New Obligations Regarding Heat Consumption Registration and Changes in Energy Regulation
September – October 2026
During September and October 2026, the energy sector was subject to several changes. These were introduced primarily by Act No. 116/2026 Coll., which entered into force on 1 July 2026. The changes include the establishment of a register of heat consumption objects. They also introduce new information and contractual obligations. In addition, provisions of Act No. 259/2025 Coll. entered into force on 1 September 2026. These concern credits for meeting reference values when placing fuels on the market. They are linked to renewable electricity used at charging stations.
Register of Heat Consumption Objects
Act No. 116/2026 Coll., amending and supplementing Act No. 251/2012 Coll. on Energy and amending and supplementing certain acts, amended Act No. 657/2004 Coll. on Heat Energy in Article IV. It introduced a register of heat consumption objects and related information obligations for heat suppliers and final customers. These provisions have been effective since 1 July 2026.
The register is maintained by the Regulatory Office for Network Industries (ÚRSO). For each heat consumption object, it records information on its location, including the region, district, municipality, part of the municipality, street, building number and descriptive number, cadastral territory and the number of the title deed under which the object is registered (§ 30(f) of Act No. 657/2004 Coll.).
Under the transitional provision, ÚRSO is required to establish the register of heat consumption objects by 31 October 2026. The practical implementation of the obligations also depends on the technical requirements and guidance issued by ÚRSO, which should be verified before submitting the data.
Obligations of Final Customers
A final customer who allocates heat to end consumers or uses it for own consumption must provide the heat supplier with information on heat consumption objects upon request. The required data are specified in § 30(f) of Act No. 657/2004 Coll. Any changes must be reported to the supplier within 30 days.
Obligations of Heat Suppliers
A heat supplier must provide ÚRSO, upon request, with up-to-date information on heat consumption objects within the scope of the data specified in § 30(f) of Act No. 657/2004 Coll., where the supplier supplies a final customer who allocates the heat to final consumers or uses it for its own consumption.
The transitional provision also stipulates that the heat supplier must submit the data to the authority for the first time by 30 November 2026. Further deadlines and the technical method of submitting the data should be verified against the current requirements of ÚRSO.
Heat Supply and Consumption Agreements
A heat supply and consumption agreement concluded from 1 July 2026 with a final customer who allocates the supplied heat to final consumers or uses it for its own consumption must also include a list of heat consumption objects supplied with heat from the relevant delivery point or points (§ 19(2)(a) of Act No. 657/2004 Coll.).
For agreements concluded by 30 June 2026, the list is to be added only when the agreement is amended after that date (§ 38ai(2)).
Practical Implications
Heat suppliers subject to the obligation should request and verify information on heat consumption objects from their customers and prepare for the first submission of data to ÚRSO by 30 November 2026.
Property managers of apartment buildings, owners of larger premises and businesses with their own heat consumption should verify the accuracy of the data concerning their objects, review their contractual documentation and establish a process for notifying the supplier of changes within 30 days.
Further Changes in Energy and Renewable Energy
Credits for Charging Stations
From 1 September 2026, the provisions of Article IV, points 42, 50 and 51 of Act No. 259/2025 Coll. apply. These provisions regulate credits under Act No. 309/2009 Coll. on the Promotion of Renewable Energy Sources for meeting reference values when placing fuels on the market.
The credit mechanism applies to renewable electricity used to charge electric vehicles through a charging station. The specific scope of eligibility for credit issuance, registration obligations, the method of recording, deadlines and conditions for demonstrating the origin of electricity are governed by §§ 14a to 14cc of Act No. 309/2009 Coll.
Electricity and Gas Supply
Act No. 116/2026 Coll. amended the mandatory requirements for electricity and gas supply agreements.
From 1 July 2026, an agreement must include information on whether the customer is a household customer and information on the nature of consumption at the delivery point (§ 17c(1) of Act No. 251/2012 Coll.).
The customer provides this information to the supplier when concluding the agreement. Suppliers must also reflect the information in their records.
Agreements concluded by 30 June 2026 are to be supplemented when amended after that date.
A gas supplier must fulfil its record-keeping obligation no later than 1 January 2027. For household customers whose contractual relationship was established by 30 June 2026, the deadline is no later than 1 July 2027.
The rules for determining vulnerable customers and applying the relevant rates continue to apply in accordance with the law and implementing regulations. For a specific delivery point, the current requirements under the applicable legislation should be verified.
Incorrect application of a household tariff to a delivery point belonging to a business or to a person who does not meet the statutory conditions may have sanction-related consequences under Act No. 250/2012 Coll. The specific offence, the person subject to the sanction and the amount of the fine must be assessed under the current wording of the law.
What Should Businesses Review?
- Heat suppliers: Request and verify information on heat consumption objects from customers and prepare the first submission of data to ÚRSO by 30 November 2026. Further deadlines and the method of submission should be verified against the current requirements of ÚRSO.
- Customers allocating heat or using it for their own consumption: Check the information on heat consumption objects and establish a process for notifying the supplier of changes within 30 days.
- Heat supply and consumption agreements: New agreements must include a list of heat consumption objects from the outset. For agreements concluded by 30 June 2026, the list is added when the agreement is amended after that date.
- Electricity and gas supply agreements: Add information on whether the customer is a household customer and on the nature of consumption, and verify the relevant records in accordance with the applicable obligations.
- Charging station operators: Review obligations related to the credit mechanism under §§ 14a to 14cc of Act No. 309/2009 Coll.
Conclusion
The most significant change during the period under review is the introduction of the register of heat consumption objects and related information obligations. In this context, heat suppliers must provide ÚRSO with up-to-date information on heat consumption objects upon request. The required data are specified in § 30(f) of Act No. 657/2004 Coll.
The first reporting deadline is 30 November 2026. By this date, heat suppliers must submit the relevant data to the authority for the first time under the transitional provision. Furthermore, the technical method of submission and subsequent deadlines should be verified against the current requirements of ÚRSO.
As of 1 September 2026, provisions on credits for renewable electricity used to charge electric vehicles also apply. New requirements for electricity and gas supply agreements have been in force since 1 July 2026. Therefore, businesses should review their recorded data, contractual documentation and notification processes ahead of the relevant deadlines.
