Heat networks regulation: registration guidance
Summary
Ofgem publishes guidance on registering heat networks under new regulatory framework taking effect January 2026. Heat network operators and suppliers with deemed authorisation must register by end of initial period through new digital service launching spring 2026. Framework covers district and communal heat networks supplying multiple buildings or separate premises within buildings.
Key facts
- •Registration required for heat networks serving 2+ buildings (district) or separate premises in single building (communal)
- •Digital service launches spring 2026 for registration submissions
- •Registration deadline: end of first part of initial period
- •Exemptions include HMOs and converted buildings with domestic heating ≤45kW
- •Multiple operators must nominate single contact point with Ofgem
Timeline
Memo10,000 words
We are consulting on our draft guidance for heat networks registration. This guidance supports authorised persons undertaking operation or supply on a relevant heat network during the first part of the initial period. It explains roles and responsibilities, registration requirements, and obligations under the Registration and Nominated Operator authorisation conditions. It also includes specific guidance for registering Shared Ground Loop (SGL) heat networks and outlines what happens after registration is completed. ## Who should respond We would like views from people with an interest in heat networks and particularly welcome: * heat network operators * heat network suppliers * energy service companies * housing providers * consumer groups * asset owners * metering and billing agents * trade associations ## Background This follows our consultations: * [Heat networks regulation: authorisation and regulatory oversight](https://consult.ofgem.gov.uk/energy-supply/heat-networks-regulation/) which set out our policy on this topic * [Heat networks regulation: authorisation conditions for registration, nominated operator, and notification of changes](https://consult.ofgem.gov.uk/energy-supply/heat-networks-regulation-authorisation-conditions/), which covered the associated draft authorisation conditions The draft guidance document is published alongside this consultation and should be considered in conjunction with our updated authorisation conditions included in the [Heat networks regulation: authorisation conditions](https://www.ofgem.gov.uk/consultation/heat-networks-regulation-authorisation-conditions) consultation. Our aim is to support regulated entities to understand the scope of the regulatory framework and their registration obligations. ## Before you start Read the Heat networks regulation: registration guidance consultation document. You'll find it in the 'Related' section on this page. Please refer to this document when giving us your views. ## Why your views matter Your feedback will help shape the final guidance to ensure it works effectively. The guidance aims to provide clarity on roles, responsibilities, and registration requirements for heat networks under the regulated framework. --- Consultation Heat networks regulation: registration guidance Publication date: 17 November 2025 Response deadline: 15 December 2025 Team: Email: Heat Networks HeatNetworksRegulation@ofgem.gov.uk We are consulting on our draft guidance for heat networks registration. The guidance sets out the roles, responsibilities, and obligations for authorised persons that are operating or supplying a relevant heat network during the first part of the initial period, as set out in regulation 26 of the Heat Networks (Market Framework) Regulations 2025 (the regulations), and are therefore required to complete heat network registration. This follows our consultations: • Heat networks regulation: authorisation and regulatory oversight which set out our policy on this topic • Heat networks regulation: authorisation conditions for registration, nominated operator, and notification of changes, which covered the associated draft authorisation conditions The draft guidance document is published alongside this consultation and should be considered in conjunction with our updated authorisation conditions included in the Heat networks regulation: authorisation conditions consultation. Our aim is to support regulated entities to understand the scope of the regulatory framework and their registration obligations. We welcome feedback from stakeholders to help refine this guidance and ensure it is clear and fit for purpose. Consultation Heat networks regulation: registration guidance © Crown copyright 2025 The text of this document may be reproduced (excluding logos) under and in accordance with the terms of the Open Government Licence. Without prejudice to the generality of the terms of the Open Government Licence, the material that is reproduced must be acknowledged as Crown copyright and the document title of this document must be specified in that acknowledgement. This publication is available at www.ofgem.gov.uk. Any enquiries regarding the use and re-use of this information resource should be sent to psi@nationalarchives.gsi.gov.uk. 2 Consultation Heat networks regulation: registration guidance Contents 1. Introduction .................................................................................................... 4 Purpose of this consultation ..................................................................................... 4 Context and related publications .............................................................................. 5 Overview ................................................................................................................. 5 Consultation stages ................................................................................................. 6 How to respond ....................................................................................................... 6 Your response, data, and confidentiality .................................................................... 6 How to track the progress of a consultation ............................................................... 7 2. Scope of heat networks regulation ................................................................... 8 Context ................................................................................................................... 8 3. Registration .................................................................................................... 9 Context ................................................................................................................... 9 4. Heat networks with multiple operators .......................................................... 10 Context ................................................................................................................. 10 Next steps ........................................................................................................ 11 Send us your feedback ...................................................................................... 12 Appendix 1. Privacy policy ............................................................................ 13 Personal data ........................................................................................................ 13 Consultation Heat networks regulation: registration guidance 1. Introduction This section explains the purpose of the consultation and how guidance for heat network registration fits in the context of our new regulatory responsibilities for heat networks. Links are provided to related documents that may be useful to stakeholders. Under section 217 (1) of the Energy Act 2023, the Gas and Electricity Markets Authority (GEMA), the governing body of Ofgem, is appointed as the regulator for heat networks in England, Scotland, and Wales (Great Britain). Our Forward Work Programme outlines the work we are doing in 2025 and 2026, including preparations for our new regulatory responsibilities for heat networks and implementation of the new regulatory regime in January 2026. This consultation forms part of that preparation by seeking stakeholder views on guidance for registration. Registration is a key step in the transition to regulation of the heat networks market and will enable us to gather the information necessary to fulfil our role in securing positive outcomes for heat network consumers. Purpose of this consultation From January 2026, heat network suppliers and operators will have to comply with the obligations set out in authorisation conditions, including Registration with the Authority. We are seeking views on our draft guidance for heat networks registration to ensure it clearly informs authorised persons operating or supplying a relevant heat network during the first part of the initial period. Our aim is to support understanding of the registration obligations and the necessary steps to complete the process. We would like views from people with an interest in heat networks and particularly welcome responses from: • heat network operators • heat network suppliers • energy service companies • housing providers • consumer groups • asset owners • metering and billing agents • trade associations We also welcome responses from other stakeholders with an interest in heat network regulation, and the general public. We are also seeking views from stakeholders involved in Shared Ground Loop (SGL) heat networks and heat networks with multiple operators about sections of the draft guidance that cover these specific issues. 