White Paper | April 2026
PRACTICAL OPERATIONAL GUIDE
From arrears identification to disconnection, with single binary decisions at each point and detailed instructions.
Built against the final Authorisation Conditions published by Ofgem on 13 January 2026 and the Ofgem Heat networks regulation: consumer protection guidance of the same date. Version 8, April 2026.
Recovering arrears from domestic heat consumers is a regulated activity. The Ofgem Authorisation Conditions impose a structured pathway under condition B9, prohibitions on disconnection in defined household circumstances under B9.14, and a continuing duty of fair treatment under supplier B1.3.4. Failure to follow the framework correctly exposes the operator to enforcement action and consumer redress orders, the costs of which should not ordinarily be recoverable through the tariff.
This guide presents the debt-handling decision in four phases.
Establishes the threshold at which the operator's debt-handling policy engages, confirms that the case falls within the B9 regulated framework, and assigns case ownership before the B9 pathway is opened.
Runs the structured B9 payment difficulty pathway: B9.3 proactive contact, B9.7 ability-to-pay assessment, B9.6 services offer, multi-channel engagement, the welfare visit question, and the elapse of a reasonable engagement period. A consumer who engages and enters a workable repayment arrangement at any point exits to MONITOR — escalation does not proceed.
Where engagement has not produced a workable arrangement, the operator chooses between three onward routes: revised engagement, consensual prepayment, or escalation to non-consensual prepayment or disconnection. Disconnection is not the default end-point; it is one of several routes, and the choice is made deliberately and on documented reasoning. Phase 1.5 closes with the B9.12 precondition — a statutory requirement that reasonable steps have been taken via the prepayment route before disconnection can proceed.
Reached only where Phase 1.5 has selected disconnection as the proportionate route. Tests the B9.14 prohibitions (year-round medical and winter triggers), considers the A3 vulnerable situation duty, checks technical feasibility and legal authority, and runs the formal notice and sign-off before any disconnection is executed.
Each diamond on the flowcharts asks one binary question with a YES or NO answer. This is deliberate. A workflow that combines multiple criteria into a single decision is harder to audit, harder to train staff against, and harder to defend in any subsequent regulatory or ombudsman scrutiny. Each binary decision in this guide can be evidenced separately on the consumer's case file.
Each decision and action node in the flowcharts has a corresponding instruction block in the pages that follow. The instruction blocks set out the regulatory basis, what to do at the decision point, and any notes on common pitfalls or best practice. An evidence checklist appendix at the end of the guide draws together the documentary record an operator should be able to produce at each stage.
Phase 0 is the gating phase. Its job is to confirm that this case is appropriate for treatment under the B9 framework, that either the operator's own debt-handling policy threshold has been crossed or a B9.3 / B9.5 statutory trigger has independently engaged, and that case ownership has been assigned before the structured pathway begins. A case that has not passed through Phase 0 is not yet ready for Phase 1.
The flowchart on the next page shows Phase 0 in full. The phase has three binary decisions, two of which can lead to an exit from the framework rather than progression to Phase 1.
Regulatory basis. B9.3 — trigger to offer the B9.6 services where the operator is aware, or has reason to believe, that the consumer is having or will have payment difficulty. B9.5 — proactive contact obligation, with timing triggers including no later than two missed monthly payments, one missed quarterly payment, or the consumer's own statement that they cannot make the next scheduled payment. CPG 6.28 confirms these two timing triggers as mandatory flags. CPG 6.31 lists behaviour-change indicators (lower-than-normal consumption suggesting self-rationing; PPM top-up patterns) that may also signal payment difficulty.
What to do. Test both gates. The operator's internal arrears threshold governs case-management escalation discipline; it determines when collections work transitions formally into B9 case handling. The B9.3 / B9.5 statutory triggers govern the regulatory obligation; once they are engaged, the B9 pathway begins regardless of what the operator's internal threshold says. Where (a) is YES, the operator's discipline carries the case forward. Where (b) is YES, the statutory pathway is engaged and any internal threshold becomes immaterial. Either answer takes the case to Q2.
Notes. The single most common Phase 0 error is allowing an internal threshold to delay statutory B9 treatment. Where a consumer has stated they cannot make their next payment, B9.5 has been engaged and the B9 pathway must begin — even if the operator's internal threshold has not yet been crossed. An internal threshold defined in monetary terms ("£X outstanding") is usually too narrow as a case-management trigger; threshold criteria that capture both monetary arrears and qualitative signals (missed direct debits, repeated late payments, contact from the consumer about difficulty, the CPG 6.31 behaviour-change indicators) sit closer to the B9.3 / B9.5 obligation.
Regulatory basis. A1 (Application of the conditions); A3 definitions of "Domestic Consumer" and "Heat Consumer".
What to do. Confirm that the consumer is a domestic heat consumer of a regulated heat network supplier, and that the supply arrangement is the one B9 is designed to govern. Where the supply is to a freeholder, managing agent, housing association, or other intermediary on a B2B basis (and the intermediary then supplies the end-user under a separate arrangement), B9 may not apply to the operator's recovery from the intermediary. The framework's protections are domestic-consumer-facing.
Notes. See the section Bulk supply and B2B arrangements below for fuller treatment, including the B9.16 downstream-protection regime that may restrict disconnection of bulk-supply arrangements even where the contractual debt is B2B. Note also B9.9 / B9.10: domestic supply contracts must reflect B9.3–B9.7 and B10 and must include offset rights. Where the supply contract does not, recovery action under this guide is being run on a defective contractual basis. Take legal advice where the position is unclear; misclassification is a frequent source of compliance difficulty.
Regulatory basis. Operational best practice rather than a specific authorisation condition. The documentation evidence required by the B9 framework as a whole, and the Standards of Conduct at B1, point strongly towards a single-owner model.
What to do. Assign a single named owner of the B9 case file. The owner is responsible for the documentation discipline that the framework requires — every contact, every assessment, every offer, every response. Without a single owner, documentation gaps emerge that are very difficult to defend later. Open the B9 case file at this point.
Notes. The owner does not have to be senior. They have to be consistent. Where the case is owned by a team rather than an individual, ensure that the team has a documented hand-off process so that documentation discipline survives shift changes and absences.
Many UK heat networks operate through bulk supply or intermediary arrangements rather than direct supply to the end-user. The contractual structure determines whether the B9 framework applies, and to whom. Misclassification at Phase 0 Q2 produces compliance exposure in either direction: applying B9 procedures to a B2B recovery imports unnecessary obligations; failing to apply B9 procedures to a domestic consumer recovery breaches the framework.
