AGL urges Treasury to focus on getting the Draft Energy Rules right following energy sector feedback on Treasury’s latest consultation on the Consumer Data Right (CDR) in the energy sector: proposals for further consultation, August 2021 (Consultation), and the release of the energy specific CDR rules (Draft Energy Rules). In its response, AGL raises serious concerns with the proposed CDR implementation pathway and the inclusion of all NEM retail customers being eligible to access the CDR regime. AGL has been a consistent and vocal supporter of the CDR regime as an economy wide model that enables consumers to have access to, and control over, data that directly relates to them. However, AGL recommends that the proposed date of 1 October 2022 for Tier 1 retailers to comply with the CDR be extended until at least 1 July 2023 to allow proper time for retailers, together with AEMO and Accredited Data Recipients, to implement the significant system changes and business processes that need to be developed, tested and implemented to allow for an effective and functioning CDR regime to be rolled out to consumers. Further, AGL recommends that the priority consumer segments, residential and small and medium enterprise businesses (small customers), are the appropriate starting point for the CDR regime with large customers being removed from the first iteration of the CDR. Extension of the Draft Energy Rules to include large business customers does not reflect an understanding of how these customers interact with their energy retailers nor from an IT systems perspective in how these segments are onboarded, managed and billed. We also believe CDR will not improve large customer outcomes because the current bespoke arrangements provide these customers access to far greater granular and tailored information than CDR would offer. Without proper consultation with the energy industry and an arbitrary date set for the CDR regime to take effect not based on any project management assessment, AGL raises serious concerns in its submission that this could result in poor customer outcomes and an overall lack of consumer trust in CDR. We elaborate on these significant issues and others in our response.