4 Consultation Heat networks regulation: registration guidance Context and related publications The Heat Networks (Market Framework) Regulations 2025 establish the regulatory regime for heat networks, overseen by us. The regulations set out timings relevant to this consultation such as authorisation conditions coming into effect from 27 January 2026, and the first part of the initial period. The draft guidance is based on policy already confirmed through: • Heat networks regulation: implementing consumer protections (the 2024 government consultation), published jointly with the Department for Energy Security and Net Zero (DESNZ) • Heat networks regulation: authorisation and regulatory oversight (the 2024 consultation), which set out the policy framework and process for heat network registration. An initial set of authorisation conditions accompanied these consultations and were revised following stakeholder feedback before publication as updated draft versions alongside respective consultation decision documents. Draft authorisation conditions related to the draft guidance for heat network registration have been consulted on as part of Heat networks regulation: authorisation conditions for registration, nominated operator, and notification of changes. Updated draft authorisation conditions were also published in the consultation response. The consultation, Heat networks regulation: authorisation conditions, seeks feedback on the full suite of authorisation conditions that will come into effect from 27 January 2026, including those that have been consulted on separately over the last year. We have recently published the following consultations on guidance for other heat networks policy areas: • Heat networks regulation: authorisation conditions and guidance on measures to mitigate the risk and impact of financial failure • Heat networks regulation: consumer protection guidance • Heat networks regulation: fair pricing protection guidance Overview The draft guidance for heat network registration explains the scope of the regulatory framework and the requirement to register, including the information that must be submitted as part of registration and the steps to be taken once registration is complete. It covers the obligations for both operators and suppliers, clarifies the distinction between different types of heat networks, and outlines exemptions from regulation. The guidance also provides specific information for registering Shared Ground Loop (SGL) heat networks and details the responsibilities where multiple entities are involved in the operation of a network. 5 Consultation Heat networks regulation: registration guidance Consultation stages Stage 1 Consultation open: 17 November 2025 Stage 2 Consultation closes for responses (awaiting decision): 15 December 2025 Stage 3 Responses reviewed and published: 23 January 2026 Stage 4 Publication of guidance: 23 January 2026 How to respond We want to hear from anyone interested in this consultation. We have asked for your feedback in each of the questions throughout. Please respond to each one as fully as you can. We will publish non-confidential responses on our website. Your response, data, and confidentiality You can ask us to keep your response, or parts of your response, confidential. We will respect this, subject to obligations to disclose information. For example, under the Freedom of Information Act 2000, the Environmental Information Regulations 2004, statutory directions, court orders, government regulations, or where you give us explicit permission to disclose. If you do want us to keep your response confidential, please clearly mark this on your response and explain why. If you wish us to keep part of your response confidential, please clearly mark those parts of your response that you do wish to be kept confidential and those that you do not wish to be kept confidential. Please put the confidential material in a separate appendix to your response. If necessary, we will contact you to discuss which parts of the information in your response should be kept confidential and which can be published. We might ask for reasons why. If the information you give in your response contains personal data under the General Data Protection Regulation (Regulation (EU) 2016/679) as retained in domestic law following the United Kingdom's withdrawal from the European Union ("UK GDPR"), the Gas and Electricity Markets Authority will be the data controller for the purposes of GDPR. Ofgem uses the information in responses in performing its statutory functions and in accordance with section 105 of the Utilities Act 2000. Please refer to our Privacy Notice on consultations, see Appendix 1. If you wish to respond confidentially, we will keep your response confidential, but we will publish the number, but not the names, of confidential responses we receive. We will not link responses to respondents if we publish a summary of responses, and we will evaluate each response on its own merits without undermining your right to confidentiality. 6 Consultation Heat networks regulation: registration guidance How to track the progress of a consultation 1. Find the web page for the call for input you would like to receive updates on. 2. Click ‘Get emails about this page’, enter your email address and click ‘Submit’. 3. You will receive an email to notify you when it has changed status. A consultation has three stages: ‘Open’, ‘Closed (awaiting decision)’, and ‘Closed (with decision)’. 7 Consultation Heat networks regulation: registration guidance 2. Scope of heat networks regulation This section includes the consultation question and provides context for the section of the draft guidance that covers scope of heat networks regulation. Questions Q1. Do you agree with the proposed guidance for the scope of heat networks regulation? Please explain your answer, including any suggestions to improve clarity, scope or detail. Context 2.1 The guidance for the scope of heat networks regulation explains key definitions and parameters of the regulatory framework that are established in the relevant legislation and have been covered in previous consultations such as the 2024 consultation. 2.2 By clarifying the definitions of key terms and how regulatory responsibility applies in relation to physical network infrastructure, we intend that all parties involved with a heat network will understand their role and the principles underpinning the regulatory framework. 2.3 The guidance clarifies terms such as ‘regulated activity’, ‘authorised person’, and ‘relevant heat network’, to support entities in identifying whether their activities fall within the scope of regulation. 8 Consultation Heat networks regulation: registration guidance 3. Registering a heat network This section includes the consultation question and provides context for the section of the draft guidance that covers registering a heat network. Questions Q2. Do you agree with the proposed guidance for registering a heat network? Please explain your answer, including any suggestions to improve clarity, scope or detail. Context 3.1 Registration is part of the transitional provisions for implementing heat networks regulation. Entities carrying out regulated activities can continue operating as they are brought into the regulatory framework. We consulted on proposals for the registration process in 2024 consultation and confirmed these policy positions in our 2025 decision. 3.2 Under the regulations, entities operating or supplying on a relevant heat network during the first part of the initial period are deemed authorised. They must register their heat networks and activities before the end of this period, in line with the draft Registration with the Authority authorisation condition, which we are consulting as part of the full suite of conditions currently. These conditions will come into effect from 27 January 2026. 3.3 Registration is not an authorisation assessment. Its purpose is to enable Ofgem to gather information about existing heat networks, operators, and suppliers. This will help us identify networks, understand current practices, and establish a baseline for monitoring and compliance. 3.4 Operators and suppliers must register each heat network and provide network- specific details. Some information, such as organisation contact details or suitability of senior personnel, does not need to be resubmitted for each network. 3.5 Registration will be completed through a digital service expected to launch in spring 2026. The draft guidance provides high-level information about this service, and we will develop detailed resources to assist navigation before launch. 