The operator is the regulated heat supplier and contracts directly with the domestic end-user. The end-user pays the operator. B9 applies to the operator's recovery action against the end-user. This guide applies in full.
The operator supplies a freeholder, managing agent, housing association, or similar intermediary. The intermediary supplies the end-user under a separate arrangement — tenancy, lease, service charge. The operator's recovery action against the intermediary is a B2B commercial matter; B9 does not directly apply to that action. However, the operator's B9 obligations to the end-user may still be engaged through the supplier registration: the regime does not generally allow operators to escape consumer-protection duties by interposing an intermediary.
Where the intermediary is itself separately registered as a heat supplier and supplies the end-user, B9 applies to the intermediary's recovery action against the end-user. The operator's role is upstream of the consumer-protection framework. This is the cleanest classification but requires explicit registration of the intermediary as a heat supplier.
B9.16 creates a specific protection regime for disconnection of one heat network by another heat network where domestic consumers downstream would be affected. The regime is broadly analogous to the B9.14 protections in this bulk-supplier context: the operator considering disconnection of the downstream network must take into account whether domestic consumers would be left without supply, and whether any of those consumers fall within categories comparable to those at B9.14. A bulk supplier cannot rely on the B2B classification of its own contract to avoid the downstream consumer-protection effect. Where B9.16 applies, Phase 2 of this guide should be read as governing the bulk-supplier decision, with appropriate adjustment for the fact that the consumers affected are not the operator's own domestic consumers but those of the downstream network.
Domestic supply contracts must reflect B9.3–B9.7 and B10, and must include offset rights. This is a contractual precondition that ought to have been settled at supplier registration but is sometimes left unaddressed in older supply documentation. Before any recovery action is taken, confirm that the contract terms with the consumer (or with any intermediary) are B9.9 / B9.10 compliant. Recovery action under this guide is being run on a defective contractual basis where the underlying supply contract does not reflect the framework's substantive obligations.
Operators should classify each network connection by its contractual structure as a matter of standing operational discipline. The classification should be visible on the billing and collections systems so that case workers can tell at a glance whether a recovery action falls within the B9 framework or under commercial terms. Mixed estates (some direct, some intermediary) are common; the worst outcome is to apply a uniform process across them.
Phase 1 runs the structured B9 payment difficulty pathway. It begins where Phase 0 ends — case assigned, B9 pathway opened — and runs through to the elapse of a reasonable engagement period without a workable repayment arrangement.
If the consumer engages at any point during Phase 1 and enters a repayment arrangement, the workflow exits to MONITOR. Escalation does not proceed while a repayment arrangement is being honoured. Phase 1 is the longest of the four phases and is where most cases resolve — the structured engagement pathway is, on the regulator's framing, the primary mechanism for recovery.
The flowchart on the next page shows Phase 1 in full. The HOLD nodes (amber) pause the flow where a charges dispute is unresolved or where engagement time has not yet elapsed. The instruction blocks that follow set out what each decision and action point requires.
Regulatory basis. B9.3 — trigger to offer B9.6 services on awareness or reason-to-believe basis. B9.5 — proactive contact obligation with timing triggers: no later than two missed monthly payments, one missed quarterly payment, or the consumer's own statement that they cannot make the next scheduled payment. CPG 6.28 sets these timing triggers as mandatory flags that the authorised person must include.
What to do. Two distinct obligations operate at this point. B9.3 is the trigger to offer the B9.6 services where the operator is aware, or has reason to believe, the consumer is having or will have payment difficulty. B9.5 is the proactive contact obligation, with specific timing triggers. Confirm that B9.3 has been engaged on the operator's awareness or reasonable belief, and that B9.5 contact has been made within the timing triggers. The downstream conditions all assume both steps are complete.
Notes. B9.3 and B9.5 are commonly conflated. They are distinct obligations within the payment-difficulty framework: the B9.3 trigger may be engaged on the operator's awareness or reason-to-believe basis (for example, through a third-party referral that the consumer is in difficulty); B9.5 creates objective trigger points at which proactive contact must be made, even if the operator has not otherwise identified payment difficulty earlier. In practice operators should treat either limb being engaged as starting the proactive contact and B9.6 services obligation.
Regulatory basis. B4 (Complaints handling), B6 (Provision of Billing and Price Transparency of Information).
What to do. If any element of the charges being pursued is the subject of an unresolved complaint or dispute, the disputed element should not ordinarily be relied upon as the basis for recovery action. Resolve the disputed element first under condition B4 (Complaints). Action on the undisputed remainder of any debt may continue, but a disconnection pursued where the underlying debt is wholly or substantially in dispute is liable to be reversed and to trigger consumer redress.
Notes. A dispute does not have to be formally lodged with the Energy Ombudsman to count as unresolved — a clearly raised challenge to the bill that the operator has not yet addressed is enough. Where only part of the debt is disputed, treat the disputed and undisputed elements separately.
Regulatory basis. B9.7 — ability-to-pay assessment obligation. B9.8 — due consideration of the consumer's circumstances. CPG 6.34 lists the services authorised persons must provide, including — for consumers in a vulnerable situation — the setting of payment plans over a longer than normal period; the assessment is the basis on which that judgement is made.
What to do. Carry out and document a structured assessment of the consumer's ability to pay. Capture income, essential outgoings, household composition, and any factors affecting the consumer's circumstances. The assessment is the basis on which any repayment proposal is structured. See the section Designing a workable repayment plan below for guidance on translating the assessment into an arrangement that is affordable and sustainable.
Notes. A tick-box form is not an assessment. The B9.7 obligation requires real engagement with the consumer's circumstances. Where the consumer will not engage with the assessment, document the attempts made.
Regulatory basis. B9.6 — the three services to be offered to consumers in payment difficulty (instalments, prepayment where applicable, efficiency information). CPG 6.34 elaborates the services list and adds longer-than-normal payment plan duration for consumers in a vulnerable situation. B9.8.2(d) and B5 — advice and assistance obligations, under which debt advice signposting and wider support sit. CPG 6.38 makes clear signposting and referral to external debt advice services such as Citizens Advice and National Debtline is mandatory; CPG 6.39 addresses default plans where contact has not been possible. The two should be documented separately on the case file.
What to do. Offer the three services required by B9.6 in writing: (a) a facility for the consumer to pay charges by regular instalments; (b) a facility to pay by prepayment meter where it is safe and reasonably practicable; and (c) information about reducing charges through efficiency measures. Record the offers made and the consumer's response. Separately, and as part of the B9.8 / B5 advice and assistance obligations, signpost to free debt advice services and to any hardship support arrangements available. See the section Signposting and hardship support below for the B9.8 / B5 framing.
