How the BSR Impacts FHS and Heat Network Risks

We have been considering risks with upcoming regulations given the current Building Safety Regulator requirements and timelines. The Future Home Standard (FHS) and heat network regulations provide new complications to work through with timing becoming critical. The following are two examples that can be reviewed today and added to risk registers:

• The FHS proposals includes changing the commencement definition requiring more work to have been completed before considering a development to have started (see article). The impact of this change will be tighter development programme and ensuring BSR gateway submissions are of the highest quality for first time compliance. Developers that don’t receive BSR approvals in time could find themselves having to redesign entire developments to new standards.
• The Heat Network Regulations make heat a regulated utility, like electricity or gas, and propose quality and technical standards for operational performance (see article). Achieving these standards for new heat networks require appropriate design work alongside building development which can impact submissions to the BSR (see article). Developers who do not adequately focus on heat network design performance risk holding onto assets that are not compliant with regulatory requirements. Though Ofgem have not explicitly outlined their stance on this, there is potential for delaying operations until standards are met.

There have been constant rumours of the imminent release of the FHS. However very little Government communication has been made available to help understand the timelines or the scale of the technical changes that will be adopted.

Meanwhile Heat Network Regulations have been progressing with their published implementation dates (see article). The latest interim Heat Network Regulations milestone reached was the opening of consumer advocacy and advice on 01/04/2025 through Citizens Advice and the Energy Ombudsman.