Citizens Advice published its response to Ofgem's consultation on Consumer Protection Guidance for the heat network sector on 3 November 2025. The charity said it welcomes the consultation, and that with new regulations set to take effect in January 2026 the guidance will play a crucial role in securing fair outcomes for the estimated 1.1 million people connected to heat networks1.
The response states that heat network consumers have no choice of supplier, which it gives as the reason the guidance must support suppliers in meeting their obligations1. It sets out four areas it says must be addressed. On billing, it identifies an inconsistency between the guidance and authorisation conditions around separate billing and lease requirements, and says this should be clarified to avoid inconsistent outcomes for consumers. On back-billing, it says Ofgem should clarify how the back-billing rules interact with existing case law, warning that the current approach could expose consumers to unfair, long-term catch-up bills1.
On contracts, Citizens Advice says suppliers should be required to update contracts within 12 months of the deadline to register with Ofgem, so that consumers can challenge unfair charges and poor service without unnecessary delay. On vulnerability, it says Ofgem should clarify how protections for vulnerable consumers under housing law interact with its regulatory framework, helping suppliers understand their responsibilities and provide appropriate support1.
"Overall, Citizens Advice supports the intent of the guidance but urges Ofgem to provide clearer instructions, practical examples, and evidence-based expectations."
The charity adds that this approach will help ensure suppliers aim for good consumer outcomes rather than meeting the absolute minimal standard to be considered compliant1.
Why it matters for households
Heat networks supply heating and hot water to homes through communal or district systems rather than an individual gas boiler. The heat network suppliers that run them are the only option for the households connected, so the protections set out in heat network regulation carry the weight that choice of supplier would otherwise carry. The 1.1 million figure Citizens Advice cites is its estimate of how many people are connected1.
The four points in the response map onto practical risks. Separate billing and lease arrangements determine how a household is charged and what it has agreed to; back-billing rules determine how far back a supplier can recover unpaid sums; contract update deadlines determine how quickly a household can challenge charges it considers unfair; and the interaction with housing law determines what support a vulnerable resident can expect. Citizens Advice's position is that each is currently unclear enough to produce inconsistent outcomes1.
The consultation sits within Ofgem's wider consumer protection work, alongside the energy complaints and redress routes that households use when something goes wrong. Advice on heat network disputes is handled by energy consumer bodies including Citizens Advice.
What happens next
The new regulations are set to take effect in January 20261. Citizens Advice has asked Ofgem to provide clearer instructions, practical examples and evidence-based expectations in the guidance before that date1. Ofgem has not published its response to the consultation points raised, and no date for final guidance has been reported1.