Notes. The B9.6 prepayment offer is consensual. It is not the non-consensual B10.9 route. Where the consumer accepts the prepayment offer, explicit consent is given and the B10 framework follows the consensual pathway. See the prepayment paper for operational guidance on the B10 consensual pathway. Debt advice signposting is a B9.8 / B5 obligation distinct from the B9.6 services and should be recorded as such; treating it as a B9.6 service is a regulatory misclassification.
Regulatory basis. B9 (general) — case-by-case treatment and proportionate response.
What to do. If the consumer engages and enters a repayment arrangement, exit to MONITOR. Monitor and manage the arrangement. Do not progress to escalation while the arrangement is being honoured. Where the arrangement subsequently breaks down, return to Q6 and reassess ability to pay before any further action.
Notes. A repayment arrangement that the consumer has signed but is plainly unaffordable is not a workable arrangement. Where the arrangement is breached repeatedly, the ability-to-pay assessment may have produced an unrealistic plan, and the assessment should be revisited.
Regulatory basis. B9 (general) and the CPG. CPG 6.36 expects debt communications to strike the right tone, be understanding of the consumer's circumstances, and provide clear debt solutions. CPG 6.78 requires authorised persons to maintain records of each attempted contact. CPG 6.79 addresses the specific case where only a postal address is held: an appropriate — not necessarily large — number of contact attempts, with evidence of attempts to obtain additional contact details.
What to do. Make further engagement attempts through different channels. Letters, telephone, in-person where appropriate. Multiple letters of the same type sent at different dates do not constitute multi-channel engagement. Document each attempt separately, with date, channel, and outcome.
Notes. Where the consumer has explicitly refused certain channels (for example, declining home visits), respect that preference but document it. Continued engagement through other channels remains required.
Regulatory basis. The Site Welfare Visit is mandatory in the B10.13 non-consensual prepayment context, not for disconnection or for B9 generally. CPG 6.73 defines a Site Welfare Visit as a visit by appropriately trained staff to identify or further assess vulnerabilities and determine whether prepayment would be safe and reasonably practicable. CPG 6.74 sets the conduct duties — audio recording or body cameras, appropriate aftercare, documentation retained for at least five years. The recommendation here draws on those B10.13 / CPG provisions, the supplier B1.3.4 vulnerability duty, and the wider expectation of reasonable steps to engage.
What to do. Where the case is escalating towards Phase 1.5 and possibly Phase 2, operators should consider whether a welfare-focused visit is appropriate. Such a visit can identify household circumstances relevant to the B9.14 protections, capture any vulnerability triggers, and produce evidence of the operator's reasonable steps to engage. Document the reasoning either way — whether a visit is carried out or whether it is decided that a visit is not appropriate in the circumstances.
Notes. A meter read or debt-collection visit is not a welfare-focused visit. Where a welfare-focused visit is carried out, recording by audio or body camera (as required by B10.13.4 in the prepayment context) is sound practice. Where the consumer has refused engagement, a decision not to attempt a visit may be reasonable — document the reasoning.
Regulatory basis. B9 (general) — case-by-case treatment and proportionate response. CPG 6.24 expects authorised persons to take a sustainable approach to debt management and not focus on short-term debt recovery. CPG 6.44 reinforces that disconnection is a last resort, to be undertaken only once all other reasonable options have been exhausted.
What to do. Confirm that a reasonable period has elapsed between the first proactive contact under B9.5 and the point at which escalation is considered. The exact duration is not prescribed in the authorisation conditions; what is required is a period proportionate to the consumer's circumstances, typically measured in weeks. Shorter periods may be appropriate where the consumer has clearly refused all engagement; longer periods are appropriate where vulnerability factors are present or where engagement has been intermittent.
Notes. The proportionate engagement period is a judgement, not a fixed window. Avoid policies that prescribe a single duration as a hard cut-off. The Ombudsman is likely to test the period actually applied against the consumer's specific circumstances, not against a uniform policy deadline.
The B9.6 obligation is to offer instalment facilities; the B9.7 obligation is to assess ability to pay; the B9.8 obligation is to give due consideration to the consumer's circumstances. CPG 6.36 expects debt communications to be in the right tone, understanding of the circumstances, and supplying clear solutions; CPG 6.37 expects clear and prominent information on how much debt is owed and how it will be collected. These obligations together require the repayment plan to be a real arrangement, not a paper compliance step. A plan that was designed to fail is indistinguishable, on subsequent regulatory review, from no plan at all.
The plan should be affordable on the basis of the B9.7 assessment. The headline test is whether, after the proposed monthly repayment, the consumer has enough left over to meet essential outgoings (food, housing, transport, utilities other than heat). Where the answer is no, the plan is not affordable, regardless of what the consumer says. Operators should not interpret consumer agreement to an unaffordable plan as evidence of affordability.
The plan should clear the arrears within a realistic timescale. The right timescale depends on the size of the debt, the consumer's surplus income, and the consumer's wider circumstances. A debt that cannot be cleared within (say) two or three years on the consumer's affordability is a debt that may need partial write-off, debt advice referral, or other intervention rather than a plan that simply runs indefinitely.
CPG 6.34 lists the services authorised persons must provide and includes, expressly, "the setting of payment plans over a longer than normal period where the consumer is in a vulnerable situation". This is a CPG-derived expectation that runs alongside the B9.6 instalments service and the B9.7 assessment. Where the consumer's circumstances meet the A3 vulnerable situation test, the operator should not default to the standard two-to-three-year timescale; a longer plan may be required to keep the repayment affordable. The vulnerability assessment and the duration decision should be documented together so the plan reads, on review, as a deliberate response to the consumer's circumstances.
The plan should be agreed by the consumer in writing or by a recorded equivalent. A plan imposed unilaterally by the operator is not an arrangement the consumer has entered into. Where the consumer is unable to engage for reasons of vulnerability, the plan may need to be designed in consultation with a debt advice service or a representative.
The plan should include a mechanism for review. Consumer circumstances change — income, household composition, health — and a plan that was workable when designed may become unworkable later. A scheduled review point (six months, twelve months) and a route by which the consumer can request early review are both sensible.
Document the basis on which the plan was designed: the B9.7 assessment values used, the affordability calculation, the consumer's circumstances considered, the date of agreement, the review schedule. This documentation is both the operator's evidence of compliance and the basis on which any subsequent breach can be assessed.
