AGL recently responded to the Australian Competition and Consumer Commission’s (ACCC) Consumer Data Right (CDR) Energy Rules Framework consultation.
AGL has been a strong advocate of CDR being introduced into the energy sector, actively engaging in the discussion for over two years as we recognise the benefits that the CDR can deliver Australian consumers and the broader economy.
The ACCC’s Framework consultation focuses on two key areas:
- Governance matters relating to how consents and authentication should occur for energy participants, who should be responsible for the consumer dashboard, tiered accreditation, dispute resolution approaches etc.
- Electricity data maters relating to the designated data sets, and whether energy data is less sensitive (in full or in part) when compared to the banking sector.
In our submission, we provide comments on the Framework consultation for energy and note that:
- The ACCC should pursue a ‘minimum viable product’ approach as was taken in version 1 of the banking CDR.
- Energy data should not be considered as less sensitive than banking data as it can reveal a lot about an individual but tiering data will also create unnecessary complexity in the CDR system.
- To fully realise the benefits of the CDR the ACCC must ensure interoperability is preserved. This will help provide a consistent experience for consumers and will minimise the costs of other participants (both accredited data recipients and data holders).
- To achieve the interoperability objective, the proposed Gateway model should be limited to data transfer/conduit role between CDR participants. This should be explicitly stated within the ACCC Rules.
- The CDR Rules should leverage existing business processes, systems and customer relationships to maximise benefits (therefore promoting a retailer based authentication model and retailer facilitated consumer dashboard).
You can access our full submission to the ACCC here.