Heat Network Regulation for Landlords: Are You Now a Regulated Heat Supplier?

If your building has a communal boiler, a shared heat pump or a connection to a district heating scheme, and you recharge tenants or residents for the heat, you may now be a regulated energy supplier. That surprises a lot of landlords, because for years heat networks were barely regulated at all.

That changed on 27th January 2026, when Ofgem began regulating heat networks across Great Britain under the Heat Networks (Market Framework) (Great Britain) Regulations 2025. Existing networks were given temporary “deemed authorisation” to carry on while the system is phased in, but the clock is running. Operators and suppliers need to register with Ofgem by 27th January 2027.

Here is what the rules mean in practice, who they catch, and what to do between now and the deadline.

Does this apply to you?

The regulations apply to “relevant heat networks”, which come in two forms:

• District heat networks, supplying two or more buildings
• Communal heat networks, supplying a single building divided into separate premises, such as a block of flats, a mixed-use development or a multi-tenant commercial building

Two roles are regulated, and you may well hold both:

• The operator controls the transfer of thermal energy and has substantial control over decisions that affect how reliable and efficient the network is.
• The supplier manages the commercial relationship with the people receiving heat: charges, billing and customer service.

One point catches landlords out. Law firm Bevan Brittan notes that being a supplier is not limited to having a formal heat supply agreement, and can extend to arrangements under leases, tenancy agreements or service charges. If you recover heating costs from occupiers in any of those ways, check your position against Ofgem’s guidance or take advice.

Some arrangements are outside the rules. Ofgem’s guidance on who needs to register lists houses in multiple occupation with single-dwelling-capacity shared heating, building conversions with a heating capacity of 45kWth or less, single buildings with non-self-contained shared facilities, and third-party waste heat producers. Self-supply, industrial and shared ground loop networks are in scope but with reduced obligations. If you think one of these applies to you, confirm it against the guidance rather than assuming.

The rules reach beyond residential, but not evenly. Registration asks you to declare your customers as domestic, non-domestic, small business or microbusiness, so a commercial landlord supplying heat to tenants is not automatically outside scope. However, Ofgem’s consumer protection conditions apply to domestic, microbusiness and small business customers. Larger non-domestic customers are treated differently, so a landlord whose tenants are mostly large businesses may find the day-to-day consumer duties apply less widely than the registration duty does.

The timeline

What you need to do

1. Register with Ofgem. You will need details of your organisation, technical details of each network, customer numbers by type, continuity plans, your complaints procedure and, if you are a supplier, how you identify vulnerable customers. Ofgem has said registration is not an approval process. It confirms your status and sets a baseline. The obligations come from the authorisation conditions that follow.
2. Join the Energy Ombudsman scheme if you are a supplier. Residents and tenants can take unresolved complaints to the Energy Ombudsman, and suppliers register separately with its heat network scheme.
3. Set up consumer protections. Expect to need transparent, easy-to-understand bills, a clear complaints process, a Priority Services Register for vulnerable customers, and fair pricing. Ofgem’s authorisation conditions say charges to consumers must be fair and not disproportionate, and must reflect actual costs. Law firms advising on the rules expect pricing to face reasonableness benchmarking.
4. Document your assets. The authorisation conditions require authorised persons to create and maintain a Material Asset Register early in the initial period, recording the condition and function of the network’s critical assets.
5. Keep meeting the metering rules, and expect billing to be judged by Ofgem. Parts of the Heat Network (Metering and Billing) Regulations 2014 still apply in Great Britain. Networks with buildings classed as viable for metering must keep meters installed and maintained. Several parts were revoked from 27th January 2026: the duty to notify, the billing regulation and its schedule (replaced by Ofgem’s conditions on bill information and transparency), and the provisions allowing heat cost allocators to be used to comply. Buildings previously assessed as not cost-effective to meter no longer have to repeat the assessment. Northern Ireland is different: the 2014 regulations continue in full there.
6. Prepare for technical standards. HNTAS is expected to launch in 2027 and will be mandatory, but consultation proposals phase it in over several years for existing networks, and the detail is not final. Networks that already have good meter data and clear records will find it far easier.

What happens if you don’t?

Ofgem has enforcement powers including financial penalties and compensation orders, and can audit networks. It can impose penalties of up to £1 million or 10% of turnover, whichever is higher. Beyond the fines, the practical risk for most landlords is simpler: a tenant disputes a heating bill, takes it to the Ombudsman, and you cannot show how the charge was worked out.

The common mistakes

• Assuming it only applies to housing associations. Any landlord running qualifying communal or district heating can be caught.
• Assuming “supplier” means a formal contract. Service charges and leases count.
• Treating registration as the finish line. It is the start. Authorisation conditions apply to you as an authorised person, including during the deemed-authorisation period.
• Bills based on estimates. If meters are not read, or do not communicate, you cannot bill on actual use, and you cannot defend the charge.
• No single owner. Registration, complaints, vulnerable customers and meter data usually sit with different people. Ofgem expects someone to be accountable.

Where the data comes in

Nearly every obligation above leans on one thing: being able to show what each customer used and what it cost. Billing on actual consumption needs reliable meter reads. Defending a charge needs the cost data behind it. Handling a complaint needs the history for that property. Planning for HNTAS needs performance data for the network as a whole.

Most landlords have some of this, scattered across a meter reading portal, a managing agent’s spreadsheet and a supplier invoice. The work is bringing it together so one person can answer “why was this resident’s bill that amount?” in minutes rather than weeks.

Your next steps

1. List every building where you provide communal or district heating, hot water or cooling.
2. For each one, decide whether you are the operator, the supplier or both. Check leases, tenancy agreements and service charge provisions.
3. Check each network against the exemptions in Ofgem’s guidance.
4. Find out who owns registration, complaints and vulnerable customers in your organisation.
5. Audit your meters: which are working, which are read, which bills are estimated.
6. Put 27th January 2027 in the diary, and aim to register well before it.

How Enerlytic helps

Enerlytic can help with the whole process, not just the metering. On the data side, we bring consumption data from your electricity, gas, water and heat meters, and from your bills, into one place. You can see what each site and supply used, spot heat meters that have stopped reporting, and produce the evidence behind a charge when a resident or tenant asks for it. Beyond the data, we can help you work through the registration process with Ofgem and get ready for the rules that follow. If you’d like help, get in touch and we’ll talk through where your estate stands.

Need help with heat network registration or metering? Get in touch at www.enerlytic.co.uk. Not sure where your estate stands on meter data? Our Energy Diagnostic reviews your data and tells you where the gaps are. Book a free 30-minute demo at www.enerlytic.co.uk.