Debt-advice signposting and hardship support are obligations of the operator under B9.8.2(d) and B5 (Assistance and Advice), distinct from the B9.6 services proper. The distinction matters: B9.6 sets out three specific services (instalments, prepayment, efficiency advice); B9.8 and B5 establish the wider advice and assistance duty into which signposting and hardship support fit. Treating signposting as a B9.6 service is a regulatory misclassification that can produce both under-provision (where the operator believes signposting alone discharges the B9.6 instalments obligation) and case-file confusion (where the documentation does not distinguish the two).
Operators should provide consumers in payment difficulty with details of free debt advice services. CPG 6.38 makes clear that authorised persons must signpost and refer to external debt advice services such as Citizens Advice and National Debtline, and that this information could be included in first debt letters to consumers. The principal UK services include StepChange, National Debtline, and Citizens Advice. Signposting should be in writing, with current contact details, and should be repeated rather than provided once and not mentioned again. Different consumers respond to advice services at different points; the signposting that is ignored on first contact may be acted on six months later. Where contact with the consumer has not been possible, CPG 6.39 contemplates default repayment plans based on Fuel Direct minimum payments, token amounts, or other consumption and spending assessments.
Some heat network operators maintain hardship funds, either directly or in partnership with their local authority or housing association partners. Where a hardship fund is available, signpost to it as part of the B9.8 / B5 advice and assistance obligation. Where no hardship fund is available, consider whether the operator's commercial circumstances support establishing one; the cost-benefit picture for the operator is often better than it appears, because hardship support that prevents disconnection also prevents the cost of a disconnection process.
On networks serving social housing or local-authority-owned stock, the housing provider often has its own welfare and hardship support arrangements that are accessible to the consumer. Establishing a referral relationship with the housing partner is a sensible operational step. The operator's case file should record the referral as part of the documentation for Q7 (B9.6 services offered) and as B9.8 / B5 advice and assistance evidence.
Signposting should not be a substitute for the operator's own engagement obligations. A consumer signposted to debt advice is still entitled to the full B9 pathway treatment from the operator. Use signposting to expand the consumer's options, not to discharge the operator's duties.
Phase 1.5 applies only where Phase 1 has been completed and the consumer has not entered a workable repayment arrangement. It exists to make the route-choice decision explicit. Disconnection is not the default end-point of the engagement pathway; it is one of several routes, and the choice between them is made deliberately, on documented reasoning, and in the consumer's best interests as well as the operator's.
The routes available at this point are: revised engagement (return to Phase 1 with a different arrangement), consensual prepayment (B9.6 / B10 consensual pathway), non-consensual prepayment (B10.9), or disconnection (Phase 2). The first three are less intrusive than disconnection and should be considered first.
The flowchart on the next page shows Phase 1.5 in full. Operational guidance on the prepayment routes is in the companion white paper Getting Prepayment Meters Right on Heat Networks; this guide does not duplicate that treatment.
Regulatory basis. B9 (general) — case-by-case treatment.
What to do. Before escalation beyond engagement, confirm that no alternative arrangement remains on the table. Late-stage engagement is common: consumers who have not engaged for weeks sometimes engage when escalation becomes imminent. Where a new arrangement, revised offer, or fresh engagement appears, return to Phase 1 and pursue it. A revised arrangement entered at this point is still an arrangement, and the operator's obligations to monitor and manage it apply.
Notes. A token gesture from the consumer is not the same as a workable revised arrangement. The test is whether the new offer is one that, on the B9.7 ability-to-pay assessment, would in fact be workable. Where it is not, Q12 returns NO and the route choice continues.
Regulatory basis. B9.6 — prepayment as one of the services to be offered. B10 (consensual sub-pathway) — consent quality, supplier B1.3.4 vulnerability duty, B10.3 continuing obligation. CPG 6.59 sets the explicit-consent standard: written or recorded, dated, retained, and not given under pressure from the authorised person.
What to do. Consider whether the consumer would accept a prepayment meter on a consensual basis. Where prepayment is technically feasible and the consumer would consent, the consensual prepayment route is available. It avoids the B10.9 non-consensual constraints and avoids the disconnection pathway entirely. The detailed operational guidance on the consensual prepayment route is in the prepayment paper.
Notes. Consensual prepayment is not always the right answer. For consumers with a long history of non-engagement, switching to prepayment may simply move the disconnection event from a regulated process to an unregulated self-disconnection. The B11 self-disconnection framework applies but is harder to manage operationally than a structured B9 process. Use Q13 carefully.
Regulatory basis. B10.8 — explicit consent for installation requiring premises access. B10.9.1–.2 — gateway conditions (no access required; explicit consent absent). B10.9.3–.8 — the six mandatory requirements for non-consensual remote installation. B10.10/B10.11 — vulnerability protections in the non-consensual pathway.
What to do. Consider whether a prepayment meter can be installed remotely (without premises access) and whether the B10.9 conditions are met. B10.9 has two layers: B10.9.1–.2 are gateway conditions — (1) installation can be effected without gaining access; (2) the Domestic Consumer has not given Explicit Consent. B10.9.3–.8 are the six mandatory requirements, covering prior engagement, ability-to-pay basis, vulnerability triggers, suitability, and documentation. CPG 6.51 confirms that involuntary installation for heat networks applies only to remote switching, and CPG 6.60 confirms that authorised persons have no powers of entry for debt management. Where prepayment is technically and legally available, it should be considered as a less intrusive alternative to disconnection. The choice between the two routes turns on the facts of the case. A YES answer at Q14 does not require the operator to take the B10.9 route; it requires the operator to consider it and to document the reasoning if disconnection is chosen anyway. Operational guidance on the B10.9 pathway is in the prepayment paper.
Notes. A B10.9 prepayment alternative may not be viable if the meter cannot be reconfigured remotely (older meters), if the B10.10 absolute winter ban applies (in which case the ban applies to both routes), or if the safe-and-reasonably-practicable determination concludes that prepayment would also be inappropriate. Where Q14 is NO, the operator continues to Q15 — the B9.12 precondition — with no remaining less intrusive alternative on the table.
Regulatory basis. B9.12 — prohibition on disconnection for unpaid charges unless all reasonable steps have been taken to recover via the B9.6.1(b) prepayment service, where safe and reasonably practicable. The CPG sits alongside B9.12: CPG 6.40 expects debt recovery actions to be fair and proportionate and aimed at good consumer outcomes; CPG 6.42 contemplates the full range of forbearance options where the consumer is in a vulnerable situation, including pausing or deferring recovery; CPG 6.44 reinforces that disconnection should only be undertaken as a last resort once all other reasonable options, including exploration of prepayment, have been exhausted.
