Complaint

This page signposts to sources of consumer rights advice for domestic heat network consumers in Great Britain (England, Wales and Scotland) who aren’t on Heat Trust registered heat networks. It summarises general advice from other external sources and gives links to these sources for more help.

Please note that Heat Trust isn’t an advice service, can’t give legal advice, and can’t intervene directly in disputes between individual consumers and their heat suppliers. You should always seek expert advice before taking any action that could involve risks or costs to you.

If you're disputing a bill with your heat supplier, we don't recommend that you cancel direct debits or stop paying your heat charges as this could make the situation worse. We suggest instead telling your supplier that you're paying under protest and ask if they can put the disputed part of the bill on hold. If you can't afford your bills, you should always talk to your supplier about it and ask them how they can help (we have a separate webpage about this here).

Before reading on:

  • Confused about what heat networks are? Start with our explanation here.
  • On a Heat Trust registered heat network? See here instead for how our Scheme protects you.
  • Not sure if your heat network’s registered with us? Check here.
  • Thinking of moving into a home on a heat network? Read our information here.
  • Want your heat network to register with Heat Trust? Use our template letter to write to your heat supplier.
  • Looking for support with paying bills or managing debt? See our separate page here.

Are heat network operators and heat suppliers regulated?

No. Unlike gas and electricity supply and distribution activities, which are regulated by Ofgem, GB heat network operators and heat suppliers are currently unregulated (other than some minimum regulatory requirements about metering and billing, which we explain below).

Heat Trust’s voluntary Scheme is currently the only form of regulation for heat networks that sets minimum standards of customer service and gives consumers access to the Energy Ombudsman. Only consumers on heat networks registered with us benefit from these protections. We want all heat network consumers to be protected in the same way as gas and electricity consumers, so we’ve long advocated for statutory regulation of the sector.

The good news is that government intends to make Ofgem the GB regulator for heat networks, though this won’t happen until 2025 at the earliest. You can find out more about this planned regulation here.

What are my rights if my heat network isn’t registered with Heat Trust?

There are various other consumer protections that may apply to you. Because heat networks are installed at a building level, both housing law and general consumer law will apply.

Your legal protections will vary depending on:

  • When your home and heat network were built, and whether your heat usage is metered.
  • Whether you own your home or rent it (and, if you’re a homeowner, what type of ownership arrangement you have).
  • Whether you live in private or social housing.

The first thing you should always do if you have an issue with your heat network is complain directly to your heat supplier. Your heat supplier will be the entity who has the contractual arrangement with you to supply you with hot water and/or heat. This is usually the owner of the building you live in.

If you haven’t been able to get anywhere by complaining to your building managing agent, letting agent, or the company sending you your heat bills, it’s probably because they’re not your actual supplier. Instead they’re likely to be a subcontractor acting on your supplier’s instructions.

You should always check the terms of any legal occupancy agreement and any other contractual information about your heat network, as these should set out your specific rights and responsibilities as well as the name of your heat supplier.

Our general guidance for making an effective complaint is to:

  • Keep a record of all events and conversations about your complaint. Include times and dates, what happened, who you spoke to and what was said. Keep copies of any other relevant information like meter readings, bills and bank statements.
  • Check if other residents on your heat network are having the same or similar problem(s), and co-ordinate action with them if possible. Contact your residents’ association if you have one.
  • Check your rights as a homeowner or renter. The information on this page signposts to organisations who can help you to understand these rights.
  • Check your general rights as a consumer. We link to sources of information on these below.
  • Know what you would like your heat supplier to do to resolve your complaint.
  • If you’re still unhappy with how your supplier’s handled your complaint, consider what other organisations or elected officials might be able to help you. The information on this page signposts to various other potential sources of help.

The Consumer Rights Act 2015 protects you against unfair contract terms and notices.

Schedule 2 of the Act lists consumer contract terms that may be regarded as unfair, including:

  • ‘A term which has the object or effect of enabling the trader to alter the terms of the contract unilaterally without a valid reason which is specified in the contract.’
  • ‘A term which has the object or effect of giving the trader the discretion to decide the price payable under the contract after the consumer has become bound by it, where no price or method of determining the price is agreed when the consumer becomes bound.’
  • ‘A term which has the object or effect of permitting a trader to increase the price of goods, digital content or services without giving the consumer the right to cancel the contract if the final price is too high in relation to the price agreed when the contract was concluded.’
Where to go for help

The Competition and Markets Authority (CMA) has published further guidance here about when contact terms can be considered unfair. Because heat networks are natural monopolies, heat suppliers and operators also need to ensure that they’re not abusing a position of market dominance. The CMA has guidance here on what types of business behaviour are illegal under competition law. The CMA’s contact details are here.

