Guidance

Guidance on the Energy Bill Relief Scheme pass-through requirements for heat networks in the UK

Updated 29 September 2023

Overview

Under the Energy Prices Act 2022, the government has established a requirement that any energy price support is passed on to end users. This means that intermediaries in the UK in receipt of support from the Energy Price Guarantee, Energy Bills Support Scheme, and/or the EBRS (Energy Bill Relief Scheme) must pass on the benefit obtained to the end users, as the intended beneficiaries of the relevant schemes. A heat supplier which has been provided with a benefit under the EBRS is counted as an intermediary. In some circumstances, a heat supplier does not need to be in receipt of EBRS to be counted as an intermediary. This guidance clarifies the requirements in each circumstance. A heat network consumer is counted as an end user.

Heat networks usually purchase energy to supply heat through commercial contracts. As non-domestic consumers, heat networks will receive support from the Energy Bill Relief Scheme. This will reduce wholesale gas and electricity unit prices for commercial energy suppliers and reduce the prices that they offer to the market. Throughout this guidance, reference to the ‘EBRS’ means both the Energy Bill Relief Scheme for Non-Domestic Customers in Great Britain and the Energy Bill Relief Scheme for Non-Domestic Customers in Northern Ireland.

For heat networks that utilise Combined Heat and Power (CHP), accompanying legal guidance can be found in (Chapter 2 of Part 4 – Arrangements for Customer to deliver electricity to the grid (GB and NI Schemes)). The CHP guidance should be read in conjunction with this guidance.

The government brought into force regulations in Great Britain on 1 November 2022, regulations in Northern Ireland on 5 November 2022, and further regulations on 7 December 2022 introducing the following requirements on heat suppliers:

• to provide information to the Secretary of State for the heat networks they operate. Heat suppliers are required to submit their name, business address and contact details in the Heat Networks Energy Bill Relief Scheme (EBRS) Pass-through Notification Form. This applies to all heat suppliers, even those not in receipt of EBRS.
• to pass on the benefit of the EBRS to end consumers, both domestic and non-domestic, and provide consumers with information on how the ‘pass-through’ will be effected. This only applies to heat suppliers in receipt of EBRS. See information below on being in receipt of EBRS and resulting responsibilities for heat suppliers.

For heat suppliers in Great Britain (even those not in receipt of EBRS):

• to register for the redress scheme, administered by the Energy Ombudsman, which will allow domestic and microbusiness consumers on heat networks to raise a complaint if they have not received the benefit of the EBRS. Heat suppliers subject to consumer complaints will need to pay the Ombudsman a case fee to cover the costs of investigating a complaint, as is the case for Heat Trust registered participants and gas and electricity suppliers. More information can be found on the Energy Ombudsman’s website. Heat suppliers can also contact [email protected] for more information on the redress scheme.

For heat suppliers in Northern Ireland:

• domestic and microbusiness consumers on heat networks will be able to raise a complaint with the General Consumer Council for Northern Ireland (CCNI). More information will be provided shortly on how consumers will be able to raise complaints with the CCNI and requirements on heat suppliers. Consumers can contact the CCNI at [email protected].

Who is the heat supplier? What are end users?

The heat supplier will be responsible for notifying to the OPSS and meeting requirements to pass on the benefit of the EBRS to end users. The heat supplier is the body responsible for supplying and charging for the supply of heating and/or hot water to premises through the heat network. In most cases, this will be the body with a heat supply contract or equivalent with the consumer.

The following examples will help illustrate who the heat supplier is:

• a housing association has a heat supply contract with its residents, stating that it is responsible for the supply of heat. The housing association contracts out the metering and billing services to a billing agent. The housing association is still classed as the heat supplier under these Regulations as it has a contract to supply heat network customers with heating and hot water.
• a landlord charges its residents for the supply of heat via a service charge. The landlord enters into a contract with an energy service company (or management company), for the purchase of energy from the wholesale market and to calculate the heat billing on the service charge. The landlord is still classed as the heat supplier under these Regulations as it holds the contract with the heat network customers to supply heating and hot water, via the leasehold and tenancy agreement which also holds details of the service charge arrangements.

Some requirements under the Regulations apply to all heat suppliers. Some requirements only apply to those heat suppliers who are in receipt of the EBRS. See When will heat suppliers deemed to have been provided with the EBRS? for more details on whether a heat supplier is in receipt of EBRS.

