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Heat network zoning is a framework for identifying areas where heat networks are expected to be the lowest cost, low-carbon means of heating buildings. In those areas, government and local bodies will coordinate the development of district heat networks, rather than leaving projects to emerge on a piecemeal basis. The aim is to give developers and investors more certainty that there will be sufficient heat demand to justify the upfront cost of building network infrastructure.
On current government timetables, heat network zoning is moving quickly from policy concept to delivery framework in 2026. The government has confirmed that zoning will be implemented in England through secondary legislation made under the Energy Act 2023, following consultation on the detailed policy framework. The regulations are expected to be laid in draft form shortly during spring 2026 although, at the time of writing, only a few days of spring remain.
The forthcoming regulations will be significant as they will determine how zoning works in practice for local authorities, developers, building owners, heat source owners and consumers. The government’s consultation response has already set out the intended framework, but the regulations will need to translate that policy into a scheme that is legally robust, commercially workable and administratively deliverable.
This article considers what the draft regulations should seek to address in order to achieve this.
The starting point is governance. The government consultation response refers to a heat network zoning authority, initially within DESNZ, and zone coordination bodies with local delivery responsibilities. Public materials also indicate that local bodies will be involved in refining zone boundaries, consulting locally, publishing market prospectuses and appointing developers.
The regulations should make that allocation of responsibility clear. Local authorities will want to understand not only what powers they have, but also what duties, liabilities, governance requirements and resourcing expectations come with the role. That will be particularly important where an authority may have more than one interest in a scheme, for example: as a planning authority, highways authority, landowner, housing landlord, potential customer or possible delivery partner.
The framework will need to manage those overlaps carefully. If local authorities are to exercise regulatory style functions while also supporting or participating in heat network delivery, the regulations and accompanying guidance should address conflicts of interest, decision making independence and governance separation.
Mandatory connection is likely to be one of the most sensitive parts of the zoning regime. Public guidance states that certain types of buildings and low-carbon heat sources can be required to connect within a prescribed timeframe. It identifies possible categories of mandatory connection, including new buildings, non-domestic buildings above an agreed threshold and buildings that are already communally heated. It also states that homes within zones which are not already communally heated will not be required to connect, although they may be able to do so voluntarily.
The balance here is delicate. Developers need sufficient demand certainty to justify major upfront investment. Property owners, however, need protection from disproportionate costs, impractical connection requirements or being locked into a solution that is not suitable for their building.
A clear process will therefore be needed for connection notices, exemptions, deferrals, appeals and evidence requirements. The regulations should also deal with the practical interfaces that are likely to matter most on the ground, including local authorities’ other statutory functions, planning, building safety works and leasehold arrangements. These are not peripheral issues. They are precisely the points at which a mandatory connection requirement may become difficult to implement.
One of the biggest practical issues for the forthcoming regulations is how they deal with heat network projects that are already operating, under development, or substantially progressed before zoning comes into force.
This matters because in many areas projects may already have gone through feasibility work, procurement, development agreements, gateway approvals, stakeholder engagement or investment planning. The regulations need to provide a clear route for those projects into the new regime.
The key question is not simply whether existing projects are “grandfathered”. It is what is preserved and how.
If an existing heat network project has already agreed mandatory requirements, delivery milestones, social value commitments or local decarbonisation outcomes, the regulations should make clear whether those commitments automatically carry across into the zoning framework, or whether they need to be restated as consent conditions, standard conditions, special conditions or part of a zone development plan. Without that clarity, there is a risk that secured won local commitments fall between the cracks.
That risk is particularly acute for advanced projects. A scheme may be commercially well developed, but misaligned with the statutory sequence that zoning is likely to require: zone identification, boundary refinement, consultation, designation, developer consent, approval of a zone development plan and only then connection requirements.
If earlier project documents do not map onto those statutory stages, local authorities may inherit projects that are advanced in commercial terms but difficult to supervise under the new regime.
The regulations should therefore include a clear transitional bridge. That bridge should protect legitimate pre-zoning progress, but not allow existing arrangements to bypass the core safeguards of zoning, e.g: local oversight, transparency, decarbonisation, consumer protection and enforceable delivery obligations.
Heat network zoning is not only about connecting buildings, it is also about making better use of local heat sources. Public government materials refer to the use of local sources of low-carbon heat and heat that would otherwise go to waste. The government’s zoning materials also refer to identifying local heat sources as part of the zoning process.
The regulations will need to provide a practical framework for identifying, securing and integrating waste heat sources. That raises commercial and legal questions, e.g.: how are heat source owners engaged; when should voluntary commercial agreements be expected; what happens if negotiations fail; and how are price, access, installation works and operational risk dealt with?
A heat source owner may not regard itself as being in the heat network sector at all, for example, a data centre, industrial facility or wastewater asset owner. The regulations should aim to ensure that any powers to require access to heat sources are proportionate, transparent and supported by appropriate procedural safeguards.
Enforcement will be central to whether zoning works. The government response indicates that enforcement, compliance and appeals are key parts of the intended framework. That is unsurprising: if zoning creates obligations, there must be a way to monitor and enforce them.
However, enforcement should support delivery, not simply penalise failure after the event. Local authorities and zone coordination bodies should have tools to monitor performance, require information and manage non-compliance. Developers will need a predictable regime that distinguishes between serious failures, minor breaches and issues outside their reasonable control. Building owners and heat source owners will need clear appeal routes where obligations are imposed on them.
The best framework would combine staged intervention, transparent decision-making, proportionate penalties and effective review rights. That would give the regime teeth, without making it unnecessarily adversarial.
Heat network zoning has the potential to be one of the most important changes to local heat infrastructure policy in England. It could provide the structure needed to scale heat networks, unlock investment, integrate waste heat and support local decarbonisation. But its success will depend on the detail.
The forthcoming regulations will need to convert a strong policy ambition into a regime that works on the ground. That means clear roles, fair connection rules, sensible treatment of existing projects, workable heat source powers, proportionate enforcement and practical governance for local authorities.
For local authorities, developers and building owners, now is the time to prepare. The regulations may not yet be final, but the direction of travel is clear: heat network zoning is moving from discussion to delivery.
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