What to do. B9.12 is a statutory precondition. The operator must not disconnect for unpaid charges unless it has first taken all reasonable steps to recover those charges through the B9.6.1(b) prepayment service, where prepayment is safe and reasonably practicable. The legal test is "all reasonable steps", which is fact-specific to the case. In most cases, the case file should show: (a) that consensual prepayment was offered and refused, or accepted but not honoured (Q13 path); and (b) that non-consensual prepayment under B10.9 has been considered and either was not viable (Q14 NO) or was viable but disconnection was chosen on documented reasoning (Q14 CONSIDER). These two are usual evidence of reasonable steps in a typical case, not a closed legal formula — unusual circumstances may require additional steps, or may make either of the usual two unnecessary. Where prepayment is not safe or reasonably practicable in the consumer's circumstances, the test is satisfied without an actual prepayment attempt being required — but the operator should document the safe-and-reasonably-practicable conclusion. Where the test is not satisfied, disconnection is statutorily prohibited until the missing reasonable steps have been taken.
Notes. B9.12 is the principal statutory constraint between Phase 1 engagement and Phase 2 disconnection. It is not a proportionality consideration; it is a legal precondition. Operators that proceed to disconnection without documenting the B9.12 conclusion expose themselves to the most serious form of compliance challenge — a disconnection executed in circumstances where the precondition had not been satisfied. The case file must show, in terms, the basis on which the operator concluded all reasonable steps had been taken.
This guide does not provide full operational guidance on the prepayment routes. The companion white paper Getting Prepayment Meters Right on Heat Networks is the primary operational guide. The summary below is intended only to support the Phase 1.5 route-choice decision; operators actually pursuing a prepayment route should work from the paper.
Where the consumer accepts a prepayment offer, the B10 framework applies on a consensual basis. Explicit consent at the A3 standard — written or recorded, dated, and not given under pressure, per CPG 6.59 — supported by the supplier B1.3.4 vulnerability duty and the B10.3 continuing obligation, governs the installation, ongoing operation, and any subsequent transition between meter types. The consensual route avoids the B10.9 non-consensual constraints but does not switch off the operator's wider B10 obligations — vulnerability protections, fault-handling, and reasonable-practicability considerations all continue to apply.
Where the consumer has not consented but a prepayment meter can be installed remotely, B10.9 applies. CPG 6.51 confirms that involuntary installation for heat networks applies only to remote switching, and CPG 6.60 confirms there are no powers of entry for debt management. The condition has two layers: B10.9.1–.2 are gateway conditions — (1) installation can be effected without gaining access; (2) the Domestic Consumer has not given Explicit Consent. B10.9.3–.8 are the six mandatory requirements, covering the operator's prior engagement, the ability-to-pay basis for the switch, the absence of relevant vulnerability triggers, the suitability of the consumer's circumstances, and the documentation required. Failure to meet any of the requirements means the B10.9 route is not available and the operator must consider another route — or must address whichever requirement is not met.
B10.10 imposes an absolute winter prohibition on non-consensual prepayment installation in defined household circumstances. The triggers parallel those at B9.14 for disconnection — winter period, vulnerable household categories — and CPG 6.45 articulates the prohibition in CPG voice, alongside the year-round medical-condition trigger. CPG 6.64 sets out the "do not install" (DNI) category in fuller detail, including dependency on a warm home (for example circulatory disease or sickle cell disease), households with elderly occupants without support, households with children under 2, and chronic or terminal health conditions. The principal operational options within this framework where the trigger applies are to return to engagement or to consider alternatives outside the B10.9 / disconnection routes altogether.
B10.12 creates a transitional exception to the B10.10 prohibition for small heat networks. CPG 6.52 confirms the scope: heat networks with ten or fewer connected premises may remote-switch a capable meter to prepayment mode after following the debt pathway and the safety assessment, even in winter. CPG 6.65 extends this to consumers in the "do not install" category for ten-or-fewer networks but requires evidence that the rest of the prepayment obligations have been met, and recognises these consumers as particularly at risk. CPG 6.66 frames the exception expressly as an interim mitigation in place from regulatory commencement until the launch of an enduring solution to mitigate unrecoverable debt. Operators relying on the exception have above-average reason to take legal advice on the position before doing so. Where the exception applies, B10.10's winter ban may be displaced for the qualifying networks but the wider supplier B1.3.4 vulnerability duty and the B10.11 year-round protections continue to apply. Treat the exception as transitional rather than permanent and as narrowly drawn rather than broad.
B10.11 imposes year-round protections on non-consensual prepayment installation for consumers in defined vulnerability categories. CPG 6.61 distinguishes two CPG categories: "do not install" (DNI; CPG 6.64) and "further assessment needed" (FAN; CPG 6.67), the latter covering children aged 5 and under, serious medical conditions including neurological and respiratory conditions, mental health conditions including dementia, and temporary situations such as pregnancy or bereavement. CPG 6.68 introduces the precautionary principle: authorised persons should assume that a consumer facing involuntary prepayment for debt is likely in financial difficulty and therefore more likely to self-disconnect. The protections operate on a knows-or-ought-reasonably-to-know basis and require the operator to take account of the household's specific circumstances rather than apply a uniform process.
B10.16 governs the point at which a consumer who has cleared the underlying debt should be moved off prepayment. The operator's obligation is to assess and act on this point, not to leave the consumer on prepayment indefinitely once the debt has been cleared. The test is part of the continuing obligation framework that distinguishes prepayment as a recovery tool from prepayment as a permanent meter type.
Phase 2 applies only where Phase 1.5 has selected disconnection as the proportionate route and B9.12 has been satisfied. The phase tests the B9.14 prohibitions (year-round medical and winter triggers), considers the A3 vulnerable situation duty under supplier B1.3.4, checks technical feasibility and legal authority, and runs the formal notice and sign-off before any disconnection is executed.
B9.15 imposes an express obligation on the authorised person to take all reasonable steps to ascertain whether B9.14 applies before disconnection. The B9.14 trigger checks at Q16, Q17 and Q18 must be conducted on this reasonable-enquiry basis, not on a passive assumption that absent consumer disclosure means the trigger is absent.
The flowchart on the next page shows Phase 2 in full. Stop nodes (red) reflect circumstances in which disconnection is prohibited or not feasible. Action nodes (amber) trigger additional duties or push the flow back towards a less intrusive route.
Regulatory basis. B9.14 — year-round disconnection prohibition for medical-condition households. CPG 6.45 articulates the prohibition in CPG voice. B9.15 — obligation to take reasonable steps to ascertain whether B9.14 applies.
