Smart Meter Upgrade Smart Pay-As-You-Go Policy - CRU Ireland
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An Coimisiún um Rialáil Fóntais Commission for Regulation of Utilities
An Coimisiún um Rialáil Fóntais
Commission for Regulation of Utilities
Smart Meter Upgrade
Smart Pay-As-You-Go Policy
Decision Paper
Reference: CRU21109 Date Published: 15/09/2021
www.cru.ie
0An Coimisiún um Rialáil Fóntais Commission for Regulation of Utilities
Executive Summary
This decision paper summarises the responses to the consultation on Smart Pay-As-You-Go
(Smart PAYG) and sets out the CRU decision on the policy for Smart PAYG for smart electricity
meters. Smart PAYG is a prepayment service that will be enabled by the smart meters deployed
by ESB Networks (ESBN). It is an additional ‘smart service’ for customers who have an ESBN
smart meter and is not intended as a replacement for other prepayment meters.
The High-Level Design (HLD) for the National Smart Metering Programme (NSMP) was approved
in 20141 and was revised in 20172 at which point the deployment of smart meters and the
introduction of smart services was divided into three phases. The allocation of smart electricity
meters follows ESBN’s deployment plan. Approximately 250,000 meters were installed in Phase 1
(2019-2020) and a further 500,000 meters are to be installed each year in Phase 2 (2021- 2023)3
and Phase 3 (2023-2025) respectively.
Smart services will also be introduced in a phased manner. Phase 1 of the programme was
completed in February 2021 with smart services such as remote reads, time-of-use (ToU) tariffs,
and access to historical consumption being introduced for customers.
In line with the ‘Phased Approach’, Smart PAYG functionality will be available from the end of
Phase 2 in 2023. Enabling this functionality via the ESBN meter from 2023 will extend the range
of PAYG services available to customers alongside existing PAYG solutions. Over time as
customers and the industry gain more experience with this new form of prepayment it may replace
some of the other PAYG products, for example, ESBN keypad meters.
In 2020 the CRU reviewed the policy to support Smart PAYG functionality and published a call for
evidence in December 2020 (CRU20169) to seek views on a number of topics. Responses
received on the call for evidence were summarised and published in April 2021 in a consultation
paper (CRU21046) which included the CRU proposal for key elements of the Smart PAYG policy
taking account of that feedback.
The CRU has considered the views of respondents to the consultation and its decision is as follows:
1. Offering PAYG Services
In future, customers with meter connectivity level (CTF) of 4 will be able to avail of a Smart PAYG
service via the ESBN smart meter. Customers with a CTF of below 4, will not. The CRU decision
1 Smart Metering High Level Design (CER/14/046)
2 Update on the Smart Meter Upgrade (CER/17/279)
3 The delivery of Phase 2 and Phase 3 functionality was extended by 9 months respectively. The Phase 2
functionality will ‘go-live’ in September 2023 (CRU21074).
1An Coimisiún um Rialáil Fóntais Commission for Regulation of Utilities
on the guidelines for budget controllers (CER/10/203) includes a requirement for all suppliers to
offer a PAYG service and to offer a prepayment meter as a debt management option to customers.
Operating an ESBN keypad meter (the current PAYG solution for customers in financial hardship)
requires financial investment by suppliers. It is important to ensure that all customers can avail of
an appropriate PAYG service (where needed for customers in financial hardship) however some
suppliers do not provide a PAYG service, which means not all customers have access to PAYG
services. The consultation proposed various alternatives, including mechanisms which allow
customers of suppliers who do not provide PAYG customers to move to a supplier who does,
where the customer wishes to avail of a PAYG service, or needs it for financial hardship reasons.
The consultation also explored debt management options for customers who do not wish to share
their granular consumption data with their supplier, and requested feedback from stakeholders.
