Policy · Roles & Responsibilities
Heat network operator vs supplier — what’s the difference under Ofgem?
Your role — operator, supplier, or both — determines which Ofgem authorisation conditions apply to you. Getting this wrong at registration is one of the most common errors. Here is a clear breakdown.
The two roles
| Role | Definition | Primary obligations |
|---|---|---|
| Operator | Controls and maintains the physical network infrastructure | Network reliability, metering and monitoring, technical standards |
| Supplier | Provides heat to customers and is their main point of contact | Billing, consumer protection, complaints, vulnerable customer identification |
When you are both
Most housing associations, local authorities and private landlords managing their own networks are both operator and supplier. If you maintain the plant and invoice residents directly, both sets of conditions apply. Ofgem does not reduce your obligations because the roles sit with one entity.
When operator and supplier are different entities
In schemes managed by ESCOs or under heat supply agreements, each entity registers separately and meets only the conditions relevant to their role. Contracts between them should clearly allocate compliance responsibilities — Ofgem can pursue either party for failures in their respective areas.
How to determine your role
- Do you control and maintain the physical network? → You are an operator.
- Do you charge residents for heat and handle their queries? → You are a supplier.
- Both? → Register as both. All authorisation conditions apply.
Frequently asked questions
What is the difference between a heat network operator and supplier?
The operator controls and maintains the physical network infrastructure. The supplier provides heating to customers and is their main contact for billing and complaints. Many heat network owners are both operator and supplier and must meet the conditions for both roles.
Can a managing agent be the supplier without owning the network?
Yes. If they handle billing and are the residents’ primary contact, they may be the supplier regardless of who owns the infrastructure.
What if I am unsure which role I hold?
The test is functional — who controls the network, and who bills the customer. If your arrangements are complex, clarify before completing Ofgem registration, as incorrectly registering your role creates compliance gaps.
What if I am both operator and supplier?
Both sets of authorisation conditions apply. You must register both roles with Ofgem and maintain compliant documentation for all applicable conditions.