What to do. Check whether any occupant has a medical condition that means heating or hot water is needed throughout the year, not just in winter. Where the operator knows, or ought reasonably to know, that this trigger applies, disconnection is prohibited at any time of year. This trigger is tested first because it operates regardless of season; if it applies, the seasonal tests at Q17 and Q18 do not need to be reached.
Notes. A consumer's statement of medical need should normally be treated seriously and accepted unless there is a reasonable basis for further verification. The condition does not require the operator to verify the medical condition through clinical evidence as a default. Where the operator has reason to believe the trigger applies, the prohibition applies.
Regulatory basis. B9.14 — winter disconnection prohibition. Winter period defined as October to March inclusive in the authorisation conditions.
What to do. Determine whether the current date falls within the winter period. The Authorisation Conditions define the winter period as the months of October, November, December, January, February, and March. The B9.14 winter prohibition applies during these months only; outside the winter period, the year-round trigger at Q16 is the relevant test.
Notes. Where the conditions are amended, the winter period definition should be re-checked against the binding text. Until any such amendment, the October-to-March definition is the operative one.
Regulatory basis. B9.14 — winter disconnection prohibition for the listed categories (CPG 6.45 sets the same categories in CPG voice). B9.15 — obligation to take reasonable steps to ascertain whether B9.14 applies.
What to do. Reached only where Q17 is YES. Check whether any of the listed categories apply to any occupant of the premises. The check is against the operator's knowledge or reasonable belief — where information about household composition is incomplete, the safe assumption is that the trigger may apply, and a welfare-focused visit may be appropriate to establish the position. Where any category applies, disconnection during the winter period is prohibited.
Notes. The categories are read inclusively. "Chronically sick" is not narrowly defined and is likely to include long-term physical conditions. "Disabled" is likely to be interpreted consistently with Equality Act 2010 principles, though the Authorisation Conditions do not expressly import that definition. Where any doubt exists, the safe position is that the trigger applies.
Regulatory basis. A3 — Vulnerable Situation definition. Supplier B1.3.4 — Standards of Conduct vulnerability duty. CPG 6.42 — vulnerable-situation forbearance options.
What to do. Apply the A3 two-limb test: a person is in a vulnerable situation if their personal circumstances mean they are either (a) significantly less able than a typical person to protect or represent their interests, or (b) significantly more likely than a typical person to suffer detriment, or detriment is likely to be more substantial. The comparator is "a typical person", not a typical tenant or social housing resident. Where the consumer is in a vulnerable situation, apply the supplier B1.3.4 vulnerability duty: take additional steps, document the support offered, and reconsider whether the B10.9 prepayment route is more proportionate (in which case return to Phase 1.5 Q14). CPG 6.42 contemplates the full range of debt forbearance options where the consumer is in a vulnerable situation, including pausing or deferring debt recovery actions until there is a material change in circumstances; that option remains available at Phase 2 as well as in Phase 1.
Notes. A vulnerable situation is not the same as being on the Priority Services Register. The PSR is a register of consumers entitled to specific priority services. The A3 vulnerable situation is a broader status that triggers the supplier B1.3.4 duty across all interactions; a consumer can be in a vulnerable situation without being on the PSR. Households with young children (notably those aged 2 to 5, who fall outside the under-2 trigger at Q18 but are still very young) will commonly meet the A3 test, particularly during the winter period.
Regulatory basis. This check is operational rather than a specific authorisation condition. The general duty under C1 (Operator Standards of Conduct), the security-of-supply obligation under C2, and the Health and Safety at Work etc. Act 1974 all bear on it.
What to do. Confirm that disconnection of the specific consumer's heat supply is technically feasible without impact on neighbouring consumers or on the integrity of the network. Many older communal systems lack dwelling-level isolation; in such cases, selective disconnection of a single dwelling may not be possible, and the disconnection pathway cannot be completed. Where the supply cannot be safely and selectively disconnected, return to engagement and consider B10.9 prepayment or other alternative recovery routes.
Notes. The check is particularly important on heat networks with communal risers and older dwelling-side infrastructure. Where the technical feasibility position is unclear, take engineering advice before issuing final notice. A final notice for a disconnection that cannot in fact be carried out exposes the operator to consumer redress and reputational damage.
Regulatory basis. The tenancy / lease / freehold check sits outside the authorisation conditions but is a precondition to lawful disconnection. B9.16 — bulk-supplier disconnection regime providing protections broadly analogous to B9.14 for downstream domestic consumers. Disconnection in breach of any of these exposes the operator to civil liability alongside any regulatory consequences.
What to do. Confirm that the operator has the legal and contractual authority to disconnect the supply. The position varies across private rented sector tenancies, social housing tenancies, leasehold arrangements, and freehold supply arrangements. Tenancy and lease terms may impose contractual limits on disconnection that go beyond the authorisation conditions. Where the disconnection in question is of another heat network rather than of an end-user (a bulk-supplier disconnection), the B9.16 downstream-consumer regime applies and must be checked: domestic consumers downstream of the network being disconnected may be protected by B9.16 in a broadly analogous way to the operator's own domestic consumers being protected by B9.14. Where the legal, contractual, or B9.16 position is unclear, resolve before proceeding and take legal advice where necessary.
Notes. In multi-let buildings, the heat operator's contract may be with a freeholder, managing agent, or housing association, with the end-user supplied through a secondary arrangement. The legal authority to disconnect the end-user may sit with that intermediary rather than with the operator directly. Where the contemplated disconnection is of one heat network by another (bulk supply), the B9.16 regime is the most important check at this stage. See the section on Bulk supply and B2B arrangements earlier in this guide.
Regulatory basis. B9 (general) — fair notice. CPG 6.40 — debt recovery actions to be fair and proportionate; representatives of authorised persons (debt collection agencies) held to the same standard. CPG 6.46 — good-practice expectations for disconnection communications. B10.15.1 — proportionality of any action taken to recover debt in the prepayment context.
What to do. Issue final notice in writing. CPG 6.46 expects good-practice disconnection communications to set out, in plain and simple terms, that supply will be disconnected, why, and when; what the consumer needs to do to be reconnected, with a clear way to do this, and when reconnection will follow; and signposting to further support. The notice should specify the intended disconnection date, the amount outstanding (including any recoverable costs), the consumer's remaining options to engage (further repayment proposals, prepayment offer, formal complaint), and the consequences of disconnection. The notice period must give the consumer a reasonable opportunity to respond. Use a method of service capable of evidencing receipt or attempted receipt. Recovery costs included in the notice should be proportionate to the underlying debt and the consumer's circumstances. CPG 6.40 expects debt recovery actions to be fair and proportionate and aimed at good consumer outcomes — a CPG-derived standard that applies to disconnection-stage cost decisions directly, not by analogy. B10.15.1's express "any action" framing in the prepayment context articulates the same proportionality principle.
