Hi folks,
The team has put together some feedback as requested by your consultation.
Overall, we feel that this updated framework is a fantastic step in the right direction, and hopefully you find our feedback useful.
Please see the attached Flogas Ireland Response.
See attached document
Context & Relevance to Traveller Community
Travellers are disproportionately affected by energy poverty[1], marginalised in accessing mainstream financial products, and face barriers in utilising digital tools. Reliable PCWs have been shown to help households save an average of 10–20% on energy bills. However, these benefits are accessible mainly to households with broadband access, financial literacy, and trust in digital services—criteria not consistently met by many Traveller families.
Enhancing PCWs’ transparency, inclusivity, and usability could deliver substantial savings for Travellers—especially as energy costs make up a large share of their household budgets.
Alignment with Accreditation Principles
National Traveller MABS support and urge enhancement of the CRU’s existing principles for accredited PCWs, particularly:
Recommendations
Enhanced Accessibility Requirements
Enforce use of simple, jargon‑free language and icon-based explanations (e.g., clear “€ saved/month” labels) alongside tariff visuals. All PWC’s should be required to have the plain English mark from NALA (National Adult Literacy Agency)[2].
Many Traveller families mainly access internet via smartphones with limited data. Accredited PCWs should offer data-light mobile versions and save-for-later summaries users can access offline.
Implement voice assistance and audio read-outs for key steps. Offer Irish Sign Language (ISL) and other supported audio options.
Targeted Outreach to Marginalised Consumers
Collaborate with Traveller organisations and MABS services to host local workshops offering hands-on guidance in using PCWs effectively. Include ‘tele‑supported’ sessions accessible on-site at halting sites and Traveller centres.
Energy efficiency schemes (e.g., winter credits, fuel allowances) should include guidance on switching tariffs via accredited PCWs as part of bundled support materials.
Transparency on Savings and Switching Impact
PCWs should highlight actual net savings, including potential switching costs or bonuses, with disclaimers around variable consumption.
PCWs should publish anonymised, aggregated data on switching outcomes for lower-income and Traveller households, demonstrating impact. It is extremely important that an ethnic identifier be used in collecting the data so the impact of switching can be accurately measured.
Affordability and Digital Inclusion
Accreditation criteria should incentivise PCWs to develop commission-free switching routes for low-income users to minimise potential bias.
Allow organisations like National Traveller MABS, MABS and other support agencies to access white-labelled API versions of accredited PCWs for guided switching support within community settings.
Rationale & Evidence
Financial Vulnerability of Travellers
Traveller households spend disproportionately high portions of income on energy due to substandard accommodation and energy-inefficient homes[3]. Travellers are also disproportionally affected by poverty driven by discrimination. Travellers and Roma face the highest levels of prejudice of any ethnic group in Ireland[4]. 31% of Irish Traveller households, including 28% of those with children, are in acute poverty.
40% of Travellers live in households that have great difficulty making ends meet, which is considerably higher than the general Irish population (8%). 28% of Traveller children grow up in severe material deprivation. 31% of Travellers live in households that cannot afford basic items like a nutritious meal, adequate heating, or a washing machine[5].
Even small savings (≈€20–€30/month) could help toward easing poverty pressures.
Digital Barriers
National data consistently report lower digital access, lower literacy, digital literacy, and trust among Travellers. Without tailored design and outreach, many remain excluded from potential PCW benefits.
Best Practice Model
International best-practice reviews emphasise inclusivity in PCW design. The Council of European Energy Regulators (CEER) guidelines, referenced by CRU, encourage accessibility, transparency, and user empowerment—a model to build upon.
[1] 77% of Travellers living in mobile homes were in energy poverty in 2019, Stamp. S, Kearns, M. Accommodating Ethnicity Addressing Energy Poverty Among Travellers Living in Mobile Homes and Trailers, (Dublin, 2019) available from https://www.ntmabs.org/images/resources/publications/policy/ntmabs-energy-poverty-report.pdf
[2] https://www.nala.ie/plain-english/
[3] Stamp. S, Kearns, M. Accommodating Ethnicity Addressing Energy Poverty Among Travellers Living in Mobile Homes and Trailers, (Dublin, 2019) available from https://www.ntmabs.org/images/resources/publications/policy/ntmabs-energy-poverty-report.pdf
Ehimen, E., Essling, C., Kearns, M., Foley, A, Research on the Energy Efficiency of Mobile Homes for Irish Traveller Communities, (Dublin, 2023) available from https://www.ntmabs.org/images/resources/publications/policy/mobile-homes-energy-efficiency-report-2022.pdf
[4] Carron-Kee, E., McGinnity, F., and Alamir, A. (2024). Understanding attitudes to Travellers and Roma in Ireland, Jointly-published Reports 9, Dublin: ESRI and DCEDIY, https://doi.org/10.26504/jr9
[5] Fundamental Rights Agency, Travellers In Ireland, (FRA, 2020) Available from https://fra.europa.eu/sites/default/files/fra_uploads/fra-2020-roma-and-travellers-survey-country-sheet-ireland_en.pdf
Response to Consultation Paper CRU/202566 | Consultation on a Review of the Accreditation Framework for Price Comparison Websites
Submitted by Dominic Ó Gallachóir, owner of Kilowatt.ie
We are grateful for the opportunity to respond to the consultation. Our response is below.
