Harmonised Model for Supplier Switch Report X/2013 Harmonised Model for Supplier switch Report X/2013 NordREG c/o Energy Market Authority Lintulahdenkuja 4, 00530 Helsinki Finland Telephone: + 358 10 605 000 E-mail: virasto@energiamarkkinavirasto.fi Internet: www.nordicenergyregulators.org NordREG c/o Energy Market Authority Lintulahdenkuja 4, 00530 Helsinki Finland Telephone: + 358 10 605 000 E-mail: virasto@energiamarkkinavirasto.fi Internet: www.nordicenergyregulators.org Table of content 1 Introduction 5 1.1 Scope 6 1.2 Objectives 2 Harmonised Model for Supplier Switch 2.1 Information gathering 9 2.1.1 Information gathering – Customer 2.1.2 Query Metering Point data for notification of new supply 2.1.3 Information gathering of existing contract – supplier10 2.2 Switching messages 10 2.2.1 Notification of new supply 2.2.2 Confirm or reject the supplier switch 11 2.2.3 Information from supplier to customer 11 2.2.4 Cancelation during switching process 12 2.2.5 Notify old supplier 2.2.6 Meter Reading 12 2.3 After the switch 13 2.3.1 Final settlement 13 2.3.2 Roll back a faulty switch 7 8 9 10 12 13 10 2.3.3 Cancellation during the cooling off period 13 3 Overview of the switching process 4 Appendix I, Glossary 15 5 Appendix II, Summary of 2008th switching model 14 16 List of figures: Figure 2.1General figure of the harmonised model for supplier switch. Figure 3.1 Recommended switching process from 2015 14 Figure 5.1 Illustration of switching process from 2008 17 8 List of tables: Table 2.1 Recommendations on customers’ ability to gather information 9 Table 2.2 Minimum list of data elements needed to send notification of new supply Table 2.3 Notification of new supply 11 Table 2.4 Confirm or reject the supplier switch 11 Table 2.5 Information from supplier to customer 12 Table 2.6 Cancelation during switching process 12 Table 2.7 Notify old supplier 12 Table 2.8 Meter reading 13 Table 5.1 Harmonised switching model from 2008 16 10 Introduction As part of the development towards a common Nordic retail market NordREG has worked on identifying key business processes that needs to be harmonised. This report will focus on the supplier switching process which is one of the most important processes in the retail market. Differences in national rules and practices in supplier switching were identified as a significant regulatory obstacle for establishing a harmonised Nordic retail market in the NordREG’s report “The integrated Nordic End-User Electricity Market”. Even if the supplier switching models of the Nordic countries are to some extent similar, some relevant differences still persists. These differences constitute an obstacle for the harmonisation of the Nordic retail market, since major differences may prevent the suppliers from being active in all the Nordic countries and thus reducing the potential gains of having a common retail market for the Nordic countries. For this reason NordREG presented a harmonised model for supplier switching in 2008. The switching model presented in this report is an elaboration of that model. The recommendations presented in this report are aiming at facilitating the realisation of a Nordic retail market by 2015. Some of the recommendations are also more forward looking and aims to make the most efficient use of new technology implemented in the future Nordic retail market and hence obtaining more secure, quick and easy processes in the retail market. To implement the future recommendations fully each country has to have very efficient information exchange systems and roll out smart meters. When developing the harmonised model for supplier switching the following four principles has been taken into account: 1. Procedures for switching supplier should be as smooth, easy, quick and secure as possible. 2. It is truly important that the distribution system operators (DSOs) and the information exchange system (IES) are totally neutral towards all market participants in relation to supplier switching. DSOs should have the responsibility for retrieving the meter readings and provide information about meter characteristics and act only as a device for providing this information. 3. Meter readings should be as accurate as possible when customer switch supplier. This could be done with remote reading at the hour of the start of supply. 4. Customer’s rights should always be protected. It is important for market functioning that the customers keep trusting the liberalised electricity markets. This report emphasises the following stages in the harmonised model for supplier switch: Information gathering: • Information gathering -customer • Information gathering -supplier • Information gathering of existing contract -supplier Switching messages: • Notification of new supply • Confirm or reject the supplier switch • Information from supplier to customer • Notify old supplier • Meter reading • Cancelation during switching process After the switch: • Final settlement • Roll back a faulty switch • Cancellation during the cooling off period Scope This report presents recommendations for the harmonised switching process, pointing out responsibility, time frames and content of message. This switching process should be used as a checklist when developing national switching processes to facilitate a Nordic retail market. Recommendations for critical areas that are essential for the future switching process are also made in the report. This follows from the task C4 I “Recommend harmonised rules for supplier switching, including content of messages, timeframes and responsibilities” which was presented in NordREGs Work Programme for 2012. The main target groups for this report are