Notes. Methods capable of evidencing service include first class post with proof of posting, recorded delivery, email with read receipt, online portal notification with timestamp, hand delivery with witness, and SMS where the consumer has previously confirmed the channel. No single method is universally appropriate; choose based on the consumer's circumstances and engagement history. On cost proportionality, consider the size of the underlying debt, the consumer's ability to pay, and the costs the operator would actually incur — a flat administrative charge that bears no relation to the work done is vulnerable to challenge under the CPG 6.40 standard.
Regulatory basis. B9 (general) — case-by-case treatment.
What to do. Where the consumer engages — by paying, by entering a repayment arrangement, or by raising a substantive issue requiring further consideration — exit to MONITOR. Disconnection does not proceed. Engagement late in the process is still engagement; the operator's obligation is to respond to it.
Notes. A token payment that does not address the underlying arrears is not, on its own, a sufficient basis to halt the process indefinitely — but it is a basis to pause and reassess. The proportionate response is to engage with the consumer about the next steps, not to treat the payment as a delaying tactic.
Regulatory basis. Best practice rather than a hard requirement of the authorisation conditions for B9 disconnection. The Standards of Conduct at B1, the general expectation of compliance evidence, and CPG Table 04 / 6.69 (which expects senior authorisation for involuntary PPM) make a documented sign-off process strongly advisable in the disconnection context.
What to do. Obtain documented senior management sign-off before any disconnection is executed. The sign-off should confirm that the regulatory compliance check has been carried out, that Phase 0 and Phase 1 were completed correctly, that Phase 1.5 considered the alternative routes including the B9.12 precondition, that the B9.14 triggers have been confirmed absent (with the B9.15 reasonable-steps obligation honoured in the enquiries), that technical feasibility and legal authority have been confirmed (including B9.16 where relevant), that cost proportionality has been considered against the CPG 6.40 standard, and that the notice and engagement obligations have been honoured. CPG Table 04 / 6.69 expressly contemplates senior authorisation as a proactive step Ofgem would generally expect for involuntary PPM — the analogue applies a fortiori to disconnection.
Notes. The sign-off is the operator's last line of defence against an inadvertent breach. A junior team member executing a disconnection on the basis of incomplete case files exposes the operator to enforcement risk; a senior sign-off process catches errors before they become breaches.
Disconnection is not the end of the operator's obligations to the consumer. Several continuing duties apply.
If the consumer engages after disconnection — by paying, by proposing a repayment arrangement, by raising a complaint, or by reporting a change of circumstances — the operator must respond proportionately. The disconnection does not extinguish the consumer relationship.
When the underlying conditions for disconnection no longer apply — because the debt has been settled, a workable repayment arrangement has been agreed, or a B9.14 trigger has now come to light — reconnection should be effected promptly and without disproportionate fees or conditions. CPG 6.47 expects reconnection "as soon as reasonably practicable" so that consumers are not off supply for longer than necessary, and offers the gas-and-electricity twenty-four-hour reconnection requirement as an indicative comparator (while accepting that what is reasonably practicable will differ between services, consumer needs, and operator capability).
The full case file — from Phase 0 arrears identification through to disconnection and any subsequent reconnection — should be retained for an appropriate period and made available on request to the consumer or to Ofgem in the event of investigation.
The vulnerability duty is not switched off by disconnection. If new information about the consumer's vulnerable situation comes to light after disconnection — from the consumer themselves, from a third party, from a public service referral — the operator should consider whether the disconnection should be reversed and whether additional support should be offered.
If, after a disconnection has been carried out, information comes to light that a B9.14 trigger was in fact present at the time of disconnection (a household member who was over 75, or who has a chronic medical condition, was not declared during engagement), reconnect promptly. Whether the operator's original decision was non-compliant depends on whether the operator knew, or ought reasonably to have known, that the trigger applied at the time. The consumer's protection is the immediate priority regardless of the fault analysis.
This guide reflects the author's working interpretation of the B9 framework as set out in the final January 2026 authorisation conditions and consumer protection guidance, supplemented by operational good practice on points the framework does not specifically address. Several points warrant explicit caveat.
Several decision points draw on inferred best practice rather than express requirements of the authorisation conditions. These are flagged in italics in the relevant instruction block. They include: the senior management sign-off process at Q24 (informed by CPG Table 04 / 6.69 in the involuntary PPM context, applied here by analogy); the alignment of welfare-focused visit best practice from B10.13 to disconnection at Q10 (informed by CPG 6.73–6.74); the technical feasibility check at Q20; the legal and contractual authority check at Q21 (other than the B9.16 element, which is a specific authorisation condition); the Phase 0 single-owner case management at Q3; and the structured route-choice discipline of Phase 1.5 as a whole (other than the B9.12 precondition at Q15, which is a statutory requirement). The reasoning for including these checks in an operational guide is set out in each block. Note for v8 readers: the cost-proportionality standard at Q22, which v7 carried as a B10.15-by-analogy position, is in v8 cited directly to CPG 6.40 (debt recovery actions to be fair and proportionate), with B10.15.1's "any action" framing as the express PPM-context articulation of the same principle.
References in this guide to "B1.3.4" mean supplier B1.3.4 — specifically the Supplier Standards of Conduct vulnerability duty in Section B. This is the continuing duty of fair treatment that runs alongside the B9 and B10 obligations across the debt-handling pathway. Operator B1.3.4 is a different provision (Section C, Condition 1, complaint-referral) with different content; it is not the duty referenced in this guide. v8 standardises the references to "supplier B1.3.4" throughout to prevent the two paragraphs being conflated.
The authorisation conditions require fair notice but do not prescribe an exact minimum period. Sector practice in the gas and electricity supply regimes has generally settled around minimum periods of 7 to 28 days depending on circumstances. The appropriate period in any specific case depends on the consumer's situation, the engagement history, and the size of the debt. Operators should adopt a defensible position rather than a rigid uniform deadline.
The conditions do not prescribe a fixed engagement period before escalation can be considered. As an illustrative reference point only, sector practice in the energy supply regimes has often involved engagement periods measured in weeks rather than days, with longer periods where vulnerability factors are present. Avoid embedding a single fixed period in policy as a hard cut-off; what matters is that the period actually applied is proportionate to the specific consumer's circumstances and is documented as such.