Consultation feedback section 1
We agree. Comparisons using HDF data provide greatly enhanced accuracy, especially when comparing smart tariffs.
Consultation feedback section 2
We agree that website providers should be required to provide dynamic tariff comparison.
However, we do not agree that the inclusion of dynamic tariffs should be mandated to be opt-in only.
It’s not yet clear what will provide the best user experience. At least three possibilities exist:
We believe that PCW providers should be allowed to adapt how they provide/include dynamic tariff comparison based on the experience and customer feedback which they will gain following the introduction of dynamic tariffs.
It is true that customers should be warned about the potential risks of dynamic tariffs. However, again in the interests of a smooth user experience, it’s essential that such warnings not clutter the user interface.
Therefore, we propose that PCWs specifically be required to include a brief warning about the volatility of dynamic tariffs on any results page which includes dynamic tariffs, with a link or other feature included with the warning that allows customers to access further information.
Consultation feedback section 3
We agree. Additionally, we believe that exports should always be included by default, not only as an option.
Consultation feedback section 4 & 5
The market for SME energy supply is currently opaque, with only a minority of suppliers disclosing their SME tariff rates online. We therefore welcome efforts by the CRU to increase consumer access to information on tariffs for SMEs.
We also agree that price comparison websites have a role to play in this.
However, we believe that the core issue around SME tariffs is a lack of transparency from suppliers regarding their SME tariff offerings. Until more suppliers disclose their tariffs online, PCWs will be of limited use to SMEs.
Therefore, we suggest that PCWs should only be required to include tariffs which are publicly listed on the supplier websites. This would encourage more suppliers to list their tariffs publicly.
Consultation feedback section 6
We agree with the proposal to remove the EAB requirement and to let PCWs develop their own comparison methodology.
However, we do suggest a certain degree of standardisation which would help maintain some level of consistency across platforms, specifically the following:
1) That when using smart meter data for comparison, the most recent 12 months of data be used for analysis by default. This eliminates seasonality biases (this is especially important for the growing number of customers with heat pumps and/or solar panels).
2) Additional measures outlined in our responses to Request for consultation feedback sections 7,8, and 9
We believe that it would be enough for the CRU to encourage/suggest these measures rather than making them mandatory, as it will be in the interest of the PCWs to have a reasonable level of consistency across websites in order to retain the public’s confidence. Having these as “industry standards” rather than mandatory rules would allow scope for immediate innovation by PCWs in case circumstances change.
Consultation feedback section 7 & 8
Price comparison methodology must make a trade-off between convenience and accuracy: The more questions that a user is asked, the more accurate their comparison can be. However, asking more questions also makes the comparison process more cumbersome, potentially resulting in lower switching rates.
In our experience, customers vary widely from those who enjoy digging into the details using their smart meter data, to those who just want a very quick suggestion for reasonably-price tariff, even if it’s not the absolute cheapest option for their particular usage profile.
For the benefit of the latter group (who may be dissuaded from switching if a PCW bothers them with too many questions), we think it would be beneficial that the CRU continue to specify a “National Average” usage figure, which PCWs may allow customers to use. We believe that it would be better for the CRU to continue specifying a national average usage figure than for each PCW to calculate the figure independently, as consistency across PCWs would maximise clarity for consumers.
Consultation feedback section 9
We agree with the proposal to remove the obligation to use standard load profiles. As pointed out in the consultation paper, this could facilitate more accurate comparisons that reflect each customer’s unique usage pattern.
However, we believe it would be useful for the CRU to publish a new average load profile with a figure for each half-hour period across the week (Monday-Sunday). This single profile could then be used as an industry-standard starting point for comparisons regardless of the tariff type (whether 24h, day/night, ToU, or dynamic), with optional refinements added by customers who so-deside.
Consultation feedback section 10
We agree that PCWs should be required to explain their methodology on their website.
For the avoidance of doubt, we do not believe this means that the full mathematical details of each individual price comparison calculation should be required to be individually included with the price comparison results, as these can be extremely involved in the age of smart meters.
Consultation feedback section 11
We agree
Consultation feedback section 12
We agree
Consultation feedback section 13
We mostly agree with the proposed revised version. The requirement to use “Universal Design” is of particular interest to us, as we believe that this gets to the heart of giving customers a great PCW experience. Unfortunately though, Universal Design principles force designers to wrestle with some dilemmas.
