The Australian Competition Consumer Commission (ACCC) recently released a discussion paper which sets out three models for accessing consumer energy data under the Consumer Data Right (CDR) regime. The three options considered by the ACCC were:
- A centralised model - where the Australian Energy Market Operator (AEMO) would hold all relevant consumer data sets from relevant market participants (for example, retailers, distributors, metering coordinators etc).
- A gateway model – where AEMO would act as a pipeline for the requests between data holders and data recipients but would not be responsible for holding all the relevant CDR data sets.
- The banking model – modelled on the systems and standards established in the banking sector to facilitate CDR and works on a business-to-business API structure.
AGL supports the development and application of the CDR to the energy sector and we remain committed to working with the ACCC, consumer groups and other industry participants to properly assess the impacts the regime can have to consumers and competition during the design phase. The model to deliver CDR effectively is a key consideration in developing an effective CDR framework for energy and we welcome the ACCC discussion paper.
AGL’s position on the ACCC discussion paper is broadly:
- We do not support a central model – noting the lack of consumer consideration in this proposal, security risks, and the potential costs and technical complexity to manage a central database which will only increase over time as the ACCC expands the scope through future versions of energy CDR.
- While we conceptually believe the other two models will deliver better outcomes, our submission outlined a number of areas that further information on the other models is required before being able to properly assess which is more appropriate for the energy sector. These factors include:
- User verification and authentication
- Security
- Consumer trust and control
- Data verification and alignment
- The need to undertake consumer testing and insights research to understand the likely engagement pathways for consumers under the CDR regime.
AGL recently made a submission on Consumer Experience work undertaken by Data 61 which can be accessed here.
Our submission to the ACCC is available here.