The B9.14 prohibitions operate where the operator knows, or ought reasonably to know, that a trigger applies. This is not a strict-liability test of household composition but a knowledge-based test of the operator's position. Reasonable enquiry, documentation of what was asked and what was answered, and willingness to revisit a decision when new information emerges all bear on whether the operator should have known. The framework neither requires omniscience nor permits wilful ignorance.
The classification of supply arrangements as direct, intermediary, or onward-sale is fact-specific and depends on the contractual documentation and the regulatory registration position. The summary in the Bulk supply and B2B arrangements section earlier in this guide covers the main patterns but cannot anticipate every configuration. Operators with mixed estates should take legal advice at the network registration stage rather than case by case.
This guide is for operational use. It does not constitute legal or regulatory advice. Where the application of any particular provision is genuinely uncertain, or where the consumer's circumstances raise questions that this guide does not resolve, the operator should refer to the binding text of the authorisation conditions, to the Ofgem consumer protection guidance, and where necessary to a suitably qualified legal or regulatory adviser.
Operators using this guide should validate its application to their specific operations against the primary source. The relevant Ofgem documents are Heat networks regulation: authorisation conditions decision and Heat networks regulation: consumer protection guidance, both published 13 January 2026 and available on Ofgem's website at ofgem.gov.uk.
The following items make up the documentary record an operator should be able to produce for any case that reaches disconnection. Operators may find it useful to use this as a case-file completion check before any final notice is issued, and to retain the completed checklist as part of the case file itself.
Heat Network Compliance is a specialist SaaS compliance platform for UK heat network operators and suppliers, developed by Sorted-IT (UK) Ltd. The platform provides bespoke, board-ready compliance policy documentation mapped to the full suite of Ofgem Authorisation Conditions as finally determined on 13 January 2026. For further information, visit heatnetworkcompliance.co.uk.
This document is for information only. It does not constitute legal or regulatory advice. Heat network operators and suppliers should develop their compliance arrangements with reference to the current final Authorisation Conditions and Ofgem's published guidance, and where necessary with the support of suitably qualified legal or regulatory advisers.
McDonald, H. (2026). Debt Handling Decision Guide for UK Heat Networks: Practical Operational Guide. Version 8. Heat Network Compliance / Sorted-IT (UK) Ltd.
When does an operator have to start the B9 debt-handling pathway?
The B9 pathway engages on either of two bases. First, where the operator becomes aware, or has reason to believe, that a domestic heat consumer is having or will have payment difficulty (B9.3). Second, when one of the specific timing triggers in B9.5 is reached: no later than two missed monthly payments, one missed quarterly payment, or the consumer's own statement that they cannot make the next scheduled payment. Either basis engages the regulated pathway regardless of any internal arrears threshold the operator may apply.
What is the B9.12 statutory precondition before disconnection?
B9.12 prohibits disconnection of a domestic heat consumer for unpaid charges unless the operator has first taken all reasonable steps to recover those charges through the B9.6.1(b) prepayment route, where prepayment is safe and reasonably practicable. The legal test is "all reasonable steps", which is fact-specific. In a typical case the evidence will show that consensual prepayment was offered (and refused or accepted-but-not-honoured), and that non-consensual prepayment under B10.9 was either not viable or was viable but disconnection was chosen on documented reasoning.
Who is protected by the B9.14 disconnection prohibitions?
Two categories of household are protected. Year-round, B9.14 prohibits disconnection for non-payment where any occupant has a medical condition requiring year-round heating or hot water. During the winter period (October to March inclusive), the prohibition also covers households containing any person under 2, over 75, disabled, terminally ill, or chronically sick. The B9.15 obligation requires the operator to take reasonable steps to ascertain whether these triggers apply rather than rely on absence of consumer disclosure.
What are the three B9.6 services an operator must offer in writing?
An operator must offer in writing: (a) a facility for the consumer to pay charges by regular instalments; (b) a facility to pay by prepayment meter where it is safe and reasonably practicable; and (c) information about reducing charges through efficiency measures. Debt-advice signposting sits under B9.8 / B5 and is a distinct obligation from the B9.6 services. Treating signposting as a B9.6 service is a regulatory misclassification.
Does B9 apply to bulk supply and B2B heat network arrangements?
The B9 framework directly applies to operators recovering against domestic heat consumers. Where the operator's contract is with an intermediary (freeholder, managing agent, housing association) on a B2B basis, the recovery action against the intermediary is generally outside B9. However, B9.16 may still restrict disconnection of a downstream heat network where domestic consumers would be affected, creating protections broadly analogous to B9.14 in the bulk-supplier context. Operators should classify each network connection by its contractual structure as standing operational discipline.
What is the difference between consensual and non-consensual prepayment under B10?
Consensual prepayment under B9.6 / B10 requires explicit consent at the A3 standard (CPG 6.59): written or recorded, dated, retained, and not given under pressure. Non-consensual prepayment under B10.9 applies where the consumer has not consented but a prepayment meter can be installed remotely (CPG 6.51 confirms involuntary installation applies only to remote switching). B10.9 has two gateway conditions (no access required; explicit consent absent) and six mandatory requirements covering prior engagement, ability-to-pay basis, vulnerability triggers, suitability, and documentation. There are no powers of entry for debt management (CPG 6.60).
What happens if a debt is partly disputed when the operator wants to escalate?
A dispute does not have to be formally lodged with the Energy Ombudsman to count as unresolved — a clearly raised challenge to the bill that the operator has not yet addressed is enough. The disputed element should not ordinarily be relied upon as the basis for recovery action. Resolve the disputed element first under condition B4 (Complaints). Action on the undisputed remainder of any debt may continue, but a disconnection pursued where the underlying debt is wholly or substantially in dispute is liable to be reversed and to trigger consumer redress.
Does B9.13 mean credit limiting counts as disconnection?
Yes. Where a credit limit imposed by the operator stops the supply and the consumer is not on a prepayment meter, B9.13 treats this as disconnection for the purposes of the framework. Operators sometimes use credit limiting as a less-formal alternative to disconnection on the assumption that it sits outside the B9 framework; B9.13 closes that route. The full Phase 2 process — including B9.14 trigger checks and senior sign-off — applies to credit limiting in the same way as to physical disconnection.
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Download: The Operator's Guide to B9 (PDF)Citation: McDonald, H. (2026). The Operator's Guide to B9: Debt Handling Under the Ofgem Authorisation Conditions. Version 8. Heat Network Compliance / Sorted-IT (UK) Ltd. Available at: https://heatnetworkcompliance.co.uk/white-papers/debt-handling-decision-guide
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