Consumers on the heat network who purchase heating and hot water for their own consumption (‘heat network consumers’) are referred to as end users. These consumers are the ultimate beneficiaries of the benefit of the EBRS and heat suppliers should pass this benefit on to them. Ordinarily, consumers do not need to do anything to receive the benefit of the EBRS.

However, if they do not receive the benefit or their heat supplier does not otherwise comply with the regulatory requirements, they will be able to make a complaint and will have recourse to civil proceedings (see ‘Actions a heat network consumer can take if their heat supplier does not comply with the requirements’ section below for more information).

There will be circumstances where the intermediary (the heat supplier) is also an end user (a heat network consumer), for example where a building owner responsible for the supply of heat to residents in that building also lives in that building. In such circumstances, that person is subject to all the requirements on heat suppliers and all rights for heat network consumers as set out in the Regulations.

Requirements on all heat suppliers, whether benefiting from EBRS or not

These Regulations require all heat suppliers to provide information to the Secretary of State or Scottish Ministers for the heat network(s) they operate. Heat suppliers are required to submit their name, business address and contact details in the Heat Networks Energy Bill Relief Scheme (EBRS) pass-through notification form. This is to support the delivery of the investigation and resolution of consumer complaints by the Energy Ombudsman and the General Consumer Council for Northern Ireland (CCNI).

Existing heat suppliers must submit this notification by 6 January 2023. Heat suppliers who begin operating a network on or after the 7 December must notify within 30 days of becoming operational. This includes if the network is new or has been purchased from another supplier. In this context, becoming operational refers to the first day a heat supplier supplies heating and/or hot water to consumers through a heat network.

Currently, this requirement to register will cover all networks until 31st March 2023. If you have begun operating a network after this date, and no additional guidance has been issued, you do not need to submit information via the EBRS pass-through notification form. Please be aware that, in such circumstances, requirements under the Heat Network (Metering and Billing) Regulations 2014 will still apply.

The information submitted in the EBRS pass-through notification form will be shared with the Office for Product Safety and Standards (OPSS), the Energy Ombudsman and the Consumer Council for Northern Ireland, in line with the EBRS pass-through notification privacy notice.

Should a heat supplier change its name, business address or contact details between the time of submitting the EBRS pass-through notification form and 31 March 2023, the heat supplier can organise a resubmission by contacting [email protected].

Those heat suppliers that have already submitted notifications to the OPSS under the Heat Network (Metering and Billing) Regulations 2014 are still required to submit their name, business address and contact details under the EBRS pass-through notification form by 6 January 2023. Doing this will pause the requirement to submit the more comprehensive notification under the Heat Network (Metering and Billing) Regulations 2014 until 31 March 2023. From 31 March 2023, the requirement to notify will apply again.

What happens if a heat supplier does not submit their name, address and contact details via the Heat Networks EBRS Pass-through Notification Form?

OPSS has been appointed by BEIS to enforce the EBRS pass-through notification requirement in the UK. This involves receiving and processing heat network notifications, maintaining a UK-wide heat supplier database (which is not publicly accessible), pursuing outstanding notification submissions and undertaking enforcement action in response to non-compliance.

If a heat network supplier fails to submit the required information, the OPSS can use enforcement powers to encourage compliance. If the OPSS suspects that an entity is operating as a heat supplier without notifying, they may issue an Information Notice to that entity. Typically, you will have 10 working days to respond to an Information Notice to confirm your status as a heat supplier. Requests for extensions will be considered by OPSS.

Should you fail to respond to this Information Notice, the OPSS may issue a Notice of Intent which will make clear required actions and give you the opportunity to become compliant by:

• Providing information to the OPSS clarifying whether you are in fact operating as a heat supplier without notifying.
• Notifying to the OPSS using the Heat Networks Energy Bill Relief Scheme (EBRS) Pass-through Notification Form on the OPSS website.

Should you fail to respond to a Notice of Intent, further enforcement action may be taken and you may face a penalty notice of up to £5,000.

You may receive a Notice of Intent, with no prior Information Notice. This would happen when the OPSS has reasonable grounds to believe you are a heat supplier but have not notified.

When will heat suppliers be deemed to have been provided with the EBRS?

Heat suppliers will not be in receipt of the EBRS until their energy provider has applied the discount required by EBRS and informed the heat supplier that it is benefiting from the EBRS. In the heat supplier related Regulations this is defined as the moment the heat supplier has been ‘provided with the scheme benefit’. There are links to the relevant Regulations at the end of this page. Understanding when a heat suppler is provided with the scheme benefit is important as it triggers obligations on the heat supplier, which are detailed in the next section.

