Heat network licensing: partial business and regulatory impact assessment

Section 2: Engagement and information gathering

Engagement approach

We routinely engage with a broad range of heat network stakeholders including businesses which develop and operate heat networks, local authorities and public sector bodies which operate heat networks, trade associations and consumer groups. Engagement has taken place throughout the development of the 2021 Act, which sets out the rights and powers which will be available to licence holders, and while considering how best to implement these powers in light of subsequent UK legislation.

Previous engagement has included:

• Public consultation on proposals which informed the 2021 Act, the responses of which showed consensus that heat networks should be given rights similar to other utility companies to assist construction and maintenance of networks^[4].
• Convening a licensing Stakeholder Engagement Group (SEG) bringing together a wide range of stakeholders to advise on the implementation of the 2021 Act. Feedback from the SEG consistently recognised the importance of rights and powers, while noting possible regulatory duplication with GB legislation.
• In May 2025 we held a series of stakeholder workshops seeking views on broad proposals to move from a mandatory licensing regime to an opt in approach.

The current consultation is the primary opportunity to engage and gather information on our proposals to inform any future legislation.

Internal SG engagement/ engagement with wider Public Sector

Internal SG engagement

All relevant policy areas within Scottish Government have been consulted, including:

• Directorate for Energy & Climate Change: teams responsible for Heat in Buildings regulation; teams responsible for heat network delivery programmes such as the Heat Network Fund and Heat Network Support Unit.
• Transport Scotland: Roads – operations team
• Directorate for Financial Management: Finance Business Partner.

UK/ Devolved Administrations

The Scottish Government routinely engages with the UK Government and devolved administrations at official level. In particular we regularly speak to officials at the Department for Energy Security and Net Zero (DESNZ). We have kept UK officials aware of our proposals, and sought updates on equivalent regulations being developed south of the border to ensure regimes will be as interoperable as possible.

Wider Public Sector

The Scottish Government routinely engages with officials at the energy regulator Ofgem. We have kept Ofgem officials aware of our proposals, and sought updates on their proposals to deliver regulatory regimes under the Energy Act 2023, to ensure regimes remain interoperable.

We have also engaged with local authorities which may be responsible for heat networks in their area, as well as public sector organisations such as universities, the NHS and Police Scotland, which own and operate large buildings with high heat demand which can act as ‘anchor loads’ for heat networks.

International

Not applicable.

Business / Third Sector engagement

We routinely engage with businesses involved in designing, constructing and operating heat networks.

Public consultation

This Partial BRIA accompanies a public consultation on our proposals which will run from 13 March 2026 to 5 June 2026. Consultation events are planned in March 2026 and May 2026.

Other stakeholders

Not applicable.