Heat network fit and proper test and SMRI declarations
Ofgem requires the people who run heat networks to be fit and proper. You make a declaration about this when you register. This guide explains what it means for a small company running a block's heating.
Last checked against official sources: 5 October 2026
The requirement
Ofgem's authorisation conditions say an authorised person must not appoint, or have in place, a person in a position of significant managerial responsibility or influence (SMRI) who is not a fit and proper person. In assessing this, the conditions look at matters such as whether the person has been responsible for, contributed to or facilitated any serious misconduct.
Who has SMRI
For a small residents' management company or RTM company, this is likely to include the directors and anyone else who makes the key decisions about the heating, such as a managing agent's lead manager. Keep an up-to-date list.
The SMRI declaration
Ofgem says that, as part of registration, you complete and submit an SMRI declaration, unless your organisation already has a current one on its digital service account. SMRI declarations expire after 3 years.
The declaration confirms that you comply with the fit and proper obligation, for example by having policies and procedures in place to make sure everyone with SMRI is fit and proper.
A simple process for a small company
- Adopt a short fit and proper policy.
- Ask each person with SMRI to sign a declaration on appointment, and again each year.
- Check the public registers: the Companies House disqualified directors register and the Insolvency Service's individual insolvency register.
- Ask people to tell the board promptly if their circumstances change.
- Keep the signed declarations and check dates securely, and diary the renewal of your SMRI declaration to Ofgem before it expires.
Questions
- Does a past problem automatically rule someone out?
- Not necessarily. Consider each case fairly against the requirement, and take advice if you're unsure.
- A new director has joined. What should we do?
- Ask them to sign a declaration, run the register checks, update your list, and check whether your SMRI declaration to Ofgem needs updating.
Sources
Related guides
How to register a heat network with Ofgem
A step-by-step guide to registering an existing heat network on Ofgem's digital service by 26 January 2027: who registers, what you need and what happens next.
Heat network continuity plan: what it must include
Ofgem's minimum contents for a heat network continuity plan, the yearly confirmation, and how a small block can put one together without consultants.
Heat network operator vs supplier: who is responsible?
Who is the operator and who is the supplier of a heat network in a leasehold block: freeholder, RMC, RTM company or managing agent? Ofgem's view explained.