For most heat suppliers (and other business customers), information about EBRS discount on their energy costs will come as part of their regular energy bills from their energy provider. Where it is not provided as part of the bill, the EBRS Regulations require that it be provided to the business customer within 15 calendar days of issuing the bill. Energy suppliers are under no obligation to update their business customers of the discount outside of regular billing periods. Therefore, if a heat supplier is only billed quarterly, they will not be informed of the EBRS impact on their charges until this scheduled quarterly bill is issued.

It is therefore difficult to specify a precise date by which every heat supplier eligible for EBRS relief will have been notified of the discount applied to its energy charges, and therefore be deemed to have been provided with the ‘scheme benefit’.

The EBRS scheme applies to energy usage between 1 October 2022 and 31 March 2023. Note also that business customers who do not qualify for EBRS discounts (for example because they are supplied on a fixed-price contract entered into before 1 December 2021) will not receive a discount or any notification of the kind referred to above.

Obligations on heat suppliers

Once a heat supplier has been notified by its energy supplier, as described above, that it will benefit from the EBRS, the heat supplier must provide its customers with the notice outlined in the section entitled ‘The information which a heat supplier needs to provide to its consumers if it has benefitted from the EBRS’. This must be done within 30 days, beginning on the day the heat supplier is notified by its energy provider of the EBRS reduction.

For example, if a heat supplier receives an updated invoice from its energy provider on 14th December 2022, the heat supplier will have until 12th January 2023 to inform its customers with the information outlined in the aforementioned section.

The requirements on a heat supplier benefiting from the EBRS – initial notice and effecting the pass-through

Heat suppliers must notify their consumers if it has benefitted from the EBRS

It is the responsibility of the heat supplier to notify each of its consumers in writing that the heat supplier has been provided with a benefit under the EBRS. Communication methods can include but are not limited to:

• letter
• email
• text or instant message
• a newsletter

The notice must be given to consumers by the later of these two deadlines:

• 1st December 2022
• Within 30 days of the EBRS benefit being provided to the heat supplier.

In this context, benefitting from the EBRS means the heat supplier has received a billing update from their energy provider, setting out the reduced tariff they are paying. The 30 days starts from the first day the business receives this bill, not the date they are in receipt of the new tariff, as stated by the billing update. See the section entitled When will heat suppliers deemed to have been provided with the EBRS? for more details.

The notice must set out:

• the amount of EBRS benefit provided to the heat supplier;
• the period of time to which the benefit relates;
• a summary of the requirements to pass on the benefit of the EBRS to consumers;
• when and how the amount will be provided to the heat network consumer;
• details of how the consumer may resolve any dispute it has with the heat supplier about how it has complied with the requirement to pass on the EBRS benefit, which may involve the heat supplier sharing its complaints handling procedure;
• that a consumer can make a complaint to the Energy Ombudsman (in GB) or the General Consumer Council for Northern Ireland (in NI) on the grounds set out in the section below;
• that a consumer can recover the pass-through amount as a civil debt if the heat supplier does not provide the consumer with that amount.

We have published an example letter to comply with this notice requirement (Annex A). This is an illustrative example of how a heat supplier can provide a notice to its consumers. Heat suppliers are not required to use this letter template or use this method of communication (see above for examples of acceptable forms of communication).

Heat suppliers with ‘price promises’ linked to the Energy Price Guarantee will not be required to make any further reductions to consumers’ heat charges following receipt of the EBRS. Further information on this is set out in the section below and under ‘Example (c)’. However, these suppliers are still bound by the above provision of information requirements, for example by explaining to consumers why no pass-through amount will be provided.

Heat suppliers must pass the EBRS benefit on to its customers

The Regulations also require a heat supplier which has benefitted from the EBRS to pass that benefit on to heat network consumers in a just and reasonable way. The heat supplier must ensure the benefit is passed on as soon as reasonably practicable. This could be done by showing the reduction in a consumer’s bill resulting from the EBRS. The supplier must do this as soon as reasonably practicable and no later than the date the next bill is issued, unless this fell on or before 30 November 2022 or within 30 days of the supplier benefitting from the EBRS

In this context, benefitting from the EBRS means the heat supplier has received a billing update from its energy supplier setting out the reduced energy price which the heat supplier is paying. The 30 days starts from the first day the heat supplier receives this bill, not the date it has calculated the new heat price for the end user. See the section entitled When will heat suppliers deemed to have been provided with the EBRS? for more details.