national Governments, suppliers, distribution system operators (DSOs), transmission system operators (TSOs), national point of information and regulators. With national point of information NordREG means a point where market actors can access information, for example database and/or hub. The focus of the report is on the regulatory aspects of the switching process. This report will answer the following questions: • Who should be involved in a supplier switch? • What should be the timeframes for processes within the supplier switch; such as sending and replying to messages, control of meter readings etc.? • What content should be required in each message regarding the supplier switch, and who should be responsible? The report does not cover the complete list of information needed for suppliers to provide offers etc. As done today at national levels, the more detailed processes should be developed by the industry. The report will also not include issues related to other business processes such as moving and starting/ending contract which will be dealt with in separate reports. Technical aspects regarding information exchange systems are not within the scope of this report. General contractual rules/laws or legal aspects will only be discussed when they affect the suggested harmonised model for supplier switching. The report does not take any stand regarding supplier switch during the cooling off period. It is up to the supplier to decide whether to take the risk of starting supply before the end of the cooling off period. This paper will provide input to the later reports, such as the moving process report and the information exchange report. These processes should be aligned. Objectives NordREG has setup number of objectives that the recommendations for the future Nordic retail market should be in line with. The overall target is to bring the Nordic retail markets closer to each other by harmonising the rules, but at the same time the target is also to create a better market, a market that is more efficient with more competition and that is easy to act in for a customer. The recommendations in this report have therefore been designed with these objectives in mind: • Customer friendliness. One of the objectives of the common Nordic retail market is to increase the customer friendliness of the market and to make it easier for the customer to be active in the market. • Well-functioning common market. The goal is to have a wellfunctioning common electricity market (wholesale and retail). Improved competition. To improve competition among suppliers, for instance through low entry and exit barriers, is an important objective. • Improved efficiency. Customers will benefit from improved efficiency in the market. • Compliance with EU regulation and development. The suggested solutions comply with the general development in the EU and with existing and coming EU regulation. • Neutrality of DSOs. DSOs should function as market facilitators. Harmonised Model for Supplier Switch In 2008 NordREG mapped the supplier switching processes in the Nordic countries and, based on the detected differences and recommended a harmonised switching model for the countries based on some key elements. The recommendations from 2008 form the basis for the new switching model presented in appendix II. NordREG defines the switch as an action through which the customer acts and changes his/her supplier. The meter point associated with the customer must be re-registered with the new supplier. The new harmonised switching model consists of two stages: • Information gathering • Switching messages After the switch is completed there is a need for a final settlement. In case of errors there might be a need to roll back the switch. This chapter describes the harmonised switching model with content of message, time frame and responsibility. Figure 2.1General figure of the harmonised model for supplier switch. 2. 3. Information gathering Harmonised Model for Supplier Switch Information gathering -customer Confirm or reject notification the supplier switch Notification of new supply 1. Information gathering- supplier Switching messages After the switch Information from supplier to customer Cancelation during switching process Notify old supplier Meter read Final settlement Roll back a faulty switch Information gathering of existing contract - supplier Figure 2.1General figure of the harmonised model for supplier switch. 2. 3. Information gathering Harmonised Model for Supplier Switch Information gathering -customer Confirm or reject notification the supplier switch Notification of new supply 1. Information gathering- supplier Switching messages After the switch Information from supplier to customer Cancelation during switching process Notify old supplier Meter read Final settlement Roll back a faulty switch Information gathering of existing contract - supplier Information gathering The customer searches and verifies information before entering an agreement with a new supplier. With the customers consent the new supplier can gather and verify information about the customer with the intention to start the supplier switch. Information gathering – Customer A supplier switching process starts with a customer initiative, or a customer’s acceptance to an offer from a new supplier. To ensure fair and efficient competition for all suppliers in the Nordic end-user market, NordREG sees that it is extremely important that customers are able to make fully informed switching decisions, for instance by using price comparison tools. NordREG considers that there should be at least one neutral price comparison tool available in each country that provides