You may also be able to report unfair trading to your local Trading Standards office, which you can look up here.

The only statutory regulations that currently apply to heat networks are those set out in the Heat Network (Metering and Billing) Regulations 2014, as amended in 2015 and 2020. These apply to heat networks in England, Wales and Scotland.

Metering rules

Under the regulations, all newly built multioccupancy buildings on heat networks are usually required to:

  • Install accurate heat meters in each individual home that measure, record and display each home’s heating and hot water usage (their ‘consumption’).
  • Base consumers’ bills on readings taken from these heat meters.
  • Install temperature control devices in each home that enable consumers to adjust how much heat they use.

Older heat networks may also be required to do this, where it’s cost-effective and feasible (or if it later becomes cost-effective and feasible, for example during planned building renovations).

Heat Meters

(Pictures of heat meters, including meters installed inside Heat Interface Units: photo credits Switch2 and Vital Energi.)

Secure Meters

(Pictures of a heat meter and in-home display: photo credit Secure Meters Ltd.)

PPM IHD

(Pictures of 'pay as you go' pre-payment devices: photo credit Switch2.)

Where individual heat meters aren’t required to be used, then your heat supplier must usually install heat cost allocators (HCAs), thermostatic radiator valves (TRVs) and hot water meters in each home, if it is (or becomes) cost-effective and feasible to do so:

  • An HCA is a small electronic device fitted to a radiator that measures, records and displays the radiator’s heat output.
  • A TRV enables you to adjust and control how hot a radiator gets, and therefore how much heat it uses.
  • A hot water meter measures, records and displays your home’s hot water consumption.

HCA TRV

(Picture of a TRV: photo credit Switch2. Picture of an HCA: photo credit Data Energy Management Services.)

Heat suppliers are responsible for ensuring that all installed meters or HCAs operate continuously and correctly, are properly maintained, and are periodically inspected for errors.

Billing rules

If you have a heat meter or HCA, your heat supplier must ensure that:

  • Your bills for heating and hot water are accurate and based on consumption.
  • You receive a bill at least once a year that’s based on your actual consumption (rather than estimated consumption).
  • You receive an explanation of how your bill was calculated, that splits out both fixed and variable charges (for example, your consumption may vary but your contribution to network maintenance and repairs might be a fixed cost).
  • You have the option to request electronic billing.

If it’s cost-effective and feasible to do so, your supplier must also provide you with the following billing information at least twice a year (or quarterly if you’ve requested electronic billing):

  • The current energy prices charged to you.
  • Information about your consumption.
  • A comparison with your previous year’s consumption (if available), if possible as a graph.
  • Contact information for organisations who can advise on energy efficiency improvements.
Where to go for help

You can find the government’s guidance on the Heat Network (Metering and Billing) Regulations here.

If you believe that your heat supplier isn’t complying with these regulations, you can report this to the Office for Product Safety and Standards (OPSS) at This email address is being protected from spambots. You need JavaScript enabled to view it.. Note that the regulations contain exemptions for certain specific types of buildings such as supported housing and student accommodation.

If your home has an individual meter, the most important things you can do to protect yourself against billing issues are:

1) Find your heat meter. It will be separate to your electricity meter. Sometimes it’s inside the Heat Interface Unit (HIU) that brings hot water into your home, with the display visible through a window.

2) Read your meter as soon as you first move in and at regular intervals afterwards (ideally at least quarterly).

3) Find out if your supplier also reads your meter (remotely or in person), or if you have to send your own meter readings to your supplier, and how often this should happen.

4) Send your own meter readings to your supplier if you’re required to do so, or if you have the option to do so voluntarily.

5) Keep copies of all the meter readings you take.

6) Compare your own meter readings with those given on your bills and raise any discrepancies with your supplier as soon as possible. Check your bill for your heat supplier’s contact details.

