The DCC’s role in developing a Central Registration Service and penalty interest proposals
Citizens Advice welcomes this opportunity to respond to Ofgem’s consultation on the development of the Central Registration Service (CRS)
We regard the creation of a new CRS as a sensible step in the drive towards one day switching, and the Data and Communications Company (DCC) as the best party to be responsible. Overall, however, this choice does raise a concern for us over the DCC’s track record so far on value for money.
At the time of writing the DCC has recently informed stakeholders that it will not be able to meet its Target Response Time for message delivery as set out in the Smart Energy Code (SEC). This is meant to be 30 seconds but in the case of some important message types the DCC has announced that, unless plans change, it will take more than an hour to deliver them. This is a breach of the agreement with potentially serious consequences for future consumers, who for example may not be able to practically access their full data records when using switching sites, but it is our understanding that the DCC does not currently face any penalty for missing this target. Indeed it has been suggested that the target could simply be revised down in the SEC. This, combined with our concerns about the ex post approach that has been taken so far, expressed in the previous consultation on the DCC price control, feeds into a more general concern that Ofgem may not currently be keeping a firm enough grip on the DCC’s revenue. We are not disputing the decision to allocate responsibility for the CRS to the DCC, but this makes it all the more pressing to make sure the price control is fair and watertight. We hope this consultation will be a useful step towards that.