9 Consultation Heat networks regulation: registration guidance 4. Heat networks with multiple operators This section includes the consultation question and provides context for the section of the draft guidance that covers heat networks with multiple operators. Questions Q3. Do you agree with the proposed guidance for heat networks with multiple operators? Please explain your answer, including any suggestions to improve clarity, scope or detail. Context 4.1 We outlined the advantages of being able to engage with a single party on regulatory matters related to the role of operator through: 4.2 the 2024 consultation 4.3 Heat networks regulation: authorisation conditions for registration, nominated operator, and notification of changes 4.4 We determined that requiring one operator to act as a single point contact is the most practical way of approaching regulatory engagement for heat networks with complex arrangements in the existing market. 4.5 We confirmed that where an operator is nominated as the single point of contact, they will not assume the regulatory responsibility of other operators but will be required to promptly share information and notifications between those operators and Ofgem. The other operators with deemed authorisation under the regulations will remain authorised persons and will need to comply with the general authorisation conditions from 27 January 2026. 4.6 The draft guidance explains these requirements that are set out in the Nominated operator authorisation condition. 4.7 The Nominated operator draft authorisation condition has been consulted on as part of Heat networks regulation: authorisation conditions for registration, nominated operator, and notification of changes and is included in the consultation, Heat networks regulation: authorisation conditions, with the full suite of authorisation conditions that will come into effect from 27 January 2027. 10 Consultation Heat networks regulation: registration guidance Next steps Following this consultation, we will finalise the guidance for heat network registration, incorporating the feedback received from stakeholders. The guidance will be published along with our consultation decision in late January 2026. 11 Consultation Heat networks regulation: registration guidance Send us your feedback We believe that consultation is at the heart of good policy development. We are keen to receive your comments about this consultation. We would also like to get your answers to these questions: • Do you have any comments about the quality of this document? • Do you have any comments about its tone and content? • Was it easy to read and understand? Or could it have been better written? • Are its conclusions balanced? • Did it make reasoned recommendations? • Do you have any further comments? Please send your feedback to stakeholders@ofgem.gov.uk. 12 Consultation Heat networks regulation: registration guidance Appendix 1. Privacy policy Personal data The following explains your rights and gives you the information you are entitled to under the General Data Protection Regulation (GDPR). Note that this section only refers to your personal data (your name address and anything that could be used to identify you personally) not the content of your response to the consultation. 1. The identity of the controller and contact details of our Data Protection Officer The Gas and Electricity Markets Authority is the controller, (for ease of reference, “Ofgem”). The Data Protection Officer can be contacted at dpo@ofgem.gov.uk 2. Why we are collecting your personal data Your personal data is being collected as an essential part of the consultation process, so that we can contact you regarding your response and for statistical purposes. We may also use it to contact you about related matters. 3. Our legal basis for processing your personal data As a public authority, the GDPR makes provision for Ofgem to process personal data as necessary for the effective performance of a task carried out in the public interest. i.e. a consultation. 4. Your rights The data we are collecting is your personal data, and you have considerable say over what happens to it. You have the right to: • know how we use your personal data • access your personal data • have personal data corrected if it is inaccurate or incomplete • ask us to delete personal data when we no longer need it • ask us to restrict how we process your data • get your data from us and re-use it across other services • object to certain ways we use your data • be safeguarded against risks where decisions based on your data are taken • • • entirely automatically tell us if we can share your information with 3rd parties tell us your preferred frequency, content and format of our communications with you to lodge a complaint with the independent Information Commissioner (ICO) if you think we are not handling your data fairly or in accordance with the law. You can contact the ICO at https://ico.org.uk/, or telephone 0303 123 1113. 5. Your personal data will not be sent overseas 13 Consultation Heat networks regulation: registration guidance 6. Your personal data will not be used for any automated decision making. 7. Your personal data will be stored in a secure government IT system. 8. More information for more information on how Ofgem processes your data, click on the link to our “ofgem privacy promise”. 14 --- Guidance Heat network registration (draft guidance) Publication date: 17 November 2025 Team: Email: Heat Networks HeatNetworksRegulation@ofgem.gov.uk This guidance is for authorised persons operating or supplying a relevant heat network during the first part of the initial period, as set out in regulation 26 of the Heat Networks (Market Framework) Regulations 2025 (the regulations), and therefore required to complete heat network registration. This guidance explains roles and responsibilities under the heat networks regulatory framework and outlines the obligations set out in the Registration with the Authority authorisation condition. It also details the information that must be submitted as part of registration and describes what happens after a registration has been completed. It also explains obligations under the Nominated operator authorisation condition that apply where more than one entity is undertaking the regulated activity of operation of a relevant heat network. This guidance is not relevant to authorised persons who have commenced regulated activity after the first part of the initial period. 1 Guidance Heat network registration (draft guidance) © Crown copyright 2025 The text of this document may be reproduced (excluding logos) under and in accordance with the terms of the Open Government Licence. Without prejudice to the generality of the terms of the Open Government Licence, the material that is reproduced must be acknowledged as Crown copyright and the document title of this document must be specified in that acknowledgement. This publication is available at www.ofgem.gov.uk. Any enquiries regarding the use and re-use of this information resource should be sent to psi@nationalarchives.gsi.gov.uk. 2 Guidance Heat network registration (draft guidance) Contents 1. Introduction .................................................................................................... 4 Scope ..................................................................................................................... 4 Purpose .................................................................................................................. 4 Context and related publications .............................................................................. 4 Updates to this guidance .......................................................................................... 5 2. Scope of heat networks regulation ................................................................... 6 The regulated activities............................................................................................. 6 Definition of a relevant heat network ......................................................................... 7 Exemptions from regulation ...................................................................................... 8 Connected heat networks ........................................................................................ 9 3. Registering a heat network ............................................................................ 10 Overview ............................................................................................................... 10 Who needs to register ............................................................................................ 10 How to register ...................................................................................................... 10 Detailed information requirements for registration ................................................... 13 Registering a Shared Ground Loop (SGL) heat network ............................................. 16 Next steps following registration ............................................................................. 