General Position

EnergyPal.ie supports the CRU’s proposed updates to the PCW Accreditation Framework and the move to a principles-based approach. We welcome the inclusion of:

Smart meter (HDF) data for personalized
comparisons
Dynamic tariff comparison features
Export tariffs in comparison results

These changes are important to keep consumer tools useful as the energy market changes. The framework should stay open and flexible, not tied to strict rules. This will allow new technologies like AI and automation to improve how comparison tools work, instead of holding them back.
Importantly, the framework must not advantage large players; accreditation should also be achievable for low- or non-profit organisations and individuals. As long as the rules are followed, the framework should not block small, innovative ideas.

Please note there is a number of challenges in operating PCW

Challenge 1:

Tariff data changes frequently, and suppliers do not provide a programmatic (API) interface for accessing this information. In some cases, tariff plans are made available only to selected PCWs, which disadvantages others and may mislead consumers.

Recommendation:

CRU should encourage or require suppliers to publish structured tariff data in open formats, ideally through an API. Additionally, there should be a commitment to equal access to tariff plans for all accredited PCWs.

Challenge 2:

While PCWs are expected to deliver accurate, trustworthy comparisons, there is no defined responsibility on ESBN regarding the quality and completeness of smart meter (HDF) data.

Recommendation:

The framework should clarify ESBNetworks role, including:

A responsibility to flag missing
or incomplete data to customers,
Ensuring that HDF files are accurate,
complete, and validated,
Publishing metadata with each HDF
file (e.g. completeness percentage, data date range for both import and export numbers).

Challenge 3:

The current process of downloading and uploading HDF CSV files is manual and error-prone, limiting uptake by consumers.

Recommendation:

CRU should prioritize implementation of programmatic access to smart meter data, as envisioned under the Smart Meter Data Access Code (SMDAC). With customer consent, PCWs should be able to directly access validated usage data from ESBN systems. This will unlock more meaningful, user-friendly comparisons.

Final Note

We appreciate CRU’s commitment to empowering consumers and welcome the inclusive, forward-thinking approach of this consultation. EnergyPal is aligned with the principles of transparency, independence, and innovation, and stands ready to collaborate on implementation or pilot projects related to smart meter usage or structured tariff data.

Additional feedback:

Request for consultation feedback 1:

The CRU are proposing to implement the following requirement into the framework:

Website providers must provide customers the option to use their own historical consumption

data obtained via HDF when conducting comparisons. This must be opt-in only. In relation to

missing data, or data covering shorter periods, the following requirement applies:

• If consumption data covers a period of less than one year or contains periods of missing

data (greater than 10%), customers must be informed of the associated implications this

might have on establishing an accurate consumption pattern and price comparison.

Do you agree with this approach? Why/Why not?

EnergyPal.ie relies exclusively on HDF smart meter data to provide accurate, personalised comparisons. We believe that tools like ours, which use only user-supplied HDF data, should also be explicitly covered by the accreditation framework to ensure consumers benefit from innovative, data-driven solutions.

On data quality, PCWs should validate the input data and notify users of any issues detected. However, ESB Networks should also take responsibility by including comprehensive metadata with exported HDF files to help identify and resolve data quality problems. The rollout of the Smart Meter Data Access Code (SMDAC) must be accelerated to eliminate errors caused by the manual download and upload process.

Request for consultation feedback 2:

The CRU are proposing to implement the following requirement into the framework:

Website providers must provide the ability for customers to compare dynamic tariffs. Dynamic tariffs must be clearly signposted to the customer, distinguished from other tariffs and opt-in only.

The web provider must include an explanatory message explaining the following:

• How dynamic tariffs may differ from other tariffs.

• The benefits and risks of dynamic tariffs. This includes how changing consumption

behaviour can help customers benefit from dynamic tariffs.

Do you agree with adopting a principles-based approach for dynamic tariff comparisons?

Why/Why not?

Yes, We agree but PCWs should have flexibility in methodology while ensuring users understand how dynamic pricing works. We suggest CRU also engage suppliers to standardize how they publish dynamic pricing structures, as PCWs will need structured, reliable data to present these offers meaningfully.

Dynamic pricing is not coming until June 2026, PCWs should get additional time for adopting it.

Request for consultation feedback 3:

The CRU are proposing to implement the following requirement into the framework:

Website providers must provide the ability to include export tariffs in price comparisons.

Comparison results must show the cheapest offers first, which must include the value of export payments. For clarity and transparency, the value of exports must be subtracted from the estimated bill for supply. The results must include both the costs for supply and the value of exports.

Do you agree with this approach? Why/Why not?

Yes, we agree. Export payments can significantly reduce the final bill for customers with PV installations, so including export tariffs in comparisons is essential for accuracy and transparency. Showing both import and export values ensures consumers can make fully informed decisions.