up to date, reliable information on available offers. Customers are responsible for knowing about existing contract terms when it comes to expiration date and if there are contractual fees in place. It is therefore very important that customers have easy access to this information. NordREG believes that in future markets, with a more supplier centric orientation and smart metering, customers will be better informed regarding information on personal energy consumption. The supplier may for instance present combined consumption and price data to customers in internet portals and/or mobile/notepad applications. These same portals may be useful for communicating contract terms. However, it is customers who in the end are responsible for keeping themselves informed on their current contract terms. Recommendations: • The customer should always have access to reliable and up to date information on available offers through a neutral price comparison tool • The current supplier has responsibility to provide information to the customer on existing contract, expiry date and the existence of an eventual fee for breaking the contract and terms of notice to the customer upon demand. This should be easy accessible. Table 2.1 Recommendations on customers’ ability to gather information Query Metering Point data for notification of new supply The new supplier queries information regarding a certain Metering Point from the DSO or the national point of information. This is done in order to verify and collect necessary information to start the switch. The output does not cover the complete list of information needed for suppliers to conduct their business. As done today at national levels, the more detailed list should be developed by the industry. This list of data elements is the minimum output needed to send notification of new supply: Content of message: • Customer Name • Date of birth /Organization ID • Metering Point ID • Metering Point Address Time Frame: Requested information should be accessibly any time on demand. Responsibility: There must be a contractual agreement in place in order for a supplier to collect information about the metering point. The DSO is responsible for providing up-to-date information on the metering point to the point of information. Table 2.2 Minimum list of data elements needed to send notification of new supply Information gathering of existing contract – supplier In some markets it is common that customers risk a fee for breaking a supply contract too early when switching supplier. In these markets it would increase customer friendliness and efficiency if the new supplier, on behalf of the customer, can access information on notice period and expiration date through the national point of information. The current supplier would then be responsible for providing this information to the national point of information. It is important that this information is up to date. The new supplier should be able to access this information instantly and inform the customer about notice period, expiration date and the possible risk of fees. Switching messages After the customer and the new supplier have made an agreement to switch, the new supplier starts the switch by sending a notification of new supply to the DSO or the national point of information. A transaction ID is then created, and each process should be traceable back to this ID.The time limit for the switching process should be calculated from the moment the DSO or the national point of information receives the notification of new supply. Each message should receive an immediate confirmation. If the message is rejected the reason for the rejection should be stated. Notification of new supply Notification of new supply is a message sent from the new supplier to the DSO or to the national point of information. The new supplier can send this message after all necessary data has been collected and verified. The list of data elements below is not intended to be the complete list. As done today at national levels, the more detailed list should be developed by the industry. This list of data elements is the minimum needed to notify new supply: Content of message: • Metering point ID • Start date for supply • New Supplier ID • New balance responsible ID Time Frame: This should happen as soon as possible after a contract has been agreed upon. Responsibility: Supplier is responsible for sending Notification of new supply. Table 2.3 Notification of new supply Confirm or reject the supplier switch This message is a response to the notification of new supply. It is sent from the DSO or national point of information to the new supplier, confirming or rejecting the supplier switch. The message does not cover the complete list of information needed for suppliers to conduct their business. This message can for instance also contain historical annual consumption. As done today at national levels, the more detailed list should be developed by the industry. Confirm or reject the supplier switch: Information on; confirmation or rejection: Time Frame: • Confirmation/Date of switch • Rejection / Reason for reject Change of Supplier Confirmation of Notification of new supply should be sent instantly and in any case no later than one day from the Notification of new supply has been sent. Responsibility: DSO or national point of information is responsible for sending information on confirmation or rejection of Notification of new supply. Table 2.4 Confirm or reject the supplier switch Information from supplier to customer National laws require the new supplier to send a confirmation of the contract to the customer. If the supplier wants to send additional