Our platform generates all of these documents, tailored to your network type and consumer base, with every Authorisation Condition requirement addressed.

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PSR policy, staff training framework, and consumer-facing guide — tailored to your network type, every AC requirement addressed.

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Also see: White Paper: Vulnerability, PSR and Disconnection — in-depth guidance on Ofgem's consumer protection framework.

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