Regulation · Roles & Responsibilities
Your role — operator, supplier, or both — determines which Ofgem authorisation conditions apply to you. Getting this wrong at registration is one of the most common errors. Here is a clear breakdown.
| Role | Definition | Primary obligations |
|---|---|---|
| Operator | Controls and maintains the physical network infrastructure | Network reliability, metering and monitoring, technical standards |
| Supplier | Provides heat to customers and is their main point of contact | Billing, consumer protection, complaints, vulnerable customer identification |
Most housing associations, local authorities and private landlords managing their own networks are both operator and supplier. If you maintain the plant and invoice residents directly, both sets of conditions apply. Ofgem does not reduce your obligations because the roles sit with one entity.
In schemes managed by ESCOs or under heat supply agreements, each entity registers separately and meets only the conditions relevant to their role. Contracts between them should clearly allocate compliance responsibilities — Ofgem can pursue either party for failures in their respective areas.
The operator controls and maintains the physical network infrastructure. The supplier provides heating to customers and is their main contact for billing and complaints. Many heat network owners are both operator and supplier and must meet the conditions for both roles.
Yes. If they handle billing and are the residents’ primary contact, they may be the supplier regardless of who owns the infrastructure.
The test is functional — who controls the network, and who bills the customer. If your arrangements are complex, clarify before completing Ofgem registration, as incorrectly registering your role creates compliance gaps.
Both sets of authorisation conditions apply. You must register both roles with Ofgem and maintain compliant documentation for all applicable conditions.