Chris Hamlin

From Building a Regime to Running It: A Participatory Viable System Model Diagnostic of a Regulator Entering Dual-Mode Operation

Purpose: In January 2026 the Heat Networks Directorate of Ofgem moved from designing a new regulatory regime to operating it while continuing to develop it. Initially our project asked how they could develop a better operating model, but what it concluded was that they were shifting to from a single to two core activities and needed to adapt to be able to deliver in parallel. Methods: Over ten weeks the authors combined an independent diagnostic with certified Practitioner training. A preliminary recursive map, developed inside the Directorate through a Royal Academy of Engineering Policy Fellowship, became the training material: seven staff qualified as Practitioners while jointly interrogating and revising their own model. Four systems were analysed across three levels of recursion. Findings: The decisive finding was structural. Operating the regime and developing it can no longer share one management system; each needs its own delivery, coordination and adaptive capacity, introducing a new level of recursion at the top. The analysis produced 108 observations and 28 mitigations, concentrated in under-developed coordination (System 2), thin adaptation (System 4) and an absent technical authority. Implications and Contributions: The engagement offers a transferable pattern for regulators moving from design to operation. It also surfaced a recurring question: whether to keep