16 4. Heat networks with multiple operators .......................................................... 18 Nominating an operator .......................................................................................... 18 Responsibilities ..................................................................................................... 18 Send us your feedback ...................................................................................... 19 3 Guidance Heat network registration (draft guidance) 1. Introduction Ofgem is the designated regulator for heat networks in England, Scotland, and Wales (Great Britain). Under the Heat Networks (Market Framework) Regulations 2025 (the regulations), any person undertaking regulated activity on a relevant heat network from 1 April 2025 is required to be authorised. From 27 January 2026, a range of authorisation conditions on consumer protection and supporting regulatory provisions come into effect and authorised persons are required to comply with them. Scope This guidance explains the scope of heat networks regulation including key definitions, clarification on what activity the regulations apply to, and how responsibilities map to the physical boundaries of heat networks. The guidance: • covers the requirement to register set out in the Registration with the Authority authorisation condition, which applies to persons who are deemed authorised under the regulations • provides an overview of how regulated entities must register their heat network activities with us and sets out the information that must be provided through this process. • details what regulated entities should do following registration and points to • information on further obligations under the regulatory framework includes information specific to the registration of Shared Ground Loop (SGL) heat networks. The guidance also explains obligations under the Nominated operator authorisation condition which applies to heat network operators of networks where more than one entity is undertaking the regulated activity of operation. Purpose The purpose of this guidance is to help heat network operators and suppliers with deemed authorisation to understand their obligation to register with us. Where there are multiple operators for a heat network, the guidance is intended to assist in understanding obligations that apply under the Nominated operator authorisation condition. This guidance does not apply to regulated activity that commences after the end of the first part of the initial period, and which must be authorised by application to Ofgem. Detailed guidance covering authorisation by application will be published in future. Context and related publications This guidance can be read in conjunction with other related publications: 4 Guidance Heat network registration (draft guidance) • • • • • • the Heat Networks (Market Framework) Regulations 2025, which set out the regulations that govern the framework for heat networks regulation the heat network authorisation conditions, which set out obligations for authorised persons undertaking regulated activity on a heat network the consumer protection guidance, which explains the rules and requirements set out in authorisation conditions relating to consumer protection rules such as Standards of Conduct, quality of service, billing and transparency, back-billing, heat supply contracts, protections for vulnerable consumers, and the security of supply the financial resilience guidance, which explains the rules and requirements set out in the financial resilience authorisation condition the fair pricing and cost allocation guidance, which aims to support heat networks to comply with fair pricing rules that come into effect from January 2026 the regular data reporting guidance, which is intended to help operators and suppliers meet requirements outlined in the authorisation condition for Provision of information to the Authority. Updates to this guidance This guidance may be updated from time to time following consultation with stakeholders on proposed changes. 5 Guidance Heat network registration (draft guidance) 2. Scope of heat networks regulation The regulated activities 2.1 Under the regulations, authorisation is required to undertake regulated activity on a relevant heat network. The regulated activities are: • operating a relevant heat network (operation) • supplying heating, cooling or hot water to heat network consumers by means of a relevant heat network (supply) 2.2 In this guidance, we refer to the entity undertaking operation as the ‘operator’ and the entity undertaking supply as the ‘supplier’. 2.3 While these roles are distinct in regulatory terms, it is common in practice for a single entity to act as both the operator and the supplier for a heat network. Where this is the case, the entity will be subject to the obligations associated with both roles under the regulatory framework. 2.4 It is important that all parties involved with a heat network assess their activities carefully against the regulatory definitions to determine whether they are acting as a supplier, an operator, or both. This will influence the information and evidence they are required to provide during the registration process and the ongoing compliance obligations they must meet. 2.5 We have used ‘regulated entity’ throughout this guidance to refer to an entity which undertakes either of or both regulated activities. Operation 2.6 Operating a relevant heat network means controlling the transfer of thermal energy on that heat network for the purposes of supplying heating, cooling or hot water. 2.7 A heat network operator is generally expected to have substantial control over key decisions relating to ensuring the long-term reliability, efficiency, and compliance of the heat network. 2.8 This generally includes having authority or influence over significant investment decisions, such as those concerning major upgrades, expansions, or fundamental changes to the infrastructure. 2.9 Ownership of network assets may indicate a level of substantial control but may not necessarily determine the role of operator. The operator will be the entity that has sufficient control over the material assets used or needed to comply with the regulatory framework. 6 Guidance Heat network registration (draft guidance) Supply 2.10 An entity is undertaking the regulated activity of supply where they are responsible for providing heating, cooling, or hot water to customers via a relevant heat network. 2.11 A supplier is expected to hold a contractual relationship with their heat network customers, through a heat supply agreement or other agreement. 2.12 A supplier is responsible for managing the commercial arrangements associated with the supply of thermal energy on a heat network such as setting charges, issuing bills, providing customer service and handling complaints. 2.13 All parties should ensure they assess their activities against the regulatory definitions to determine whether supplier obligations apply. Definition of a relevant heat network 2.14 The terms ‘heat network’, ‘relevant heat network’, ‘communal heat network’, and ‘district heat network’, used in this section are defined in section 216 of the Energy Act 2023. Relevant heat network 2.15 A heat network is a network that, by distributing a liquid or a gas, enables the transfer of thermal energy for the purpose of supplying heating, cooling or hot water to a building or persons in that building, and includes any appliance the main purpose of which is to heat or cool the liquid or gas. 2.16 While the term 'heat network' is used broadly to describe systems that distribute thermal energy, only those classified as ‘relevant’ are subject to regulatory requirements. 2.17 A relevant heat network means a district heat network or a communal heat network. 2.18 The heat network definition may include networks that are designed to rely wholly or in part on heat pumps specific to the buildings or premises served by the network. District heat network 2.19 A district heat network is a heat network that supplies heating, cooling or hot water to two or more buildings. 2.20 A district heat network may be located within a single site or development or may be a larger-scale system distributing heat to multiple sites or separately owned properties and involving multiple authorised entities. 7 Guidance Heat network registration (draft guidance) 2.21 A district heat network may interface with one or more other relevant heat networks such as an embedded communal heat network or a separately owned or managed district heat network. Communal heat network 2.22 A communal heat network is a heat network that supplies heating, cooling or hot water only to a single building divided into separate premises. 