Eligibility to share energy data under the CDR is confined to CDR consumers with arrangements that relate to one or more connection points in the National Electricity Market (NEM) (Schedule 4, rule 2.1(2)). In addition, energy retailers have to be operating in the NEM in order to be subject to data holder obligations (Schedule 4, rule 1.4). This means that electricity consumers in Western Australian and Northern Territory (which are not connected to the NEM) are generally ineligible to share their energy data via the CDR.
However, the designation instrument for the energy sector allows for information about goods/services that are “related” to the consumer’s NEM supply to be included as CDR data (see section 8(1)(b) of the energy designation instrument, and the note under section 5(1) of the energy designation instrument), as well as information about dual fuel plans (i.e. electricity and gas plans - see subsection 9(4) of the energy designation instrument).
The CDR rules define any CDR data covered by the energy sector designation instrument as ‘energy sector data’, and this data falls within the definitions of ‘required consumer data’ in rule 3.2(2) of Schedule 4 and the definition of ‘voluntary consumer data’ in rule 3.3(3) of Schedule 4.
The definitions of retailer-held data in rule 1.3 of Schedule 4 of the rules (‘customer data’, ‘account data’, ‘billing data’, ‘product specific data’ and ‘tailored tariff data’) are not limited to electricity. While the consumer’s arrangement with the retailer must relate to one or more connection points in the National Electricity Market, the ‘account balance at any time’ (which is included in the definition of billing data) is not limited to the costs of supplying the NEM connection points if other services impact on the account balance. For example, where the account balance on a bill includes charges for the supply of gas, the supply of electricity outside the NEM, or charges for other goods/services, the full account balance must be shared, as well as relevant data about the charges impacting on that account balance. That is, any services that affect the account balance, in circumstances where a single bill is issued, must be included as CDR data. If they are not included, then there will be discrepancies between what the consumer has paid and the account balance that is shared via the CDR.
Where a separate bill is issued for gas supply, or electricity supply outside the NEM, and this does not affect the account balance of the consumer’s account under which NEM supply is provided, we consider data relating to the services outside the NEM is not within scope for initial data sharing. However, any discounts applied because the consumer has both an electricity and a gas account with the retailer will be relevant (see definition of ‘product specific data’ in rule 1.3 of Schedule 4 the rules).
Note: This guidance establishes minimum requirements for initial data sharing in energy and we note that payloads for retailer-held data relevant to gas may increase over time.