If you have a meter, an in-home display (IHD) and/or a pre-payment (‘pay as you go’) device, your heat supplier should provide you with guidance on how to use this to view your consumption. You can often find guides and Frequently Asked Questions on the website of the company that’s sent you your heat bill.

This section of information is for consumers who are leaseholders of a freeholder landlord as the building owner. It will apply to most flat owners, or part-owners of flats under a shared ownership scheme, in both the private and social housing sectors. The building owner could be a private housing developer or freeholder, or a council (local authority) or housing association.

About leasehold

Purpose-built blocks of flats are usually sold as leasehold in England and Wales (sometimes they are sold as ‘commonhold’ or ‘share of freehold’, which we cover in separate sections below). The buyer of the flat buys the right to occupy and use the flat for the duration of a long-term lease, subject to the terms of a legal contract (the lease agreement) with the freeholder.

Under this form of home ownership, the owner or shared owner of the flat is effectively a tenant (a ‘leaseholder’) of the freeholder. The freeholder owns the building and the ground (land) it stands on, and acts as the landlord. For private leasehold buildings, the initial freeholder is usually the housing developer – who then often sells the freehold on to another private entity after a period of time.

A freeholder is usually a company but can be an individual. The freeholder often subcontracts the day-to-day management of the building to a managing agent, to whom leaseholders pay service charges for building maintenance and repairs.

How to identify your heat supplier

If you’re a leaseholder and your heat charges are included in your leasehold service charges, then your freeholder landlord is likely to be your contractual heat supplier under your lease. General service charge protections will apply to you under leasehold law. These include a limitation that the freeholder landlord can’t demand payment of service charges for costs they incurred more than 18 months ago (unless they’ve previously notified you that they’ve been incurred).

If you receive bills for heating charges from a company who isn’t your freeholder landlord or their building managing agent, and which are separate from your service charges, then your freeholder landlord is probably still your heat supplier. The company billing you for heat is likely to be a heat network metering and billing agent – a subcontractor acting on the supplier’s behalf. Check the wording on your bill or the website of the company billing you, to see if it explains this. Metering and billing agents’ websites usually have lists of Frequently Asked Questions, and some enable you to look up the name of your heat supplier using your account details or postcode.

Responsibility for heat network maintenance and repairs

Freeholders are responsible for carrying out maintenance and repairs to the building’s communal areas and infrastructure (as defined in your lease), but you’ll be required by your lease to pay your share of these costs through your service charges. Your legal protections include that the costs must be ‘reasonably incurred’ for work of a ‘reasonable standard’, and that costs above a specific amount must be subject to leaseholder consultation.

In certain circumstances leaseholders can exercise the ‘right to manage’, where they take over the freeholder landlord’s building management functions under the lease. This involves creating a Right to Manage (RTM) company, and comes with both legal rights and responsibilities. An RTM company can manage a building itself, keep the freeholder’s subcontractors or employ its own subcontractors.

Where to go for help

LEASE: The Leasehold Advisory Service (LEASE) provides free advice to leaseholders in England and Wales on residential leasehold law. LEASE publishes a specific factsheet here about leaseholders’ rights when being billed for service charges. LEASE can also help you understand shared ownership, the processes for challenging service charges through a tribunal or the courts, and the process for exercising the right to manage.

Consumer protection codes for homebuilders: If you're a private leaseholder and your home is a new build, you may have two years of certain types of consumer protection under one of the following:

These codes set out various rules around housing developers' sale, purchase and after-care processes for new homes. These include a requirement that the developer must give you accurate and sufficient information about the home during the sales process, to allow you to make an informed purchase decision.

Although these codes are voluntary, developers who are members of the main home warranty bodies are likely to be signed up to one of them. You will need to complain to your developer in the first instance. If you're still unhappy with how they've handled your complaint, you may be able to refer your complaint to independent resolution under one of these codes.

Private housing ombudsmen: If you're a private leaseholder in England, your managing agent (but not your freeholder landlord) is required by the government to be a member of either: 

If you've been through your managing agent's complaints process and are still unhappy, you can refer your complaint to whichever of these ombudsmen the agent is registered with.

In addition, your managing agent may be a voluntary member of the Association of Residential Managing Agents (ARMA, a professional association). ARMA publishes advice to leaseholders about complaints and the ombudsmen here.