2.23 A communal heat network may be a standalone building containing an energy centre or may be embedded in a district scheme from which it is supplied heat. 2.24 A residential block of flats with a communal heating system is a typical example of a communal heat network, however, the definition also includes buildings with a communal heating system that supplies non-domestic customers in separate premises within that building. Exemptions from regulation Houses in Multiple Occupation (HMOs) 2.25 HMOs that consist of a single house or building with shared facilities of a kitchen or bathroom, and where heating is provided through a shared system, are not considered to have separate premises and are therefore exempt from heat networks regulation. 2.26 The regulations explicitly exempt HMOs as defined under paragraphs (a) to (d) of subsection 1 of section 254 of the Housing Act 2004, or that would be included if section 254 extended to Scotland. 2.27 HMOs that are converted blocks of flats as defined under section 257 of the Housing Act 2004, and consist of self-contained flats, are not included under this exemption. If supplied through a shared heating system, this may be a relevant heat network and within the scope of regulation. Converted buildings with domestic heating systems 2.28 If a building has been converted by being divided into separate living accommodation and includes a shared heating system of a domestic capacity, this is exempt from regulation. 2.29 This exemption applies to single converted buildings, as defined in section 254(8) of the Housing Act 2004, that are supplied by no more than one source appliance with a thermal capacity of 45kW or less. 8 Guidance Heat network registration (draft guidance) Connected heat networks 2.30 Where a relevant heat network is connected to another relevant heat network, each network must be individually authorised under the regulations, including where a single entity undertakes operation and supply for both networks. 2.31 This may occur where a district heat network supplies heat to another relevant heat network such as an embedded communal heat network or a separately managed district heat network, potentially consisting of multiple buildings within a single site. 2.32 The physical boundary between connected heat networks, potentially indicated by a building or site meter, will generally also delineate regulatory responsibility between separate entities undertaking operation and supply for each network. 2.33 In applying the consumer protection requirements such as those relating to pricing and reliability, we will consider how a heat network supplied heat from another heat network may be affected. 9 Guidance Heat network registration (draft guidance) 3. Registering a heat network Overview 3.1 Registration is the process by which heat network operators and suppliers with deemed authorisation must formally notify us about their heat networks and the activities they undertake. 3.2 We will use registration to identify regulated entities and their heat networks and establish a compliance baseline. 3.3 The Registration with the Authority heat network authorisation condition sets out the obligation to register, types of information that must be provided, the registration procedure if operation and supply are undertaken by different entities, and requirements for heat networks with multiple operators. 3.4 Regulated entities must complete registration by the end of the first part of the initial period. 3.5 Entities that are required to register have deemed authorisation under the regulations and so the registration process will not affect their authorisation status. Who needs to register 3.6 Regulated entities that began operating or supplying a heat network before 1 April 2025 are automatically authorised under the regulations, referred to as ‘deemed authorisation’, and may continue these activities. Deemed authorisation also applies to regulated activity that is commenced during the first part of the initial period. 3.7 All operators and suppliers with deemed authorisation are required to register their heat networks with us by the end of the first part of the initial period. 3.8 For heat networks where operation and supply are undertaken by separate entities, both parties will be required to submit information relevant to their role to complete registration. 3.9 For heat networks with multiple operators, if a nominated operator has been agreed by parties, this entity will complete registration, submitting information on behalf of the other operators. How to register Digital service for heat networks regulation 3.10 The digital service for heat networks regulation is a centralised platform to support regulatory compliance across Great Britain. 10 Guidance Heat network registration (draft guidance) 3.11 Regulated entities can register their heat networks and activities via the digital service from spring 2026 by submitting required information about their operations, infrastructure, and consumer arrangements. 3.12 Registration via the digital service is designed to be user-friendly and to capture the minimum level information required for the commencement of regulatory oversight. It includes built-in help-text to assist users. Regulatory contact 3.13 When creating an account on the digital service, a ‘regulatory contact’ must be nominated as the designated contact for regulatory purposes. This individual should ideally be the most senior person with responsibility for the heat network’s operations and regulatory compliance. 3.14 To create an account, the regulatory contact will be required to submit information about the regulated entity such as name, type of organisation and contact details. 3.15 The regulatory contact can control user permissions for the account and can invite additional users to access the service and submit information. 3.16 The regulatory contact remains ultimately responsible for ensuring that all submitted information is accurate and complete. Registration as a single entity 3.17 If a single entity is undertaking both regulated activities of operation and supply on a heat network, that entity will be responsible for completing the full registration process. 3.18 The regulated entity will be required to provide detailed information related to the roles of both operator and supplier. 3.19 Information submitted as part of the registration process includes: • details of the entity or organisation • • • the regulated activities being undertaken the type and configuration of the heat network technical information about the energy centre • details about heat network customers • declarations about compliance and practices 11 Guidance Heat network registration (draft guidance) Registration of heat networks with split regulatory responsibility 3.20 For heat networks where operation and supply are undertaken by separate entities, both parties must register via the digital service and provide information about themselves or their organisation and information relevant to their role. 3.21 During the registration process, the operator must confirm whether they also undertake supply on the heat network, or they must identify another entity that does. 3.22 Once the operator has completed their submission, the entity they have identified as the supplier for the heat network will be invited to complete their section of the registration. 3.23 Under the Registration with the Authority authorisation condition, the supplier must co-operate with the operator of the heat network, including by providing relevant information to them, to facilitate the timely discharge of the obligation to register. 3.24 Suppliers cannot complete registration until they are invited to do so. The obligation for the supplier to register is not triggered until the operator has completed their submission. 3.25 If a supplier is unable to register by the end of the first part of the initial period due to a separate entity having not completed the operation component of registration, the supplier should contact us. Registration of heat networks with multiple operators 3.26 For heat networks where multiple parties fulfil the role of operator, all operators that are deemed authorised under the regulations are individually responsible for complying with the requirement to register. 3.27 These parties may however agree for one operator to complete registration and submit information on behalf of the other operators. 3.28 Where such an agreement is reached and registration is completed by the agreed party on behalf of other operators, all operators will have fulfilled the registration requirement. Registration submission 3.29 Following the creation of an account on the digital service, regulated entities are required to provide accurate information about their heat networks and activities through the registration process. Prior to submission, the regulated entity must declare that the information they have provided is correct, to the best of their knowledge. 12 Guidance Heat network registration (draft guidance) 3.30 The digital service will automatically check that all required fields have been completed. When all required information has been provided, the regulated entity may proceed to submit the registration. 