Heat network registration: is it the managing agent or the freeholder?

Usually the freeholder or RMC, with the managing agent doing the work on their behalf. It depends on who Ofgem treats as the operator and the supplier.

The operator

Ofgem's operator is the organisation with control over and responsibility for the network: the one that typically owns the plant and makes the big decisions, such as replacing the boiler or major upgrades. That stays true even when contractors carry out the day-to-day maintenance.

The supplier

The supplier holds the contractual and customer-facing side: billing, complaints and communication with residents. Heat recovered through the service charge can still count as a supply.

What that means in a leasehold block

In most blocks, the guidance points to the freeholder or the RMC as operator and supplier, with the managing agent acting for them. One organisation can hold both roles. Where they're split, the operator registers first and then invites the supplier through Ofgem's service.

Agents aren't off the hook in practice. They hold the building records, the contractor relationships and the billing, so they're the ones who'll be asked to make registration happen.

If the parties disagree

Ofgem won't rule on individual cases or settle disputes between parties. Where responsibility is genuinely contested, that's a question for a solicitor.