Registering by 26 January 2027
Based on verified entries in our requirements register (v0.3.1), reviewed 1 November 2026. Links go to the primary source; paragraph numbers are given so you can check every claim.
Since 27 January 2026, operating a relevant heat network or supplying heating, cooling or hot water through one is a regulated activity in Great Britain. Existing networks are treated as authorised (regulation 27 of SI 2025/269), but authorisation comes with conditions — and the first hard deadline in them is registration.
The deadline, and why we say 26 January 2027
Condition A4, paragraph 4.1 requires every authorised person to tell Ofgem, through its digital registration service, about each regulated activity they carry on before the end of the first part of the initial period. Regulation 26 of SI 2025/269 defines that period as ending the day before the first anniversary of the launch date (27 January 2026) — that is, 26 January 2027.
You may see 27 January 2027 in Ofgem’s registration guidance (paragraph 3.7). Ofgem’s own data reporting guidance (paragraph 2.14) and its October 2026 application arrangements consultation both say 26 January 2027, which follows from the regulation. We work to 26 January 2027: a day early is never wrong.
Who registers first
Where one organisation operates the network and another supplies through it:
- The operator starts. It must complete its submission before the supplier can proceed (registration guidance 3.8).
- The supplier must co-operate with the operator — including providing relevant information — so the operator can register on time (condition A4 4.2.1). The supplier’s own duty to register does not arise until an operator has registered (A4 4.2.2).
- If the operator has not registered as the deadline approaches, the supplier should contact Ofgem rather than sit on the problem (registration guidance 3.25).
Where several organisations each operate part of one network, they can agree that a single operator submits the registration information for all of them (A4 4.3), and they must use reasonable endeavours to agree a nominated operator to act as the contact point with Ofgem and ensure Ofgem is notified of who it is (condition A5 5.2). The nominated operator passes information between Ofgem and the other operators promptly (A5 5.3) and later submits network-level reporting data on the others’ behalf (data reporting guidance 2.17) — but Ofgem’s guidance (paragraph 4.8) is clear that it adopts no regulatory liability for the others.
The Regulatory Contact
When the digital service account is created you name a regulatory contact — ideally the most senior person responsible for the network’s operations and regulatory compliance (registration guidance 3.13). That person remains ultimately responsible for the accuracy and completeness of everything submitted (3.16), and before submitting you declare that the information is correct to the best of your knowledge (3.29). Choose someone who can stand behind that declaration, and record the appointment.
The fit-and-proper (SMRI) declaration
Registration includes a declaration about the people in positions of Significant Managerial Responsibility or Influence (SMRI). The declaration is submitted at registration unless a current one is already held on the account, expires after three years, and is refreshed when SMRI holders change (registration guidance 3.40).
The declaration sits on top of continuing duties under condition A8: no unfit person may hold an SMRI role (A8 8.1), you need processes, systems and governance that ensure every holder is fit and proper (A8 8.2.1), and holders must be reassessed regularly (A8 8.2.2). Our packs include a Fit and Proper Persons Policy built around the assessment factors in A8 8.3.
What you will be asked
Condition A4 4.1.2 requires the information the registration arrangements call for, including the nature of your activities and contractual arrangements, the networks concerned, other authorised persons on the network, financial status, ownership and organisational structure, the consumers supplied, and matters relevant to compliance with the conditions. In practice the digital service asks for:
| Asked of | What | Source |
|---|---|---|
| Every organisation, once | Organisation type, company details, organisational structure including parent companies, financial resilience indicators | Registration guidance 3.36 |
| Operators, per network | Physical and technical characteristics: location, buildings served, embedded communal networks and who is responsible for them, energy source and technology, heating capacity | 3.43–3.44 |
| Suppliers, per network | Customer types (domestic or non-domestic), numbers of each, and whether non-domestic customers are small-business or microbusiness consumers | 3.45 |
| Operators and suppliers | Whether a fit-for-purpose continuity plan is in place — the plan itself must exist by 26 January 2027; local authorities and registered providers of social housing are outside this duty | 3.49 |
Changes on the way
Two proposals in Ofgem’s October 2026 application arrangements consultation (closing 2 November 2026) are worth knowing about, though neither is in force yet:
- Organisations starting a new regulated activity on or after 27 January 2027 would apply for authorisation before starting, with declarations by the most senior person responsible (consultation, paragraphs 2.9–2.16), and register within three months of beginning the activity (paragraph 4.4; intended effective date 25 January 2027, paragraph 4.10).
- A condition requiring notification of material changes to a registered network or person was consulted on in 2025 but is not in the current condition set (January 2026 decision, chapter 1, table following paragraph 1.12). Until one is made, self-reporting under condition A10 is the nearest obligation.
Pack holders receive position-note updates when either lands.
This guide is a plain-English summary, not legal advice — see the disclaimer. Need the policies, registers and declarations the conditions ask for? See products and pricing.