3.31 Registration does not involve an assessment or approval process. Once submitted via the digital service, registration of the heat network is complete, and no further action is required by the regulated entity unless advised by us. 3.32 Regulated entities will receive an email acknowledgement following submission, confirming registration has been completed and including a unique ID which should be retained for reference and correspondence. Registration of each heat network will generate a separate confirmation. Detailed information requirements for registration 3.33 The regulatory contact is responsible for submitting all information requested via the digital service. Organisation-level information 3.34 As part of account creation on the digital service, regulated entities will be required to submit information about themselves or their organisation. This organisation-level information is submitted once during the registration process and does not need to be repeated for each individual heat network that the regulated entity registers. 3.35 Where these are separate entities, the operator and supplier will both provide organisation-level information. Details of organisation 3.36 The regulated entity will be asked to provide the following details about their organisation before they provide information about specific heat networks: • type of organisation • organisation or company details • organisational structure, for example, details of any parent companies • financial resilience indicators Significant managerial responsibility or influence (SMRI) 3.37 Operators and suppliers must not appoint, or retain in post, any individual in a position of Significant managerial responsibility or influence (SMRI) unless that person is deemed fit and proper to hold such a role. This obligation is set out in the Ongoing fit and proper requirement authorisation condition. 3.38 People with SMRI may include directly employed staff or certain advisors or consultants who have effective decision-making authority. 13 Guidance Heat network registration (draft guidance) 3.39 As part of the registration process, the regulatory entity will need to complete and submit an SMRI declaration, unless the organisation already has a current SMRI declaration on their digital service account. SMRI declarations expire after 3 years. 3.40 The SMRI declaration asks the regulated entity questions to confirm compliance with the fit and proper obligation, such as having policies and procedures in place to ensure that all persons with SMRI are fit and proper. 3.41 We may contact the regulated entity for further information if they indicated they do not have robust procedures in place to assess the suitability of individuals in SMRI roles, or they do not conduct regular assessments to ensure those individuals continue to remain fit and proper. We may also contact the regulated entity if they indicate that not all people with SMRI at the organisation are fit and proper. Network specific information Technical specifications of the heat network 3.42 The operator is responsible for providing information about the physical and technical characteristics of the heat network. 3.43 The regulated entity will be required to provide key technical details about the heat network being registered, including: • • • the geographical location of the network the number of buildings being supplied heating, cooling or hot water if the network is a district heat network, the number of embedded communal networks and responsibility for those networks the type of energy source and technology used to generate and distribute heat • • heating capacity of the network Customer information 3.44 The supplier is responsible for providing information about the customers served by the heat network, including: • customer type (domestic or non-domestic consumer) • number of customers of each type • if any non-domestic customers are ‘small businesses’ or ‘microbusinesses’ 3.45 The terms ‘domestic consumer’, ‘non-domestic consumer’, ‘small businesses’ and ‘microbusiness’ are defined in the definitions section of the heat networks authorisation conditions. Continuity plan 14 Guidance Heat network registration (draft guidance) 3.46 A continuity plan provides assurance that the regulated entity has appropriate measures in place to maintain the supply of heating, cooling and hot water to customers in the event of organisational failure or disruption. 3.47 Both the operator and the supplier will be required to confirm whether a continuity plan is in place and fit for purpose. It is required to be in place by the end of the first part of the initial period. 3.48 The operator must maintain an operational continuity plan which outlines how the physical infrastructure and day-to-day operations will be sustained. 3.49 The supplier must maintain a supply continuity plan, which details how consumer heat supply will be preserved, including arrangements for alternative provision if necessary. Complaints management procedure 3.50 Regulated entities must maintain a suitable complaints management policy and demonstrate the ability to cooperate with other regulated parties, where necessary, to resolve consumer complaints effectively. 3.51 During registration, the operator and supplier are jointly responsible for confirming that the following appropriate complaints procedures are in place: • a clear and accessible process for consumers to raise complaints • a defined procedure for investigating and resolving complaints in a timely and fair manner Consumer vulnerability 3.52 The supplier is responsible for providing information during registration about consumer vulnerability and compliance with associated regulatory requirements. 3.53 Under the heat network authorisation conditions, the supplier must establish and maintain a Priority Services Register (PSR), or an accepted equivalent, to ensure appropriate treatment and support for vulnerable consumers. 3.54 During the registration process, the supplier is required to confirm whether a PSR or an equivalent mechanism is in place and operational. 3.55 Suppliers are expected to collect information about the vulnerability of their customers to ensure these customers are identified and given appropriate support. 3.56 To establish baseline data for monitoring this requirement, the supplier will be required to confirm as part of registration: • whether the heat network is supplying to any vulnerable consumers • the number of vulnerable consumers supplied by the network 15 Guidance Heat network registration (draft guidance) Registering a Shared Ground Loop (SGL) heat network 3.57 When registering a Shared Ground Loop (SGL) heat network, the regulated entity will be asked for information relevant to the specific characteristics of this heat network type and its charging structure. 3.58 Certain questions, such as those relating to the heat network energy centre, will not be asked in the registration process where they are not applicable to the regulation of SGL heat networks. SGL heat network definition 3.59 An SGL heat network is defined as a heat network that relies solely on closed ground or water loops for heat generation, in combination with individual consumer heat pumps. 3.60 The registration process includes questions to identify SGL heat networks and confirm the charging and ownership structure for the network as one of following: • • the ‘utility model’, whereby centralised infrastructure is owned by, and the responsibility of a third-party that charges an access fee the ‘non-utility model’, whereby centralised infrastructure is owned by, and the responsibility of a third-party that does not charge any fees • a ‘small, private SGL’, whereby network consumers have joint ownership and responsibility for centralised infrastructure, and no charges are levied Registration of co-located SGLs 3.61 Under the regulations, authorisation is required for each individual relevant heat network. 3.62 Due to the design characteristics of SGL heat networks, multiple systems may be installed in proximity to each other without being physically connected by pipework. 3.63 Regulated entities may include a group of co-located SGLs in a single registration, where these are managed as a single entity. Next steps following registration Publication of list of authorised persons 3.64 Under the regulations, Ofgem is required to publish a list of authorised persons including: • • the regulated activities that they undertake the geographical location of the heat network 16 Guidance Heat network registration (draft guidance) 3.65 The published list will be updated regularly with details of completed registrations. Authorisation conditions 3.66 Operators and suppliers must comply with the authorisation conditions relevant to the regulated heat network activities they are authorised to undertake. If there are changes to the nature or scope of the regulated activity, the applicable authorisation conditions may also change. 3.67 Each regulated entity is responsible for ensuring they are familiar with the authorisation conditions that apply to them. The heat network authorisation conditions are published on our website with associated guidance. 