Decarbonising residential heat is essential for achieving net zero targets. The Netherlands and the UK are embarking on heat transitions from similar starting points, with a heavy dependence on natural gas. However, their governance approaches differ, with local municipal visions and plans playing a lead role in the Netherlands compared with a market-led approach in England and Wales. Scotland occupies an intermediate position. This article focuses on why these differences have arisen through the development of a comparative institutionalist framework. We show that heat transition governance approaches are rooted in institutional arrangements for politics, political economy and the degree of centralisation. Our framework can be applied to heat transition governance approaches more widely, but it is not aimed at evaluating different approaches and an agenda for further research would be to link governance effectiveness to institutional context.