information to what is required by national law and the list of minimum content below it must be developed in a customer friendly way. The channel of how the information is sent is decided nationally. Information from supplier to customer: Minimum content of information: • Confirmation of start of contract • Date of start of contract/switch Time Frame: The information should be sent soon as possible after receiving confirmation of Notification of new supply. Responsibility: The new supplier is responsible for sending confirmation of the new contract and date of contract start/ switch to the customer. Table 2.5 Information from supplier to customer Cancelation during switching process Cancelations could be necessary due to either customer request or in case of faulty switches. If the cancelation takes place before the switch is completed a message cancelling the switch can be sent from the new supplier to the DSO or the national point of information. Cancellations after the switch is completed are discussed in chapter 2.3 After the switch. If the supplier cancels without the customer requesting it, the supplier should inform the customer about the reason for cancellation. In case of a faulty switch the new supplier must correct the situation so that the parties involved will take no harm. As done today at national levels, a more detailed list than what is stated below should be developed by the industry. Cancelation during switching process: Content of message: • Cancellation Time Frame: This message can only be sent after the notification of new supply is sent and before the switch is completed. Responsibility: The new supplier is responsible for sending the message. Table 2.6 Cancelation during switching process Notify old supplier In this process the DSO or national point of contract will notify old suppler of the switch. Notify old supplier: Content of message: • Metering point ID • End Date Time Frame: The notification should be sent at the same time as the confirmation of the supplier switch is sent to new supplier. Responsibility: DSO or the national point of information is responsible for sending this message. Table 2.7 Notify old supplier Meter Reading A message containing meter reading is sent from the DSO to both new and old supplier or from the DSO to the national point of information who then distributes the meter reading to the new and old supplier. Meter reading: Content of message: • Meter reading at the hour of the switch • Meter reading the day of switch +/- 5 days. or Time Frame: Meter reading should be sent at latest ten days after the switching date. Responsibility: The DSO is responsible for executing the meter reading and sending the meter value to the old supplier or the national point of information. In the case of mechanical meters this message should also be sent to the new supplier within the same time frame. Table 2.8 Meter reading After the switch This chapter describes the process final settlement that will take place after the switch. It also describes the processes roll back a faulty switch and cancellation during the cooling off period. Final settlement After the switch is completed there is a need for a final settlement. The old supplier is responsible for sending information on final settlement to the customer. This must take place no longer than 6 weeks from the last day of supply. Roll back a faulty switch Faulty switches may occur. If a faulty switch is detected all parties involved should be informed immediately. If a supplier detects the fault it should inform the customer and start to roll back the faulty switch by a manual process involving all relevant parties. This is further regulated by law proceedings. NordREG suggest that the customers will should be respected, and not take any harm. As of today this is handled manually and nationally. A harmonisation could be beneficial for the efficiency in the market and should be considered in the future. Cancellation during the cooling off period The supplier is free to carry out the switch during the cooling off period, and then takes the risk of the customer cancelling. As of today this is handled as a manual process. A harmonisation could be beneficial for the efficiency in the market and should be considered in the future. Overview of the switching process The figure below draws up the general switching process that NordREG is recommending for the harmonised Nordic retail market for 2015. The figure shows how messages are to be sent between the new and the old supplier and the DSO or the national point of contact: Figure 3.1 Recommended switching process from 2015 Figure 3.1 Recommended switching process from 2015 NOTIFICATION OF NEW SUPPLY POSSIBLE CANCELLATION OF SWITCH. CONFIRMATION/REJECT OF SWITCH METER READING VALUES NEW SUPPLIER DSO or National point of contact OLD SUPPLIER Is there need for at time frame? Within one hour or no later than 1 working days after Notification of new supply After notification of supply has been sent and before start of supply. Max 10 working days after switch At the same time as the confirmation is sent to new supplier. Max 10 working days after switch NOTIFICATION OF NEW SUPPLY POSSIBLE CANCELLATION OF SWITCH. CONFIRMATION/REJECT OF SWITCH METER READING VALUES NEW SUPPLIER DSO or National point of contact OLD SUPPLIER Is there need for at time frame? Within one hour or no later than 1 working days after Notification of new supply After notification of supply has been sent and before start of supply. Max 10 working days after switch At the same time as the confirmation is sent to new supplier. Max 10 working days after switch Appendix I, Glossary In this document the