Time to get a grip on grievances

This change to the regulatory framework comes partially in response to a rise in complaints from heat network residents to the Housing Ombudsman, who has no jurisdiction over this industry. Issues such as slow repairs, missed appointments, unclear billing and opaque tariff structures have all contributed to eroding consumer confidence in heat networks. The sector is under pressure to raise the bar – and quickly.

Resolving problems

Whatever the final form of the new regulations, it’s certain that handling customer complaints and disputes will be an key area of focus. Ofgem intends to implement a range of clear, detailed, time-lined requirements for how grievances are handled, tracked, reported and resolved. 

Until recently, heat network residents who had exhausted their heat supplier’s internal complaints process had no further route for escalation. Since 1^st April 2025, however, Citizen’s Advice and Consumer Advice Scotland have been providing free advocacy services for heat network consumers. Furthermore, where a complaint reaches “deadlock” after eight weeks, residents will be able to seek independent redress via the Energy Ombudsman at a cost to heat network operators of between £250-£375 per case submitted. This aims to help close a long-standing gap in consumer protection and introduces a higher level of accountability for heat suppliers. 

Heavy workload

The scale and pace of regulatory change and the ongoing uncertainty present a significant challenge for the industry and housing providers. Heat network stakeholders have faced a constant stream of consultations from Ofgem and the Department for Energy Security and Net Zero (DESNZ) over the past two years, with multiple documents released every few weeks, often running to hundreds of pages each time. For operators and suppliers without prior regulatory experience, industry memberships, or know-how, keeping up can easily be an overwhelming task.

Inevitably, smaller heat suppliers are likely to face the steepest learning curve. Many do not have specialist teams or established systems and processes to track complaints in detail, let alone manage escalations from the Energy Ombudsman. But even larger organisations that may already have corporate complaint structures will still need to introduce new workflows and reporting fields to ensure heat-related issues are captured, monitored, and reported accurately.

So, what are the key steps to take now to get ready for the new rules?

Preparing the ground

Ofgem’s latest authorisation conditions for the Heat Network (Market Framework) (Great Britain) Regulations 2025 and soon-to-be-published consumer protection guidance documents offer a good indication of what’s likely to be expected moving forward, so they offer a useful starting point for shaping organisations’ approaches to complaint handling. 

One key point is that landlords and managing agents will need to identify, record, triage and manage heat network complaints separately from general housing complaints, in line with Ofgem’s new regular data reporting guidance. That means clear processes, trained teams and updated systems. 

Some key questions to think about when looking at complaint protocols include:

• Can you meet the different timescales and procedural requirements set by Ofgem and the Energy Ombudsman?

• Are you set up to record and submit heat network complaints data to Ofgem as part of its quarterly reporting requirements?

• Can residents – including those in vulnerable situations – easily access clear information about complaints procedures, including appropriate escalation routes? 

• Can complaints be made via any reasonable channel, without creating barriers for vulnerable residents?

• Can you flag and separate heat network complaints on your information systems, including categorising them by type and identifying where they are raised as part of a group complaint?

• Can you track the outcome of each complaint, including resolution times, and any referrals to the Energy Ombudsman?

• Can your service partners – including metering & billing agents and maintenance contractors – report customer complaints in a way that aligns with Ofgem’s requirements? 

• Do your service contracts need updating to reflect the new complaints obligations?

• Would it be more effective to outsource your complaint-handling procedures altogether?

What we’re doing

As a heat network service provider supporting over 40,000 UK households, we share the government’s commitment to improving outcomes for residents. As well as actively engaging in Ofgem’s consultation process to help shape the new regulations, we’ve been reviewing and enhancing our own internal processes in preparation. 

We’ve strengthened our complaints policy, supporting systems and staff training, with everything to be overseen by a newly created and dedicated Complaints Manager role. Every expression of consumer dissatisfaction is logged and categorised, response times are monitored against the expected eight-week resolution window, and client organisations receive clear, consistent data to support Ofgem’s forthcoming quarterly reporting requirements through our client portal, VANTAGE. And, for housing providers that lack the capacity to handle complaints in-house, we’re now rolling out a full complaints management service, including Energy Ombudsman liaison as needed.

However, as with all good businesses, our aim is always to avoid complaints in the first place. 

This is where clear, accurate and timely communication with residents matters most. For instance, we invest a lot of time in producing scheme-specific tariff change notification letters for residents, providing transparent and detailed cost breakdowns and forecasts of the new annual charges. Our Customer Experience team also hold Monthly Contact Review meetings to analyse each customer discourse and identify opportunities for improvements. While heat networks are inherently complex, and we are often only one of several providers in the mix, meaning issues are not always within our gift to fix, we always endeavour to provide a rapid response, a listening ear and clear, helpful information. 

What’s next

As the new rules bed in, housing providers and property managers will need to keep evolving their processes. More guidance is expected as Ofgem continues to refine the new framework. But one thing is already certain: with a statutory advocate, a formal ombudsman pathway, and Ofgem oversight, the era of informal or inconsistent complaints handling is over.

This article was written by Insite Energy.
For a practical overview of the emerging regulations, Insite Energy’s updated consumer protection guide is available here:
https://insite-energy.co.uk/businesses/heat-network-regulations