Social housing ombudsmen: If you’re a leaseholder in social housing, you can complain to one of the following social housing ombudsmen. The relevant ombudsman will expect you to have gone through your landlord’s own complaint process first:

Sometimes private landlords also voluntarily register with The Housing Ombudsman (you can check this on their website using the link above).

As well as your protections as a leaseholder, you have some general protections under consumer rights law. See our section on these above.

About commonhold

Commonhold is an alternative to the long leasehold system described above. Under commonhold, buyers of individual flats within a building own their flat’s freehold without an overall time limit (lease length).

Responsibilities and protections

The rest of the building that forms the commonhold is owned and managed jointly by the flat owners, who are called ‘unit-holders’, through a commonhold association. Each unit-holder is a member of the commonhold association and their rights and obligations are set out in a commonhold community statement (CCS). Unit-holders pay the commonhold association for their share of the costs incurred in managing the building, including repairs and maintenance.

Because they have the right to be part of the decision-making processes for their building, unit-holders do not need or have many of the rights and protections that leaseholders have by law. If you are a unit-holder, your CCS will set out processes for managing disputes.

Where to go for help

LEASE (the Leasehold Advisory Service) has a guide to commonhold here and can provide advice.

About share of freehold

‘Share of freehold’ homes are usually leasehold flats, so see also our advice on leasehold above. The normal rules between the leaseholder and freeholder still apply under leasehold law, including those around service charges, maintenance and repairs.

The difference is that the person who owns both a lease and a share in the freehold wears two different legal hats. The share of freehold element essentially gives the leaseholders power to make collective decisions about the building, which may still be discharged through a managing agent and other subcontractors.

Where to go for help:

LEASE (the Leasehold Advisory Service) has information on share of freehold here and can provide advice.

Following various legal reforms, nearly all home ownership in Scotland (including flats) is through ‘outright or absolute ownership’ – equivalent to freehold ownership in England and Wales.

Rights and responsibilities

Scottish flat owners usually have shared responsibility for maintenance and repairs to communal elements of the building, often carried out by property ‘factors’ (managers).

Under shared ownership in Scotland, the buyer owns a share of the home and rents the remaining share from a housing association under an occupancy agreement. The occupancy agreement sets out rights and responsibilities, including those for maintenance and repairs.

Where to go for help

Consumer advice organisations: Citizens Advice Scotland, Shelter Scotland and Advice Direct Scotland provide advice to Scottish homeowners:

Shelter Scotland has specific advice on shared ownership rights.

Consumer protection codes for homebuilders: If your home is a new build, you may have two years of certain types of consumer protection under one of the following:

These codes set out various rules around housing developers' sale, purchase and after-care processes for new homes. These include requirements that the developer must give you accurate and sufficient information about the home during the sales process, to allow you to make an informed purchase decision.

Although these codes are voluntary, developers who are members of the main home warranty bodies are likely to be signed up to one of them. You will need to complain to your developer in the first instance. If you're still unhappy with how they've handled your complaint, you may be able to refer your complaint to independent resolution under one of these codes.

Your landlord’s responsibilities

Your landlord must ensure that your home meets minimum standards of repair and fitness for habitation. This usually includes ensuring that it’s not too hot and not too cold, and that you have a supply of hot water.

Your exact legal protections will differ depending on whether you live in England, in Wales, or in Scotland. Because of the regional differences in regulations, the number of bodies involved in enforcing them, and the potential risk of eviction, we give only general advice below with links to where you can get more help.

Generally speaking:

  • Your landlord is responsible for carrying out and paying for repairs and maintenance (unless you caused the damage). Your first action should always be to complain to your landlord, or to your letting agent if they manage repairs for your landlord.
  • You have rights to enforce these minimum standards and repairs, which (depending on your region and circumstances) could include involving your local council, going to an ombudsman, using a tribunal or taking court action.
  • The specific legislation for your region will set out what types of charges can be legally included in your rent.
Understanding your home’s heat supply arrangement

If your heat charges are included in your rent, then your landlord is effectively acting as your heat supplier as they have the contractual agreement with you to provide you with heat. In this situation, you should raise any issues about your heat supply with your landlord or letting agent before taking any further action.