following definitions is used: • Supplier: the Company that is the seller of electricity to the end user. • Balance Responsible Party: A party that has a contract proving financial security and identifying balance responsibility with the Imbalance Settlement Responsible of the Market Balance Area entitling the party to operate in the market. This is the only role allowing a party to nominate energy on a wholesale level. • Distribution System Operators (DSO): Distribution System Operator. The operator of the local or low voltage electricity network. • Information Exchange System: Is the system where information is exchanged between market actors. • Customer: With customer we mean all customers regardless consumption or legal status e.g. businesses or households. Customers and those customers that are deemed to be protected by Annex 1 (and Article 3) of the 2009 Electricity and Gas Directives, when implementing the 3rd Package. Each individual Member State may in addition choose to enlarge the scope from only household customers to also include small and medium-sized businesses. The national definition should be used when applying the indicators. • Automatic meter reading (AMR): Meter reading is done automatically and remotely via data transmission system. No on-site reading needed • National point of information: Point where market actors can access information, for example database and/or hub. • Switch: NordREG defines a switch as the action through which the customer acts and changes his/her supplier. The meter point associated with a household must be re-registered with a new supplier. A customer moving residence should only be recorded as a switch if the customer switches supplier. • Price comparison tool: A tool where the customer have access to reliable and up to date information on available offers. Appendix II, Summary of 2008th switching model In 2008 NordREG mapped the supplier switching processes in the Nordic countries and, based on the detected differences, recommended a harmonised switching model for the countries based on some key elements. The following recommendations, presented in a table and a graph, describes the switching model presented in 2008 in a comprehensive way. The recommendations from 2008 form the basis for the new switching model that is presented later in this report. HARMONISED MODEL Supplier switching is possible on any weekday of the month. Supplier switching is possible in 14 days notice period. No fees are allowed in relation to supplier switch. A common way of automatically retrieving metering point IDs is in use in each country. All suppliers have access there easily and without high expenses. Procedures for data exchange are included in binding regulation. One electronic data format and method is used by all market participants. All countries have same minimum content of messages and deadlines for sending them. Timetables regarding cancellation are similar. One unique or at least national certifying process for testing is available and all the data systems are tested before taking them into use. A present supplier may not oppose the switch in any situation. Only the same person can make a supply and a network contract to the same consumption place. Table 5.1 Harmonised switching model from 2008 Figure 5.1 Illustration of switching process from 2008 Making a new contract and timeframe for supplier switching NordREG suggested that the timetable for the switching procedure could be as short as possible and that the switch could take place any day of the week within 14 days. To initiate the switch customers have to be in contact only with the new supplier. The person making the supply contract being the same person who has the contract with the DSO was not seen as a critical point for harmonisation at that point. It is important that each country has an arrangement for making relevant customer data about their national customers available, and that this information is easily accessible to all the Nordic suppliers without high expenses. Data exchange between the market participants NordREG suggested that a new supplier should send a message on the supplier switch to the DSO as soon as a new contract has been made and at minimum 14 days before the planned start of supply. The DSO’s time limit for sending a confirmation message containing customer data to the new supplier should be no more than three working days. The time limit should be calculated from the moment the DSO has received the message on the supplier switch from the new supplier. As regards the DSO’s message containing customer data to the old supplier, it should be sent no later than three working days before the announced switch date. NordREG also suggested that a cancellation message from the new supplier to the DSO should be sent no later than four working days before the announced switch date. Metering issues The meter reading itself should be done on the day of the switch because it gives the most correct consumption specification, but may also, in some cases, be read ± 5 working days from the switch. Estimated metering values should only be allowed in very limited situations. Deadline for sending meter reading from the DSO to the old and new supplier should be done, by the latest, 10 working days after the switch. There should be no financial obstacles when it comes to supplier switching and therefore also meter reading. As a result it should not be allowed to have any meter reading fees in this regard. NordREG c/o Danish Energy Regulatory Authority Carl Jacobsens Vej 35, 2500 Valby Denmark Telephone: + 45 41 71 54 00 E-mail: post@energitilsynet.dk Internet: www.nordicenergyregulators.org