3.68 Regulated parties are required to comply with all relevant consumer protection obligations both before and after the registration of a heat network. This includes ensuring fair treatment, clear communication, and appropriate support for heat network consumers. Monitoring 3.69 Following registration, regulated entities will be required to submit monitoring data on a regular basis. The specific data to be submitted, along with the frequency of reporting, will be determined by the applicable authorisation conditions. Heat network technical assurance scheme (HNTAS) engagement 3.70 It is expected that in future, regulated parties will be required to engage with the heat network technical assurance scheme (HNTAS) as part of their ongoing compliance obligations following registration. 3.71 At the time of publication of this guidance, the requirements of HNTAS have not been finalised. 17 Guidance Heat network registration (draft guidance) 4. Heat networks with multiple operators Nominating an operator 4.1 This guidance is intended to support understanding and compliance with the obligations outlined in the heat networks nominated operator authorisation condition. It applies specifically to heat networks with multiple operators, clarifying the responsibilities for nominating an operator to act as the main regulatory contact and share information and notifications. 4.2 The regulations set out the circumstances under which multiple parties may be identified as the operator for a relevant heat network. Where this occurs, these parties must use reasonable endeavours to agree which of them is to act as the contact point with Ofgem, on behalf of the other operators for the network. 4.3 It is expected that all parties identified as operators of the heat network will take practical and proportionate steps to reach an agreement such as actively communicating and cooperating with other parties and making genuine efforts to resolve any differences. Responsibilities 4.4 The nominated operator must promptly relay any information and notifications received from us to the other operators of the relevant heat network, and likewise communicate information and notifications received from those operators to us. 4.5 Other operators that are not the nominated operator must promptly provide information and notifications to the nominated operator as may be reasonably required. 4.6 The transfer of information and notifications between operators, and between operators and Ofgem, should occur without undue delay and within a timeframe that is both practical and reasonable in the circumstances. 4.7 The nominated operator must provide reasonable co-operation and coordination in their role as the single point of contact. This means they must work with the other operators and us to facilitate the communication of information and notifications that is required to follow regulatory rules and for us to exercise our duties in relation to regulation of activity on the heat network. 18 Guidance Heat network registration (draft guidance) Send us your feedback We are keen to receive your feedback about this guidance. We would also like to get your answers to these questions: • Do you have any comments about the quality of this guidance? • Do you have any comments about its tone and content? • Was it easy to read and understand? Or could it have been better written? • Do you have any further comments? Please send your feedback to stakeholders@ofgem.gov.uk. 19 --- Decision Heat networks regulation: Registration Guidance Publication date: 23 January 2026 Team: Email: Heat Networks HeatNetworksRegulation@ofgem.gov.uk This decision sets out our final position following consultation on draft guidance for registration. Stakeholders were generally supportive of the draft guidance, especially its explanation of regulated roles and exemptions, but sought greater clarity on how the framework applies in complex or multi-party arrangements, calling for clearer definitions, boundaries, and practical examples. Stakeholders also emphasised the need for proportionate treatment of very small, self-supply and low-risk networks, as well as tailored guidance for sectors such as social housing and education. Across the guidance, stakeholders asked for more structured processes, including clearer evidence requirements, dispute-resolution mechanisms, alongside digital functionality to support large portfolios. This decision includes our response to feedback from stakeholders, and we have published a final version of the guidance alongside this decision. The final guidance maintains our overall approach to the scope of regulation, registration and multiple-operator arrangements while improving clarity through strengthened drafting, added detail and cross-references to relevant regulations, authorisation conditions and other guidance. It explains how the framework applies to self-supply, industrial and shared ground loop networks, clarifies exemptions and provides more detail on operator roles in layered management structures. Refinements to the registration section clarify evidence requirements, the order of obligations between operators and suppliers, and the treatment of declared non-compliance. For multiple-operator networks, the guidance continues a non-prescriptive approach to avoid impacting established arrangements. It clarifies that nominated operators serve as the primary regulatory contact without assuming liability for others, with expectations applied proportionately on a case-by-case basis. Decision Heat networks regulation: Registration Guidance © Crown copyright 2026 The text of this document may be reproduced (excluding logos) under and in accordance with the terms of the Open Government Licence. Without prejudice to the generality of the terms of the Open Government Licence, the material that is reproduced must be acknowledged as Crown copyright and the document title of this document must be specified in that acknowledgement. This publication is available at www.ofgem.gov.uk. Any enquiries regarding the use and re-use of this information resource should be sent to psi@nationalarchives.gsi.gov.uk. 2 Decision Heat networks regulation: Registration Guidance Contents 1. Introduction .................................................................................................... 4 Purpose and scope .................................................................................................. 4 Overview of consultation responses .......................................................................... 4 Decision-making stages ........................................................................................... 4 Related publications ................................................................................................ 4 2. Proposed guidance for the scope of heat networks regulation ........................... 5 Question analysis .................................................................................................... 5 Ofgem response ...................................................................................................... 6 3. Registering a heat network .............................................................................. 7 Question analysis .................................................................................................... 7 Ofgem response ...................................................................................................... 8 4. Heat networks with multiple operators ............................................................ 9 Question analysis .................................................................................................... 9 Ofgem response .................................................................................................... 10 5. Next steps .................................................................................................... 11 Send us your feedback ...................................................................................... 