If you’re a renter in a block of flats in England or Wales, your landlord could be a leaseholder tenant of the overall building owner (see information on leasehold above). Where this is the case, the overall building owner is likely to be the contractual heat supplier to the leaseholder flat owners. Repairs and maintenance to communal parts of the building will usually be the responsibility of the building owner, undertaken by a managing agent appointed by the building owner. Where this is the case, the leaseholder flat owners will be required to fund these through the service charges they pay to the managing agent. This all means that your landlord may, under the terms of their own leasehold agreement, have the overall contractual responsibility to pay for your home’s heat usage and share of heat network maintenance and repairs.

Sometimes building owners appoint dedicated metering and billing agents to collect heat charges. These agents may set up billing accounts with each resident without knowing if that resident is the actual flat owner or their tenant. If you’re getting heat bills from a company that are separate to your rent, this company is likely to be acting on behalf of your actual heat supplier (who’s usually the overall building owner). Check the wording on your bill or the website of the company billing you, to see if it explains this. Metering and billing agents’ websites usually have lists of Frequently Asked Questions, and some enable you to look up the name of your heat supplier using your account details or postcode.

Your responsibilities

Ultimately, what heat network costs you’re responsible for paying will depend on:

  • The terms of your rental agreement with your landlord or letting agent. Check what this says, including how to raise any queries or complaints with them.
  • Any separate contractual terms and conditions with the company billing you for heat, if these bills are separate to your rent. These T&Cs should have been provided to you when you set up your account to receive these bills. Check your bill for details of how to raise any queries or complaints with this company, or with the heat supplier on whose behalf they act.
  • The specific legal protections for renters in your region.
  • General consumer rights protections (see our section on these above).
Where to go for help

Citizens Advice provides help to private renters, with separate tailored advice for each region of GB:

Shelter also has separate advice sections for private renters in England and Scotland:

Social housing landlords can include local authorities, housing associations, housing trusts, arm's-length management organisations (ALMOs), housing co-operatives and tenant management organisations (TMOs).

Your landlord’s responsibilities

Your landlord must ensure that your home meets minimum standards of repair and fitness for habitation. This usually includes ensuring that it’s not too hot and not too cold, and that you have a supply of hot water.

Your exact legal protections will differ depending on whether you live in England, in Wales, or in Scotland. Because of the regional differences in regulations, the number of bodies involved in enforcing them, and the potential risk of eviction, we give only general advice below with links to where you can get more help.

Generally speaking:

  • Your landlord is responsible for carrying out and paying for repairs and maintenance (unless you caused the damage). Your first action should always be to complain to them.
  • You have rights to enforce these minimum standards and repairs, which (depending on your region and circumstances) could include using a right to repair scheme, complaining to a local councillor, complaining to an ombudsman, or taking court action.
  • The specific legislation for your region will set out what types of charges can be legally included in your rent.
Understanding your home’s heat supply arrangement

If your heat charges are included in your rent, then your landlord is effectively acting as your heat supplier as they have the contractual agreement with you to provide you with heat. In this situation, you should raise any issues about your heat supply with your landlord before taking any further action.

Sometimes building owners appoint dedicated metering and billing agents to collect heat charges. These agents may set up billing accounts with each resident without knowing if that resident is the actual flat owner or their tenant. If you’re getting bills from a company that are separate to your rent, this company is likely to be acting on behalf of your actual heat supplier (who’s usually your landlord as the building owner). Check the wording on your bill or the website of the company billing you, to see if it explains this. Metering and billing agents’ websites usually have lists of Frequently Asked Questions, and some enable you to look up the name of your heat supplier using your account details or postcode.

Your responsibilities

Ultimately, what heat network costs you’re responsible for paying will depend on:

  • The terms of your housing agreement with your landlord. Check what this says, including how to raise any queries or complaints with them.
  • Any separate contractual terms and conditions with the company billing you for heat, if these bills are separate to your rent. These T&Cs should have been provided to you when you set up your account to receive these bills. Check your bill for details of how to raise any queries or complaints with this company, or with the heat supplier on whose behalf they act.
  • The specific legal protections for social tenants in your region.
  • General consumer rights protections (see our section on these above).
Where to go for help

Citizens Advice provides help to social housing tenants, with separate tailored advice for each region of GB:

Shelter also has separate advice sections for social tenants in England and Scotland:

If you’ve exhausted all other avenues for help, you could try writing to:

  • Your local member of parliament (using the guidance here).
  • Your local councillor (who you can look up here).