In particular, information is useful, but the more information that you put on a web page, the more difficult it becomes for the customer to process that information. Therefore, we encourage the CRU to only apply mandates for information inclusion where it's truly vital to do so, otherwise leaving it up to PCWs to figure out what information their customers truly desire, and what is better omitted. Likewise, asking lots of questions at the input stage of a price comparison can help provide more accurate and personalised results, but having too many questions can also put customers off, especially those who are intimidated by technology. We encourage the CRU to allow PCWs the flexibility to figure out the level of comparison detail that their customers prefer over time.
We have five specific suggestions that we believe would help PCWs to minimise informational and choice overload
#1
That PCWs be allowed to exclude any tariff which is more expensive or equally expensive in all of its aspects to another tariff from the same supplier, and does not offer more flexible contract terms.
For example:
#2
That an exception also be made for “loyalty” tariffs – those which are only available to pre-existing customers of a given supplier. Such tariffs by definition are not available to most customers. And while it would be possible to filter these based on asking the user who their current supplier is, this adds friction to the price comparison process – a customer who can’t remember who their current supplier is may get frustrated and give up. Therefore, we believe it would be better to allow PCWs to simply omit loyalty tariffs.
#3
“Domestic tariffs that are available for sign up through suppliers only must be equally clear and accessible to customers and must be accompanied by a message to alert them of this fact.”
We agree that all results should be equally clear. However, we are not convinced that the proposed message alert is necessary, and worry that mandating it would add clutter to the results section, worsening the user experience and potentially therefore reducing the usage of PCWs and switching rates.
#4
“The results page must clearly show the requirements of each tariff option for example: payment method, meter type, dual fuel, expiry date, unit rate per kWh, etc.”
It appears to us that direct debit is now the de-facto standard payment method among energy retailers. Where direct debit is offered, we do not believe PCWs should be mandated to specifically point out payment method requirements, again in the interests of allowing them to avoid informational overload for customers.
#5
We believe that the requirement to provide “Links to relevant terms and conditions for each tariff” should only apply for tariffs that the customer can sign up for through the PCW. We do not believe that this otherwise falls within the logical scope of a PCW, and that the requirement could force PCWs to add clutter to the results section, degrading user experience and therefore potentially reducing switching rates.
Additional Feedback for Section 13
We suggest replacing the phrase “all tariffs and associated information they have found to be offered by suppliers” with “all tariffs listed on supplier websites”. This eliminates ambiguity and would encourage suppliers to publish their tariffs on their websites.
Regarding the requirement “The website provider must provide customers with an explanation of the different payment methods shown on the website.” We believe this would be redundant given that an explanation of payment methods is easily available through search engines and chatbots, and therefore would provide minimal benefit to consumers while adding clutter to the PCWs.
For the avoidance of ambiguity, we also propose that the phrase “publicly available” be replaced with “listed on a supplier’s website”
Consultation feedback section 14
We have several further suggestions which relate to the broader regulation of the electricity market, but which are closely tied to the question of price comparison, as follows:
Non-exclusion of smart meter customers from traditional tariffs
There’s a widespread fear among customers that they will be “locked out” of good-value mechanical meter-only electricity tariffs in the future (or even in the near-term) if they activate their smart meter by switching to a smart tariff now.
The following discussion on a web forum is just one example among many that illustrates this apprehension:
We propose that suppliers be required to make all of their mechanical meter offers also available to customers with activated smart meters. This would reassure customers that they would not get “stuck” with worse tariffs by activating their smart meter. We believe this would result in much greater uptake of smart tariffs.
Prohibition on pricing discrimination by suppliers
We propose that suppliers be mandated not to use price discrimination (also known as “dynamic pricing”, but not to be confused with dynamic tariffs) where different prices are shown/charged based on the user’s location, time of day, internet browsing history, etc. Aside from the unfairness of such practices, they would, if introduced, severely undermine the viability of PCWs.
Clearer Disclosure of Upcoming Price Changes by Suppliers
We also suggest that energy suppliers be required to provide prominent notice of any upcoming price changes on the web pages where they list their tariffs. We do not believe that the current common practice of putting a notice somewhere else on the supplier website or sending out a press release is adequate. This change would allow PCWs to reliably and without ambiguity access the information required to provide accurate price comparisons where there are upcoming price changes, and also give consumers clarity when browsing supplier sites.
Consultation feedback section 15
Our feedback on this point is covered in Request for consultation feedback 13
Please see attached response
Please find the Energia response attached. Thank you for your pre-engagement on this matter, we really appreciated it. If you have any questions in relation to our response, please don't hesitate to get in touch.
Response provided in attachment.
Please find the EAI response to all consultation questions attached.
Please see attached submission
Please see attached
Please see attached
Please See attached
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:
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:
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.