The summer was a busy time for EAI’s Retail Committee, which actively engaged in four important consultations put forward by the CRU and DCEE. As the energy sector continues to undergo significant transformation driven by decarbonisation goals, digital innovation, and evolving consumer needs, the Retail Committee remains committed to shaping the direction of policy through our consultation responses. Each of the following consultations represents a significant step in addressing key challenges and opportunities within Ireland’s evolving energy market:
- Smart Meter Upgrade – Access to Near Real-Time Metering Data: This consultation is focussed on unlocking the full potential of smart meter technology. By improving access to near real-time data, suppliers and consumers alike can benefit from enhanced visibility into energy consumption patterns.
- The Review of the Supplier of Last Resort Framework: Having in place a Supplier of Last Resort is about future-proofing a vital consumer protection mechanism. For EAI, this was a chance to ensure that the final framework is practical, balanced, consumer-focused and resilient in an ever-changing energy landscape.
- The Review of the Accreditation Framework for Price Comparison Websites (PCWs): This review sought to ensure that these platforms operate with transparency, accuracy, and fairness is important for overall health, stability and reliability of the retail market.
- The Redesign of the Energy Efficiency Obligation Scheme: As Ireland advances toward its climate goals, energy efficiency remains a cornerstone of sustainable energy policy. The Energy Efficiency Obligation Scheme (EEOS) plays a critical role by setting mandatory energy savings targets for obligated parties. The recent consultation on the redesigned EEOS offered industry stakeholders a valuable opportunity to engage with policymakers, realign the scheme with both EU and national climate objectives, and ensure it effectively supports Ireland’s national climate action goals. It also sought to address the practical challenges faced by obligated parties in contributing to the achievement of these goals.
Together, these consultations address important topics spanning areas from data access, market stability, consumer empowerment, to energy efficiency. The EAI’s active and ongoing involvement in these areas, including direct engagement with the CRU and the Department of the Environment, Climate and Communications (DECC), underscore our commitment to advancing a smarter, fairer and more sustainable energy market for the benefit of all stakeholders. The key points from EAI’s responses to each of these consultations is provided below:
1.Smart Meter Upgrade – Access to Near Real-Time Metering Data
- Support for removal of the backstop
EAI supports the removal of the provision set out in the 2016 decision, whereby ESBN would make an In-Home Display (IHD) available to customers via their suppliers for an introductory period.
- Considerations regarding supports for vulnerable customers
EAI recognises the importance of providing additional supports to vulnerable customers. We recommend the following considerations should the CRU decide to progress this initiative further:
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- A cost-benefit analysis should be conducted prior to any procurement decision, including an assessment of the level of interest from eligible customer cohorts and how best to reach those targeted.
- Lessons learned from similar initiatives in other jurisdictions should be reviewed and incorporated (for example in NI.)
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- A comprehensive education and support campaign will be useful to ensure the success of the initiative if implemented.
- Future market design considerations
Access to near real-time data for all customers via market systems should be considered as part of the future retail market design. This is essential to enable the level of demand flexibility and customer response required for a decarbonised energy system.
Link to our full response: 20250813 EAI Response to CRU IHD Consultation .pdf
2. Review of the Supplier of Last Resort Framework
The CRU’s review of the Supplier of Last Resort (SoLR) framework aims to enhance market resilience by protecting consumers if a supplier exits the market unexpectedly.
EAI’s response focused on ensuring the SoLR framework is:
- Resilient and future-proof to handle market challenges
- Fair to both customers and suppliers
- Efficient in managing crisis situations
- Supportive of a competitive and innovative energy market
In our response, we highlighted that the Supplier of Last Resort (SoLR) process would benefit significantly from several of the proposals outlined in this consultation, including:
- The introduction of an agreed cost-recovery mechanism that ensures transparency around requirements and timelines.
- Greater clarity on the types of supplier-related costs that are allowable, whether the SoLR is a designated provider or selected through a competitive process. It is essential that the SoLR process enables designated suppliers to recover their justifiable and evidenced costs incurred as a result of fulfilling their obligations.
- The implementation of a robust, fast-acting communications framework that ensures all market participants are provided with timely and accurate information throughout the duration of an SoLR event.
Link to full response:20250724 Final EAI Response to SOLR Consultation.pdf
3. Review of the Accreditation Framework for Price Comparison Websites (PCWs)
Price Comparison Websites are essential for empowering consumers with transparent, accessible tariff comparisons. This review presents an important opportunity for the industry to have a direct say in shaping the rules that govern key consumer tools. The EAI put forward a detailed and robust response to ensure its members have a strong voice in developing a framework that works effectively for both businesses and customers, promoting a fair, transparent, and competitive energy retail market.
Key points from our response included:
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- Clear communication of dynamic tariffs’ risks and benefits.
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- Consistency in Estimated Annual Bill methodologies to ensure fairness, transparency and accuracy.
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- Equal customer protection whether contracting through suppliers or PCWs.
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- A call for a distinct regulatory framework for third-party intermediaries beyond PCWs, reflecting their growing influence in the market and customer journey.
Link to our full response: 20250718 EAI Final Response to the PCW Consultation.pdf
4. Redesigned Energy Efficiency Obligation Scheme
Over the years, the EAI has also actively advocated on significant energy policy matters, including the redesign of Ireland’s Energy Efficiency Obligation Scheme (EEOS). Our Energy Efficiency Taskforce took the lead on this consultation, recognising the scheme’s central role in driving national energy savings and meeting climate commitments through energy efficiency policy. Our comprehensive response aimed to ensure the redesigned EEOS supports meaningful progress on energy efficiency while addressing key challenges such as affordability, flexibility, and effective delivery.
Key points from our response are as follows:
- Support the proposal to apply the 100kWh/m² threshold
We support the proposal to apply the 100kWh/m² threshold but believe its effectiveness depends on increased flexibility. To strengthen the EEOS, we recommend the following enhancements:
- Extend the Assessment Timeframe
Increase the allowable period between pre- and post-BER assessments from 2 years to 10 years, aligning with the BER certificate’s validity and better reflecting long-term energy savings.
- Introduce a Deemed Credit Approach
Implement a deemed credit methodology for individual retrofit measures—similar to that used for standalone upgrades—to simplify delivery and encourage wider participation.
- Broaden Eligible Measures
Expand the list of qualifying measures beyond external wall insulation and heat pumps to include upgrades such as windows, doors, and attic insulation, using a non-exhaustive list.
- Incentivise Overdelivery
Introduce a mechanism to recognise and reward cumulative overachievement by obligated parties, encouraging early and proactive action. This would help align EEOS more closely with the cumulative savings principle in the Energy Efficiency Directive (EED).
- Index SEAI Grant Levels to Inflation
Review current SEAI grants and ensure they are adjusted in line with inflation, particularly given the global economic climate and inflationary pressures.
Link to our full response:20250708 Final EAI Response to DCEE on EEOS.pdf
Ongoing Collaboration
EAI’s comprehensive responses underline the importance of a balanced approach that fosters innovation while safeguarding consumers and market integrity. These consultations mark significant steps towards a smarter, more resilient Irish energy market.
We look forward to further collaboration with the CRU, DCEE and other stakeholders to continue to drive progress in the energy sector.