By Peter Horne, Head of Compliance at FairHeat

When we think about our children: do we want them to be ready to succeed in school or do we want them to be equipped to thrive in the outside world?

The answer for most parents will be that we want both.

Most parents want their children to achieve in measurable outcomes like their exams.

However, they also know that a child’s overall development is determined by providing extra-curricular opportunities which build character, resilience and deeper learning as these also help gear up children to succeed outside of school.

And over and above this they want their children to be happy and healthy.

It is a similar situation in the work of heat networks, where social landlords need to pass all the tests to meet forthcoming regulations, and at the same time create reliable, well-maintained heat networks which deliver a warm, happy and healthy environment for residents over the long-term.

As well as meeting the new consumer regulations, social landlords also need to consider preparing their heat networks to be ready for the upcoming Heat Network Technical Assurance Scheme (HNTAS). HNTAS will set new minimum performance regulations for networks and ensure that their residents have fair outcomes.

Some asset owners might look at these new regulations as box ticking exercises where they are happy to do the minimum required to earn certification. As technical authors of HNTAS we can assure the industry that this is not about ticking boxes.

We believe delivering new and improving existing heat networks are opportunities to create strong processes so that heat networks continue to thrive over the long-term and deliver good outcomes for customers and investors. However, we would also encourage operators to go beyond the minimum to deliver better outcomes for both asset owners and heat networks customers.

In reality it makes sense for social landlords to set up their heat networks to achieve regulatory readiness for both consumer protection and HNTAS, and also to achieve real-world performance which exceeds the minimum where possible.

The size of the challenge for social landlords

Over the next 12 months new consumer protection regulations will come into force for social housing residents who are connected to heat networks.

This is an important and welcome step for an estimated half a million households – 180,000 of which are believed to be living in social homes connected to heat networks  – as it means all residents will benefit from energy meter readings, transparent billing, fair pricing and complaint resolution when Ofgem begin regulating heat networks from late January onwards.

Low-carbon heat networks have an increasingly important role to play in helping the UK to become more energy independent and to help reduce emissions.

However, while the new regulations are welcome this will also create new challenges for social housing landlords.

From today <<27 January 2026>>, all existing heat networks will be deemed temporarily authorised by Ofgem.

However, following this, housing associations with heat networks will need to register with Ofgem by January 2027.

Ofgem estimates that 66% of more than 14,000 existing heat networks are owned and managed by social landlords.

If this is accurate this means that social landlords which own or operate more than 9,000 heat networks, will need to register each network with Ofgem.

For some large social landlords this will be a significant undertaking with L&Q currently owning more than 260 heat networks, Peabody more than 200 heat networks and Clarion more than 175 heat networks.

These landlords will then also need to prepare new heat networks to be ready to tackle the new HNTAS regulations in 2027 and for existing heat networks when the Department for Energy Security and Net Zero (DESNZ) confirm the target dates for HNTAS.

Under the new consumer protection regulations, social landlords and/or their managing agents and other partners such as ESCOs will need to be registered to:

• Operate a relevant heat network
• Supply heating, cooling or hot water to heat network consumers.

The heat network operator is expected to have substantial control over key decisions relating to ensuring the long-term reliability, efficiency, and compliance of the heat network and have authority or influence over significant investment decisions, such as those concerning major upgrades, expansions, or fundamental changes to the infrastructure.

Even in instances where social landlords own, but do not operate the heat network, it is still extremely important for them to be aware of the new regulations to ensure the long-term health and reliability of the network and to plan for any potential future upgrades.

While the new regulations may feel like there is a lot information to learn, interpret and act on in a short space of time, social landlords actually have more time to get ready than one might think.

Breaking the new regulations down into smaller, more manageable chunks will help landlords and other asset owners to put an organised process for navigating each element of the new regulations into place.

The key is to know where to start.

Understanding and identifying your organisation’s policy gaps, strong and weak processes, particularly those exposed to new regulations, and which heat networks are underperforming will be a key feature to the early parts of 2026.

By doing this social landlords should be able to identify where these complexities lie (from a technical and consumer protection perspective), providing more time to ensure the correct approach is taken for each individual heat network to the benefit of customers and themselves as asset owners.

FairHeat has developed procedures to streamline compliance elements – enabling social landlords to demonstrate fair pricing, billing elements, vulnerable customer allowances and reporting requirements in a single process.

While this will require many social landlords and asset owners to change their approach, the wave of new regulations means change is inevitable.

The sooner landlords begin this process the more time they have to introduce and embed change before regulations take force in January 2027.

Reviewing policies and updating documents will inevitably be another focus of 2026.

However, the key to becoming compliant will be the implementation and governance of those processes.

And the key to delivering reliable heat networks is in delivering simpler, well-engineered and well-maintained heat networks which have been optimised for their performance.

While there is a lot of change due to take place, which may seem a bit overwhelming, we are advising our social landlord partners that it will be much smoother and easier to start early and navigate the changes slowly rather than trying to cram everything into January 2027.