Executive summary
Energy UK does not support the Consumer Consent Solution (CCS) as proposed in the Retail Energy Code Company (RECCo) consultation.
While we recognise the value of improving data flows and empowering customers to consent to how their data is used in the energy sector, we have serious concerns with the proposed design. These include broad concerns with the potential value, or lack thereof, that the CCS would deliver to consumers, as well as serious concerns with the specific design details.
Specifically, we are concerned that:
- The CCS as proposed will not address the original problem the workstream set out to solve.
- It remains unclear if the benefits will outweigh the costs of delivering the CCS as proposed.
- The CCS design as proposed is highly over-engineered.
- The governance design complexity needs further thought.
- We do not support RECCo defining the user experience.
As such, we recommend that Ofgem formally reconsider the value of the CCS given the updated design details, alongside an updated impact assessment. We also recommend that our key concerns with the design details are addressed.