The latter deadline, of within 30 days of the supplier benefitting from the EBRS, will apply to heat suppliers who begin new contracts before 31 March 2023 that benefit from the EBRS (they may have previously held long-term, low cost contracts or have only just begun operating).

A heat supplier may have been benefitting from the EBRS for at least 30 days and issued a bill after 30 November 2022 but before this guidance was updated. If this is the case, the supplier should check if the issued bill meets the guidance on passing through the EBRS and providing customers with the required information. If not, the supplier must reissue the bill with this information including EBRS pass-through as soon as possible.

We recognise that many heat suppliers implement a ‘price promise’ where prices for heat network consumers are linked to domestic gas and electricity prices and are therefore significantly lower than the rate that would be charged if prices were purely based on ‘cost recovery’ of commercial energy rates. In many cases, this involves setting variable charges in line with gas and electricity unit rates under the domestic Energy Price Guarantee (EPG).

Under these circumstances, heat network consumers will already be receiving prices comparable to other domestic energy consumers receiving the EPG and we are aware that some heat suppliers may be making financial losses in order to provide heating and hot water at these prices.

Heat suppliers that are contractually bound by price promises which link heat charges to gas and electricity unit charges under the EPG will not be required to make any further reductions to consumers’ heat charges following receipt of the EBRS benefit. An example (c) explains this further below.

Many heat supply contracts between heat suppliers and consumers will contain provisions requiring changes to the terms of the contract when new legislation introduces new requirements. We expect that these Regulations will trigger a requirement on heat suppliers with these contracts to update the heat charges stipulated by those contracts following receipt of the EBRS benefit. We expect these updates to be made as soon as reasonably practicable and no later than the date the next bill is issued,

Heat suppliers which are not benefiting from the EBRS, such as those which entered into fixed price contracts prior to 1 December 2021 (the earliest date from which contracts benefit from the EBRS), are not subject to pass-through requirements. If a heat supplier renews its contract with an energy supplier during the period in which discounts are applied to energy usage under the EBRS (1 October 2022 to 31 March 2023), that supplier will need to comply with the pass-through requirements.

The requirement on a heat supplier to pass through the benefit does not expire on 31 March 2023 if that supplier was receiving a benefit from the EBRS. For example, if a heat supplier is next due to update its heat bills to consumers in October 2023, that update must include the pass-through of the EBRS benefit from the October 2022 to March 2023 period.

How the heat supplier should pass on the EBRS benefit to heat network consumers

The Regulations require a heat supplier to provide either the full benefit it receives from the EBRS, or if less than the full benefit, a just and reasonable pass-through amount calculated in accordance with the Regulations. See the section entitled When will heat suppliers deemed to have been provided with the EBRS? for more details on receiving the EBRS as a heat supplier.

This section sets out how a heat supplier can ensure that a pass-through amount is just and reasonable. In circumstances where a supplier is, before the implementation of the EBRS, charging through a ‘price-promise’ linked to domestic electricity and gas, and therefore charging for heat at prices lower than would have been the case had it simply charged at an amount to recover commercial energy prices, then this should be communicated to its heat consumers. An example (c) is given below.

The heat supplier must provide consumers with evidence showing what factors it has taken into account in determining that the pass-through amount was just and reasonable. The factors which a heat supplier can take into account are:

• the amount which the heat supplier paid for the energy which was subject to price reductions under the EBRS;
• any other costs which the heat supplier incurred in supplying heating and hot water during the period it benefits from the EBRS. This includes costs from distributional heat losses, efficiency of generation, operational, maintenance, and capital costs, and set-up and operation costs of effecting the EBRS pass-through;
• any losses which the heat supplier has incurred as a result of the cost of purchasing energy exceeding the amount charged to consumers for the supply of heating and hot water during the period for which the scheme benefit was provided (the EBRS will apply to existing fixed price contracts that were agreed on or after 1 December 2021). For example, heat suppliers with ‘price promises’ to their consumers may have incurred losses from absorbing higher wholesale energy costs whilst holding prices for consumers down. A heat supplier can factor these losses into determining a pass-through amount.

In addition, the Regulations specify that a pass-through amount is just and reasonable if it is calculated on the same basis used by the heat supplier when calculating charges to the consumer when it was provided with the EBRS benefit. Specifically, if when it was provided with the scheme benefit, the heat supplier was calculating the price of heat charged to the consumer based on:

• the consumer’s heating and hot water consumption; or
• an amount which represents a proportion of the cost incurred by the heat supplier when purchasing the energy needed to supply heating and hot water,

the heat supplier’s calculation of the pass-through amount for each consumer must reflect this approach.

