Citizens Advice response to RECCo's proposed REC drafting required to deliver the CCS Minimum Marketable Product (MMP)
We don’t have strong views on the specifics of the REC drafting; we are more concerned with ensuring that the consumer journey is carefully considered, with the goal of improving consumer confidence in smart metering at the heart. To this end, our feedback largely focuses on consumer-facing aspects of the Arrangements Schedule and the Consumer Experience Guidelines, as well as the need for an effective monitoring and enforcement framework.
We would also emphasise, more broadly, that a key priority should be ensuring that the CCS interoperates with the Smart Data Repository (SDR) and the wider infrastructure of the Energy Digitalisation Framework. These other workstreams have an important role to play in enabling the goals of the CCS.
We would like to reaffirm our previous comments on the scope of the CCS*. The current proposal is to launch a portal that shows only a very limited amount of consent-based data access. Non-consent-based data access, some data access that was consented to before the tool was available, and energy supplier data access have all been moved out of scope. Smart Energy Code (SEC) other parties' data access has also been moved to a voluntary basis. There is no benefit to excluding so many data flows from the tool and significantly limiting the product will bring numerous risks.
* Citizens Advice (2026) Response to RECCO's Consumer Consent Solution Design Consultation