What Ofgem requires for supply continuity
Ofgem expects operators to maintain and evidence continuity arrangements that work in real operating conditions, not just on paper. In practical terms, that means documented processes for disruption scenarios, clear ownership of response actions, and credible step-in arrangements if the authorised entity is unable to keep supplying consumers. This is not a generic resilience statement. It is a service continuity obligation tied directly to keeping heat and hot water available, or restoring supply quickly and safely when incidents occur.
The supply continuity requirement sits within the broader framework of authorisation conditions and connects closely to the wider continuity arrangements operators must demonstrate. Ofgem typically looks for named contacts, defined activation thresholds, documented escalation routes, and practical decision points for invoking external support or step-in. Where those elements are vague, evidence is weak. Supply continuity is among the areas Ofgem scrutinises most carefully, so operators should treat this section as a front-line authorisation requirement rather than an administrative appendix. To accelerate drafting, many teams begin with a structured supply continuity plan template and then tailor it to actual network operations, contractor coverage, and governance controls.
Why this matters more for heat than gas or electricity
When a gas or electricity supplier fails, established market mechanisms can move customers to an alternative supplier. No equivalent switching mechanism exists for most heat networks. Consumers cannot choose a second network and there is usually no other pipe in the ground. That infrastructure reality means continuity obligations are more than compliance language. If one operator fails, consumers can be left exposed unless the continuity and step-in framework has already been defined, tested in principle, and operationally embedded.
That is why supply continuity planning sits at the centre of heat-network authorisation. It is not only a technical issue and it is not only a legal issue. It is a combined operations, governance, and consumer-protection issue. Ofgem expects a plan that shows who does what, when, and on what trigger, with enough specificity that the network can continue serving homes and buildings under pressure.
Planned maintenance and outages
Your Supply Continuity Plan should clearly set out how planned maintenance is prepared, approved, communicated, and completed. That includes notice periods, how maintenance windows are selected, what temporary mitigation is used, and what actions follow if work overruns. Ofgem expects definitions and timings rather than broad intent statements. For example, the plan should show how consumers are notified before shutdown, who signs off outage risk, and how engineering and customer teams coordinate restoration messaging.
Operators should also document dependencies that can delay restoration, such as contractor lead times, specialist parts, fuel logistics, or access constraints. A credible continuity plan acknowledges these constraints and sets out fallback routes if the first option fails. This level of detail helps demonstrate that planned outages are controlled events, not unmanaged risks.
Emergency response
For unplanned events such as plant failure, fuel interruption, network damage, controls failure, or severe weather, your plan should define incident triage, command and escalation, response targets, restoration priorities, and external mobilisation routes. This needs to include both technical and consumer-facing actions, because continuity failure is judged by service impact as well as engineering status.
Named contacts are essential. A response plan that only references role titles without verified contact details, rota ownership, and handover responsibilities is unlikely to satisfy Ofgem scrutiny. Operators should maintain current call trees, confirm availability assumptions, and show who can authorise temporary measures when critical decisions are needed quickly.
Consumer notification
Consumer notification should be structured by scenario and timeline. Planned outages require advance communication windows, while emergency incidents require rapid first notice and scheduled updates. Your plan should specify channels, fallback channels, and message templates that include expected duration, interim support, safety instructions where relevant, and complaint routes.
This section should also set minimum content standards so messages remain useful under pressure. If updates vary by scheme type, vulnerability profile, or operating hours, those rules should be explicit. Clear and timely consumer communication is a core continuity control, not a secondary communications task.
Step-in procedures
Step-in procedures are often the deciding factor in continuity assessments. If the operator becomes insolvent, loses operational capability, or cannot continue to deliver supply, Ofgem expects evidence of who can step in, under what trigger conditions, and how supply continuity is protected throughout transition. That means legal and operational pathways must be credible, not merely aspirational.
For group operators, this may involve parent support and formal delegated operational authority. For standalone operators, it may require contracted managing-agent support or other pre-arranged mechanisms. In both cases, trigger thresholds, authority boundaries, and operational handover steps should be documented in advance. Ofgem will not authorise an operator with no credible step-in plan – this is the one section where 'we'll work it out if it happens' is guaranteed to be rejected.
How to structure the document
A practical structure is four core parts: planned maintenance and outages, emergency response, consumer notification, and step-in procedures. Supporting appendices can then capture named contacts, escalation trees, trigger thresholds, dependency maps, and handover checklists. This keeps the operational workflow clear while preserving evidential detail for authorisation review.
The Supply Continuity Plan from Heat Network Compliance Hub is structured in four parts and aligns to this approach, at £195 individually or in the Compliant Bundle (£895). You can also buy the SCP directly and compare bundle options on the pricing page.
Getting started
Start by mapping your current real-world outage handling and recovery practice, then convert it into a documented standard that can be evidenced and audited. Most operators discover that maintenance and emergency actions exist informally, but trigger thresholds, ownership boundaries, and step-in pathways are not formally documented. Prioritise those gaps first, then tighten message standards and restoration governance.
As you draft, test each section against practical questions: who activates this process, what evidence proves activation criteria were met, and how would continuity be preserved if key people are unavailable. If the plan cannot answer those questions quickly, it is not yet operationally robust. Ofgem’s heat networks regulatory page provides the current regulatory framework, and supply continuity assumptions should be aligned with your Financial Resilience Statement position.
Frequently asked questions
What is a Supply Continuity Plan for a heat network?
A Supply Continuity Plan sets out how a heat network operator will maintain or restore heat supply in the event of a significant disruption, and what step-in arrangements exist if the operator is unable to continue. It is a core requirement of Ofgem authorisation under the Market Framework Regulations 2025.
What is a step-in arrangement for heat networks?
A step-in arrangement is a pre-agreed mechanism by which a third party can take over the operation of a heat network if the primary operator fails or is unable to continue. Ofgem requires evidence that credible step-in arrangements are in place, including identification of who would step in and under what conditions.
What should a Supply Continuity Plan cover?
The plan should cover risk identification, emergency response procedures, key contacts and escalation paths, temporary supply arrangements, consumer communication protocols during disruption, and the basis for step-in activation. It should be specific to the network rather than a generic template.
Does a Supply Continuity Plan need to be tested?
Ofgem expects plans to be credible and operational, not just documented. While there is no mandated testing schedule in the current authorisation conditions, operators should be able to demonstrate that the plan is workable and that key personnel are familiar with it.
Is a Supply Continuity Plan different from a business continuity plan?
A Supply Continuity Plan is specific to the continuity of heat supply to consumers and the step-in provisions required under the 2025 Regulations. A general business continuity plan does not satisfy this requirement unless it specifically addresses heat supply continuity and the regulatory step-in framework.