Request for consultation feedback 4:

The CRU are proposing to implement the following requirement into the framework:

Website providers must provide comparison services for all customers with an expected yearly electricity and gas consumption of below 100,000 kWh.

The CRU will not require the provision of these services to be the same as what is provided to domestic customers, however all relevant requirements for accreditation still apply.

Do you agree with this approach? Why/Why not?

No, we do not agree. While supporting SME comparisons can be useful, most PCWs (including EnergyPal.ie) are designed for domestic users, and extending services to all customers below 100,000 kWh could dilute focus and increase complexity without clear demand.
This could be a nice-to-have feature but should not be a mandatory requirement for accreditation.

Request for consultation feedback 5:

The CRU are proposing to implement the following requirement into the framework:

For business tariff comparisons, PCWs must provide the customer with a list of all tariffs and

associated information they have found to be offered by suppliers.

Do you agree with this approach? Why/Why not?

No, see point 4.

Request for consultation feedback 6:

The CRU invite respondents to assess the merit in removing the requirement for PCWs to

present EABs as outlined in the supplier handbook. The CRU propose to allow PCWs to

establish their own methodologies for comparison calculations.

Do you agree/disagree with this approach?

Yes, we agree. EAB is not meaningful for smart tariffs because it is based on typical consumption profiles and cannot reflect individual usage patterns or time-of-use rates

Request for consultation feedback 7:

The CRU are proposing to remove the requirement to use the average annual consumption

figures approved by the CRU in comparison calculations as required in the current iteration of the framework.

Do you agree/disagree with this approach?

Yes, we agree

Request for consultation feedback 8:

Should the CRU retain the approved annual consumption figures to be provided as an option for customers who do not know their own usage?

We understand the need for a fallback option, but using CRU’s approved annual consumption figures isn’t very helpful. These estimates don’t reflect individual usage and can lead to poor supplier choices, especially as tariffs become more complex.

Request for consultation feedback 9:

The CRU are proposing to remove the requirement to use standard load profiles in comparison calculations.

Do you agree/disagree with this approach?

See point 8

Request for consultation feedback 10:

The CRU are proposing to implement the following requirement into the framework:

The website provider must provide details of any calculations and associated methodology

utilised by the website provider to estimate annual consumption and energy costs to the

customer. The explanation must be in a customer-friendly format.

Do you agree/disagree with this approach?

Yes, we agree.

Request for consultation feedback 11:

The CRU proposes that all new requirements for accreditation must be implemented within six months of the CRU publishing a decision paper.

Do you agree with this timeline? If not, why not?

Yes, we agree with the proposed six-month implementation timeline. We believe this timeframe is fair and should also apply to any future requirements, such as support for dynamic pricing, provided that all necessary data is already publicly available.

Request for consultation feedback 12:

The CRU will allow apps to seek accreditation, provided they adhere to the principles of the

framework. The CRU envision all proposed requirements to be of relevance to the accreditation of apps and are therefore not proposing to implement app-specific requirements or exempt applications from certain requirements.

Yes, in principle, we support allowing apps to seek accreditation under the same framework. However, EnergyPal has successfully served thousands of Irish households for two years but did not fit the 2019 framework. To avoid blocking innovative tools in a rapidly evolving, AI-driven sector, the framework must remain flexible and regularly updated to accommodate new technologies and business models.

Request for consultation feedback 13:

Do you agree with the requirements as they appear in the proposed revised version of the Price Comparison Website Accreditation Framework?

Why/Why not?

We mostly agree with the new requirements, but think a few areas need more work to make sure the framework is fair and works well for everyone. In particular, there needs to be clearer shared responsibility for keeping tariffs up to date and for maintaining high data quality. All parties, such as suppliers, price comparison websites, and ESB Networks should work together to ensure information is accurate and reliable,

Request for consultation feedback 15:

The CRU invite respondents to comment on the audit process and the proposed audit checklist attached in appendix B, revised to reflect the proposed requirements of the updated framework.

Do you agree with the criteria as they appear in the audit checklist? Why/Why not?

2a - This item could be removed or marked as optional. Accredited PCWs should focus on domestic tariffs.

2b - It’s unclear how “all available tariffs” can be defined, as there is no single source and tariffs can change daily. Some tariffs, such as those with free Tesco points or with add-ons, do not make sense to include, these are not clearly comparable. There is also little value in comparing every minor variation (like online billing or direct debit options); instead, the best option should be selected.

2c – Same comment as 2a.

4c – This requirement does not make sense. Limiting users to only tariffs that can be switched to directly from the website often leads to suboptimal choices for users. This approach benefits the PCW, which may have affiliate deals with suppliers, rather than the consumer.

Review of the Accreditation Framework for Price Comparison Websites - Submissions

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