To provide further clarity, we have set out examples for (a) and (b) below for how this would work in practice. In addition, example (c) further explains the price-promise scenario described above.

Example for (a)

Scenario: A heat supplier supplies heating and hot water to five consumers on a district heat network. Each consumer pays a standalone heat tariff which consists of a variable charge based on consumption and a standing charge, meaning that each consumer is charged a different price for heat.

The heat supplier’s energy supply contract, which commenced in August 2022, now benefits from the EBRS. This means that the supplier is now paying 20% less for energy than it was under its previous energy supply contract.

Just and Reasonable Test: Having taken into account other factors, such as wider costs associated with supplying heat and hot water, the heat supplier applies a 15% reduction on the variable charge of each consumer’s bill.

Result: Each consumer receives an equal percentage reduction in their variable charge in November, with consumers who consume more and therefore pay more receiving a larger reduction in £ terms. Within 30 days of receiving the EBRS benefit (or on 1st December 2022, whichever is later), the heat supplier issues a bill, explaining to each consumer the pass-through amount they will receive and how the heat supplier determined that this amount is just and reasonable. The heat supplier also explains details of how the consumer can resolve any disputes, including the grounds on which the consumer may raise a complaint with the Energy Ombudsman or General Consumer Council for Northern Ireland.

Example for (b)

Scenario: A landlord is the heat supplier to its block of ten flats which is connected to a communal heat network in the building basement. When the landlord purchases energy, they then recover the cost of that energy from the ten leaseholders, with the cost split equally across each leaseholder (i.e. there is no variation in charge based on consumption, size of dwelling, or number of occupants). Prior to the EBRS, each household had been paying the landlord £400 per year for heating and hot water as part of ‘all inclusive’ rent.

The landlord’s energy supply contract, which commenced in April 2022, now benefits from the EBRS. This means that the supplier is now paying 30% less for energy than it was under its previous energy supply contract.

Just and Reasonable Test: Having taken into account other factors, such as wider costs associated with supplying heat and hot water, the landlord applies a 25% reduction to the heating charge.

Result: Each leaseholder receives a £100 per year reduction for the price of heating and hot water for the duration of the EBRS. Within 30 days of receiving the EBRS benefit (or on 1st December 2022, whichever is later) the landlord issues a new bill to each leaseholder, explaining the pass-through amount they will receive and how they determined that this amount is just and reasonable. The landlord also explains details of how the consumer can resolve any disputes, including the grounds on which the consumer may raise a complaint with the Energy Ombudsman or General Consumer Council for Northern Ireland.

If these scenarios do not apply, the heat supplier must apply the best available information to allocate the benefit of the EBRS amongst its consumers. The supplier can take into account the basis on which it was allocating charges to consumers at the time it received the benefit from the EBRS.

Example (c): heat supplier has already lowered prices through a ‘price promise’

Scenario: A heat supplier has linked its heat prices to domestic electricity and gas rates in a way that reduces the heat price for the consumer compared to a scenario where the heat supplier charged on a ‘cost recovery’ basis to recover the cost of commercial energy prices plus a margin for their operational costs.

The heat supplier purchases energy through commercial contracts but is committed to charging its consumers for heating and hot water at 7.2p/kWh via a ‘price-promise’. This commitment is made despite the price per kWh of heat being lower than the per kWh price that the heat supplier is able to purchase energy at under the EBRS, meaning the supplier is operating at a loss.

Just and reasonable test: Having taken into account other factors, such as the loss it is incurring and wider costs associated with supplying heat and hot water, the supplier decides to continue charging for heat at 7.2p/kWh and communicates to its consumers this rate in comparison to the best estimate of what consumers would have paid (the ‘pass-through amount’).

Result: Each consumer is informed that the heat supplier will continue to charge at 7.2p/kWh. This includes a ‘best-effort’ explanation of this rate as a discount to what the consumers would have been charged without the EBRS and how they determined that this discount is just and reasonable. The heat supplier also explains details of how the consumer can resolve any disputes, including the grounds on which the consumer may raise a complaint with the Energy Ombudsman or General Consumer Council for Northern Ireland.

The form in which the EBRS benefit pass-through should be provided to heat network consumers

The pass-through of the EBRS benefit to consumers can be effected in the following ways:

• application of a credit in the next heat bill provided by the heat supplier to the heat network consumer;
• a payment in cash or by any other means, including a bank transfer;
• reducing the fixed and variable charges in the next bill provided to the end user;
• adjusting the amount of money taken as part of a direct debit or standing order;
• a reduction in debt level that the consumer owes to the heat supplier at the time the heat supplier receives the EBRS;
• a combination of the methods set out above.