12 3 Decision Heat networks regulation: Registration Guidance 1. Introduction Purpose and scope We consulted on the draft guidance for registration to support implementation of the heat networks regulatory framework. The guidance is intended to assist in determining whether activities are within the scope of regulation and to help authorised persons to understand how to register, and how responsibilities work in multiple operator settings. This document provides a summary of stakeholder feedback and details our decisions regarding updates to the final guidance. Overview of consultation responses Stakeholders broadly support the draft guidance, valuing clarity on regulated roles and exemptions. Respondents most frequently called for proportionality in the approach to regulation of small or self‑supply heat networks, clarity on the treatment of connected or embedded networks, and a decision framework for determining ‘substantial control’ of heat network assets. Calls for the digital service to support the bulk upload of heat network information, clarity on roles and vulnerability data handling, and worked examples were also prominent. Decision-making stages Stage 1 Consultation open: 17 November 2025 Stage 2 Consultation closed: 15 December 2025 Stage 3 Responses reviewed Stage 4 Consultation outcome (decision) and responses published: 23 January 2026 Related publications This document may be read in conjunction with the following publications: • our 2025 decision on heat networks authorisation and regulatory oversight (2025 • • • decision) the 2025 government response to the joint consultation on implementing consumer protections for heat networks (2025 government response) the updated draft authorisation conditions published with the above 2025 government response the Heat Networks (Market Framework) Regulations 2025 Statutory Instrument (HNMFR SI) (the regulations) 4 Decision Heat networks regulation: Registration Guidance 2. Proposed guidance for the scope of heat networks regulation Section summary We consulted on draft guidance for the scope of heat networks regulation, including guidance on key definitions, and how the regulatory framework applies across different heat network arrangements. Stakeholders broadly agreed with this section of the guidance but also sought clarity on specific heat network types and complex arrangements. Question analysis Consultation Question Q1. Do you agree with the proposed guidance for the scope of heat networks regulation? Table 1: Response summary for consultation question 1 Response Number of responses Percentage of responses Agree Partially agree Disagree Not answered 13 8 0 0 61.9% 38.1% 0.0% 0.0% 2.1 Thirteen stakeholders (61.9%) agreed with the proposed guidance for the scope of heat networks regulation, with some noting it is clear and useful, particularly valuing the definitions of operator, supplier, and relevant heat network, as well as the explanation of exemptions. 2.2 Eight stakeholders (38.1%) partially agreed but also called for worked examples for complex arrangements such as social housing, education sites, embedded or connected networks, and tighter criteria for terms like ‘substantial control’. Responses also included general calls for a proportionate regulatory approach to very small or self-supply heat networks. 2.3 No stakeholders disagreed with the question, but eight respondents' comments indicated the need for further clarification on definitions and boundaries, particularly for connected networks and multi-party arrangements. 5 Decision Heat networks regulation: Registration Guidance 2.4 Five stakeholders requested a glossary of terms and cross-references to relevant regulations to link users to other documents that set out regulatory scope. 2.5 Four stakeholders requested clarification on the treatment of connected networks, including whether each connected network requires separate authorisation and how consumer protections and pricing oversight will work across boundaries. 2.6 Three stakeholders called for a decision framework for determining ‘substantial control’ of heat network assets, including setting out a hierarchy of factors such as contractual rights, operational decision-making, and investment control. 2.7 Three stakeholders highlighted the need for worked examples and cross- references to regulations in the guidance text to explain bulk supply, the role of managing agents, ESCos, layered social housing models, and types of student accommodation. 2.8 Two stakeholders said the guidance should include explicit thresholds or tailored treatment for very small or self-supply networks to avoid disproportionate compliance burden. 2.9 Two stakeholders called for clear guidance for education sites, noting that minimal consumer risk and sector resource constraints should be considered. Ofgem response We are proceeding with our overall approach to guidance on the scope of regulation and have strengthened drafting in the final published guidance to improve clarity in response to stakeholder feedback. We have added further detail to the guidance which covers self-supply, industrial and Shared Ground Loop (SGL) heat networks and explains how the regulatory framework applies in these cases. We have included examples and specified the authorisation conditions that do not apply for self-supply and industrial heat networks. We acknowledge stakeholder requests for exemptions for specific scenarios. However, we note that our guidance in this area is based on policy positions that have been established through previous consultations. In the final guidance, we have clarified the status of third-party waste heat producers and how exemptions may be invoked. The heat networks market is diverse. As such, our guidance is general, with limited content that is specific to a particular sector. To support the transition to regulation, we intend to engage with different sectors of the market and may produce resources targeted to their specific circumstances. In the final version of the guidance, we have incorporated references to authorisation conditions and relevant legislation to link to defined terms, and, in certain sections, added diagrams to further support users' understanding. 6 Decision Heat networks regulation: Registration Guidance We have added further detail about the operator role to describe typical scenarios in the leasehold sector and give clarity on how operator status may be determined in layered management structures. Due to the potential for different arrangements across the sector, we have not included a prescribed framework for establishing ‘substantial control’. 3. Registering a heat network Section summary We consulted on draft guidance for registering a heat network, including detail of process steps and the information required from authorised persons. Stakeholders welcome the digital service for registration and clear explanation of baseline data requirements in guidance. Stakeholders called for a bulk upload functionality as part of the digital service, clearer definition of roles in registration, supplier and operator dependencies, expectations on vulnerability data, and provision of practical examples. Question analysis Consultation Question Q2. Do you agree with the proposed guidance for registering a heat network? Table 2: Response summary for consultation question 2 Response Number of responses Percentage of responses Agree Partially agree Disagree Not answered 6 13 1 1 28.6% 61.9% 4.8% 4.8% 3.1 Six stakeholders (28.6%) agreed with proposed guidance for registering a heat network, describing it as helpful and clear, and expressing support for a digital service. 3.2 Thirteen stakeholders (61.9%) partially agreed, requesting more detail on process, roles, and practical improvements for large portfolios and vulnerable consumer data. 3.3 One stakeholder (4.8%) disagreed, citing unresolved issues around bulk suppliers and regulatory contact definitions. 7 Decision Heat networks regulation: Registration Guidance 3.4 Eight stakeholders requested clarity on evidence requirements, compliance declarations, and best practice for determining whether persons with Significant Managerial Responsibility or Influence (SMRI) are fit and proper. 3.5 Seven stakeholders commented on the importance of explicit dates and process milestones, including regular updates on portal launch and the registration window. Three stakeholders said the digital service should include bulk upload functionality and user-friendly digital platforms, with clear guidance and support for those with large portfolios. 3.6 Four stakeholders called for clarity on dependencies between suppliers and operators and proposed functionality for suppliers to notify Ofgem of readiness to register and fallback arrangements if operators delay. 3.7 Two stakeholders emphasised the need for data collection processes for vulnerable consumers, with clear milestones and reporting requirements. 3.8 Two stakeholders called for worked examples and case studies for common scenarios, such as managing agent as supplier, asset owner as operator, and multi-phase developments. 3.9 Two stakeholders highlighted concerns about fragmented records, legacy contracts, and adversarial relationships between operators and suppliers, with requests for prioritisation of critical data and fallback mechanisms for non- cooperation. Ofgem response We are proceeding with our overall approach to guidance on registration with some refinements to improve understanding in this area. We can confirm that bulk upload functionality will not be included as part of the digital service for registration. As outlined in the guidance, registration captures high-level information about authorised persons and their networks. Bulk upload functionality will be considered for future services such as regular data monitoring. Stakeholders highlighted the dependency between operators and suppliers to complete the registration. In guidance, we have confirmed that the supplier’s obligation to register does not come into effect until the operator has completed their component. Suppliers are encouraged to contact us if this issue arises. In final guidance, we have clarified that where non-compliance is declared as part of registration, this will not prevent an authorised person from completing the process. This forms