Wholesaler
Discussion Session 1
Codes
-
Timetable
We need to get sight of the codes early enough so we know what we
need to do and by when.
Finalising codes along a timescale that we understand would remove
uncertainty before market opening.
An overall plan with timings should make it clear who is accountable for
what in that plan.
Is it clear at the moment what wholesalers need to do to deliver against codes
vs. retailers vs. central Market Operator?
Which areas of the codes will be fixed, and by when? We want to know how
complete the next MAP will be.
At the programme level
How fixed will codes be at each milestone (50% complete / 80% complete etc).
Baselining and change management would be required.
How are we going to ensure that the codes meet the wholesalers’
requirements? How do we get confidence that the codes are in line with the legal
framework? How does any statutory conflict between codes and legal framework get
resolved? Companies to ensure codes comply with legal obligations – assurance from
a market participant perspective.
At the wholesalers’ board level
The board will need assurance as to whether the codes are ready, and
particularly whether or not they comply with competition law. The board will need to get
the assurance from itself, rather than externally.
They will want to know that we are really on track, with all market participants
ready and on track to operate this code.
1
Market Operator and Market Participants
-
Questions for these two sections should be the same and are interchangeable.
-
Who has legal accountability for implementing the Act?
The MO should be a tool for the Market Participants; Market Participants own
the MO, so the MO is accountable to Market Participants. Accountability of assurance
around this needs to be clear.
Is it feasible to establish the MO within these timescales successfully?
(Programme timescales)
We would like readiness assurance for the MO, that it will be ready. The Market
Participants are all anticipating that the MO will be ready, and they need to be assured
that there won’t be any surprises.
It is also important to ask, how can Market Participants be assured that any
other individual Market Participant is ready to go?
We need to know, not only are MPs ready to deal with the MO but also the rest
of the market – retailers. They must also be able to comply with the codes. Does your
company know what they need to do to operate in the market?
We need assurance that you will place your data in the MO – what standard of
accuracy is required? Can’t assure that the data will be 100% complete and accurate.
MO to provide data to Market Participants, and Market Participants should
provide data as accurately as possible to the MO – data needs to be sufficiently
accurate, completed in the right way and at the right time.
Programme
-
Is it possible to define and agree the system of governance?
What is the programme/programmes, and will the programme deliver what it
needs to deliver?
Are there key milestones from company plans to support transparency within
the programme? How can this be managed by the central programme? We feel that it
is important that there is visibility between the companies and the central programme.
-
More transparency is needed for larger wholesalers.
Wholesalers need to have confidence that the retailers are ready, so that
money flows.
Wholesalers also need assurance that there are robust processes in place for
new entrants wishing to access the market.
-
We are all keen that assurance doesn’t blow up into a big industry.
It is important to make sure that assurance doesn’t threaten the timeline. As
such, you need to make sure that assurance is built into your timeline.
2
Outcomes
-
Wholesalers want to be provided with services to time and cost.
-
Wholesalers then want to receive payments to time and cost.
3