CIH has worked closely with sector partners, including the National Housing Federation, Local Government Association, The Heat Network, and independent heat network consultancy Chirpy Heat, to understand the steps social housing providers should be taking.
The actions that housing providers should immediately be taking is as follows in four steps.
CIH has developed these four steps based on expert information provided by the heat network consultancy Chirpy Heat, and on information from some of the other sources of information cited throughout these pages, especially from Trowers and Hamlin. This is not intended to serve as a definitive ‘how to’ or roadmap for achieving compliance, as this will be different for different organisations. However, it does include the key steps that housing organisations and professionals should be taking to work towards full compliance, along with links to further sources of advice and information.
This page does not constitute legal advice and CIH recommends you seek expert advice from heat network consultancies or legal advisors to support you with compliance.
Very few social housing providers will be fully compliant in January 2026, and it is important to note that Ofgem will not expect this from day one. If you have not started to, the most critical thing is to understand if you will be a regulated entity, and if so, in what way, and then take steps to understand your data and compliance gaps. This should include:
- Understanding if you are in scope of the regulations, and if you are, your heat network portfolio. This will involve internal work to know how many heat networks you have; whether they are communal or district; if you are the heat network operator and/or supplier for each one; and what granularity of data you already have that can speak to how compliant you are with the authorisation conditions.
- Understanding the regulation. This will involve closely reading the authorisation conditions and associated guidance, and potentially bringing in third parties (e.g. heat network consultancies and legal advisors) to support you with this, and to help you understand gaps in your current compliance.
- Make sure your board, executive team, and compliance teams are aware of the introduction of regulation, and are aware that action is required to comply.
There are initial requirements of the regulation that you should prioritise. In particular, you should:
- Ensure that you are registered with the Energy Ombudsman.
- Ensure that you are providing clear, transparent information to residents supplied by a heat network about their rights and the new consumer protections, including the role of Citizens Advice as the independent consumer advocate.
- Review your:
- Pricing, tariffs, and heat services charges alongside Ofgem’s guidance on fair pricing.
- Existing complaints process to understand how it will need to be adapted to be compliant with Ofgem’s complaints authorisation condition.
- How operation and supply of heat is currently managed on your schemes (including any contractual arrangements with operation and maintenance contractors or metering and billing providers) and how this will need to change to comply with the regulations.
- Existing leases and tenancy agreements to determine if they are appropriate or whether separate (or updated) heat supply agreements are required.
- Data collection and management procedures, especially for data that is required by Ofgem’s reporting schedules.
- Existing processes, policies, and procedures more generally, against the authorisation conditions, to understand gaps in your current compliance.
This should include a strategy for how and when you will achieve full compliance. It should have executive and board backing, and a senior responsible owner at executive level. It should also include how you intend to resource and meet staffing requirements; what budget will be allocated for achieving compliance; support for existing staff to upskill; and appropriate oversight, governance, and monitoring procedures.
Your plan should be a roadmap for how your organisation will be fully compliant with Ofgem’s regulatory regime, and by when.
In delivering your plan, you will need to focus on ensuring you are collecting the data to demonstrate to Ofgem you are compliant (even if you are not compliant now), and maximising external funding opportunities, such as:
- The Heat Training Grant, which offers government funded heat network training.
- The Heat Network Efficiency Scheme (HNES), which provides grant funding to support performance improvements to existing/ operational district heating and communal heating projects.
