Energy UK response to Consumer Consent Impact Assessment

Executive summary

Improving data flows and empowering customers to consent to how their data is used in the energy sector is strongly supported. However, members have noted some key concerns with the impact assessment which we don’t feel have been adequately addressed.

Energy UK is particularly concerned that the Impact Assessment (IA) does not sufficiently evidence the expected outcomes, lacks clarity on assumptions, and underestimates implementation complexity across the industry. We share Ofgem’s commitment to improving consumer control over data but believe the Consumer Consent Solution, as currently proposed in the IA, does not clearly evidence the benefits and how these will be achieved.

Energy UK would also prefer to see a broader strategy focused around interoperability between existing consent mechanisms, improved data sharing in the sector, and aligned with broader digitalisation initiatives – it’s difficult to understand how they currently support each other. While Energy UK support the principles of the programme, we are concerned the implementation costs may be higher than anticipated and could impact customers, without building further trust in the energy system the solution is setting out to do.

If you have any questions about this response or wish to engage with Energy UK and its members, we would welcome further engagement.