Ofgem authorisation deadline: 26 January 2027 – most operators haven’t started

What is a supply continuity plan for heat networks?

What the plan must include, what Ofgem scrutinises most, and how to prepare one.

Key points

  • Required for Ofgem authorisation – not optional
  • Must cover planned outages, emergency response, consumer notification, and step-in procedures
  • Step-in arrangements are the most scrutinised area – Ofgem needs to know consumers will not lose heat supply if the operator fails

A supply continuity plan is a document that sets out how a heat network operator will maintain heat supply during disruption, including planned maintenance, emergency response, and step-in arrangements if the operator can no longer supply. It is a condition of Ofgem authorisation under the Market Framework Regulations 2025. This guide covers what the plan must include and how to prepare one.

Why Ofgem requires a supply continuity plan

Heat network consumers are captive – they cannot switch supplier. If a gas or electricity supplier fails, the market has established mechanisms for transferring customers. No such mechanism exists for heat networks yet. The supply continuity plan fills this gap by documenting the operator’s arrangements for keeping heat flowing in all foreseeable scenarios.

Planned maintenance and outages

The plan should document how the operator manages planned maintenance: advance notice periods for consumers, seasonal scheduling to minimise impact, contingency arrangements if maintenance overruns, and communication channels. Ofgem expects defined timescales – not vague commitments.

Emergency response

For unplanned disruptions – plant failure, fuel supply interruption, extreme weather, network damage – the plan should set out the response procedures: who is responsible, what the escalation path is, what the target response and restoration times are, and how consumers are notified.

Named contacts with current details are essential. A plan that says “the duty engineer will respond” without identifying who that is and how they are reached is inadequate.

Consumer notification

The plan must specify how consumers are notified during outages: what channels (email, SMS, notice board, letter), what timescales (planned vs emergency), and what information is provided (expected duration, alternative arrangements, complaint process). This ties directly to the consumer protection conditions.

Step-in procedures

This is the area Ofgem pays closest attention to. What happens if the operator becomes insolvent, loses its authorisation, or otherwise cannot continue supplying heat? The step-in plan should identify who steps in (parent company, managing agent, local authority, appointed administrator), what legal arrangements are in place, and how the transition is managed without interruption to supply.

For operators within a group structure, a parent company guarantee or service level agreement may be appropriate. For standalone operators, the arrangements are harder but still required – Ofgem will not authorise an operator with no credible step-in plan.

How to structure the document

The Supply Continuity Plan from Heat Network Compliance Hub is structured in parts: planned maintenance (Part A), emergency response (Part B), consumer notification (Part C), and step-in procedures (Part D). Each part includes pre-built sections with dropdown controls for timescales and notification methods. At £195 individually or included in the Compliant Bundle (£895).

Getting started

Start by documenting what you already do for maintenance and emergency response, then identify the gaps – most operators find that step-in arrangements and formal consumer notification procedures are the weakest areas. Work with your solicitor on the step-in arrangements if they involve third-party agreements.

For regulatory context, see Ofgem’s heat network operator guidance. For related preparation, see our guide to financial resilience statements – financial resilience and supply continuity are closely linked in Ofgem’s assessment.

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