The requirement to pass on the benefit of the EBRS also applies where a heat supplier charges for heat as part of wider service or rental charges (e.g. where a freeholder is the heat supplier and charges leaseholders for heat consumption as part of a biannual service charge).

Where the owner of a dwelling rents out that dwelling to a tenant and charges a rental charge, the owner only needs to pass through the benefit of the EBRS if the heating and hot water charges were included in that rental charge at the point the benefit was received.

If the contract between the heat supplier and the heat network consumer expires or is terminated before the supplier has passed on the benefit (e.g. if the consumer moves out of the property), the supplier must pass on the amount of benefit which the consumer is entitled to as soon as reasonably practicable following the expiry or termination.

A heat supplier has complied with the pass-through requirement if it has taken all reasonable steps to effect the pass-through to the consumer but is unable to do so.

Actions a heat network consumer can take if their heat supplier does not comply with the requirements

First Action: Contact your heat supplier using template letter (Annex B)

If you believe that you should have received a benefit, did not receive enough benefit, or reasonable steps were not taken to inform you of your entitlement to the benefit, you should raise this in writing with your heat supplier in the first instance. The heat supplier should provide justification as to how they have complied with the pass-through requirement. You can use the letter template (Annex B) to contact your supplier.

Consumers can identify their heat supplier by:

• reviewing their heat supply contract, lease or tenancy agreement, which should specify the body responsible for the supply of heating and hot water to the premises.
• contacting their developer, landlord or managing agent, which will have details of the heat supplier for the building.
• contacting the organisation that issues their bills, if that organisation is not itself the heat supplier.

If you are unable to come to an agreement with your heat supplier over the pass-through amount, there are options available to resolve this, including raising a complaint to the Energy Ombudsman or Consumer Council and civil enforcement of the payment as outlined below.

Second Action: Raise a complaint with the Energy Ombudsman or Consumer Council

If you are a domestic or microbusiness customer and cannot come to an agreement with your heat supplier, you can raise a complaint with the Energy Ombudsman if based in Great Britain or the General Consumer Council for Northern Ireland (CCNI) if based in Northern Ireland. A consumer can make a complaint to the Ombudsman or CCNI on the following grounds:

• their supplier has not notified the consumer that it has benefited from the EBRS;
• their supplier has not notified the consumer of when and how it will pass on the benefit from the EBRS;
• their supplier has not passed on the scheme benefit within the timeframe required by the Regulations.
• their supplier has not otherwise complied with the requirements to pass on the EBRS benefit.

All heat suppliers in Great Britain are required to join the Energy Ombudsman’s consumer redress scheme. If a consumer raises a complaint against a heat supplier that has not joined the redress scheme, the Energy Ombudsman will contact that supplier requiring them to become a member. A refusal to join the scheme at this point could lead to enforcement action by the OPSS and may result in a penalty notice of up to £5,000.

More information on the Ombudsman, the complaints process, and the registration process can be found on the Energy Ombudsman’s website. Consumers can also find out more information by contacting [email protected].

For customers in Northern Ireland, more information on complaints can be found on the Consumer Council’s website: https://www.consumercouncil.org.uk/consumers/make-complaint. Customers can also contact the Consumer Council at the following address: [email protected].

Third Action: Recovery of civil debt

The consumer can begin civil debt proceedings to recover the EBRS benefit from the heat supplier. Should a court rule in the consumer’s favour, they will be entitled to the payment, plus interest. Interest is set at 2% above the Bank of England’s base rate and will begin to accrue from 60 days after the intermediary first receives the relevant scheme benefit.

Find support on civil debt proceedings or further guidance

Relevant legislation and other links

• Energy Prices Act 2022
• The Energy Bill Relief Scheme Pass-through Requirement (Heat Suppliers) (England and Wales and Scotland) Regulations 2022
• The Energy Bill Relief Scheme Pass-through Requirement (Heat Suppliers) (Northern Ireland) Regulations 2022
• The Energy Bill Relief Scheme Pass-through Requirement (Heat Suppliers) (Amendment) Regulations 2022 [insert link]
• The Heat Network (Metering and Billing) Regulations 2014
• Template letter from heat supplier to heat network consumer – initial notice (Annex A)
• Template letter from heat network consumer to heat supplier (Annex B)
• Guidance on the pass-through requirements for energy price support provided to intermediaries