CRU Decision
Having considered the responses and the insight provided by smaller or newer entrants, the CRU
has decided that new suppliers entering the market as well as suppliers currently in the
market with customer numbers below a certain threshold will not be required to provide
PAYG services i.e. a prepayment option for customers in financial hardship. Operating a
hardship PAYG service in the Irish market requires financial investment by suppliers with third
party operators in the energy market. This financial investment can disproportionately impact small
suppliers as it involves in particular a significant upfront cost.
This decision is in the context that the Commission considers it appropriate to recognise the
diversification of supply activities in the Irish market which has crystalised over the past few years.
In addition, the Clean Energy Package (CEP) will require changes to the regulatory framework that
facilitates new actors (suppliers) in the market. The CRU has commenced work on policy relating
to Citizen Energy Communities that will set the pathway for more engaged consumers and this
option for suppliers, who will no longer be required to provide PAYG services is a response to the
challenges presented by the current requirements for these new actors in advance of a broader
review of the regulatory framework.
The customers of suppliers who do not provide PAYG services will be advised on sign up that the
supplier does not offer prepayment services and that if the customer gets into financial hardship4
they will need to switch to another supplier to avail of a hardship prepayment service. More
information on the impact of this decision is provided in Section 2. The CRU will continue to
4 A customer is taken to be in genuine financial hardship if they are unable to make payments against their bills
without assistance and are finding themselves in constant arrears. It has been widely accepted in the market that
customers with debt outstanding for more than 6 months and above a value of €700 should be considered eligible
for a budget controller.
2An Coimisiún um Rialáil Fóntais Commission for Regulation of Utilities
consider future options in the context of the CEP, including those licensees that currently do not
provide a PAYG service.
2. Data Sharing
The consultation requested feedback from stakeholders on the requirement that to customers who
do not want to share their half hourly data, suppliers are only required to offer payment plans. This
would mean that for customers who wish to avail of a smart PAYG service but where the customer
does not want to share their half hourly data, that suppliers will only be required to offer payment
plans (not PAYG services). The consultation also asked stakeholders whether they think a PAYG
product that requires less granular data would be appropriate.
CRU Decision
The CRU considers that a PAYG service utilising half hourly data provides the necessary level of
information to ensure an appropriate customer experience which allows customers to effectively
manage their expenditure, consumption, and debt more efficiently, as their supplier will be able to
provide more accurate information and balance estimates.
Customers who decide that they do not want to share their half hourly data, which is a requirement
for Smart PAYG, can still avail of a debt management solution via a payment plan. If a customer
is in financial hardship they can request, free of charge, an ‘offline’ keypad meter, which operates
without half hourly data.
3. Obligation to offer Time-of-Use (ToU) tariffs for Smart PAYG customers
The consultation requested feedback from stakeholders on the proposal to require suppliers to
offer the Standard Smart Tariff (SST) to their Smart PAYG customers. The paper clarified that
switching to a ToU tariff remains the customer’s choice.
CRU Decision
The CRU has decided not to mandate a SST for PAYG customers. PAYG products by their nature
are based on recent consumption data enabling customers to track their consumption, and the
cost of same, in near time. Mandating a day/night/peak tariff for this type of service is therefore not
considered appropriate although suppliers are free to develop their own tariff offerings.
4. Regular Balance Messages
The consultation requested feedback from stakeholders on the proposal to require suppliers to
calculate an estimate of how long the customer’s balance is expected to last when the balance is
below 10 (instead of 7) days. It is expected that this will make it more likely that customers will be
able to plan their top-ups.
3An Coimisiún um Rialáil Fóntais Commission for Regulation of Utilities
CRU Decision
The CRU has decided that suppliers should provide credit balance estimates within Regular
Balance Messages if the estimate is below 10 days. This period of time should provide sufficient
time for the customer to top-up their account and avoid disconnection. Suppliers are free to send
more frequent messages to customers who request more frequent alerts.
5. Payment Processing
Suppliers indicated that swift reconnection is more likely with some payment channels than with
others. The consultation requested feedback from stakeholders on the proposal to require
suppliers to indicate to their customers who are being disconnected the payment channel which
allows the quickest route for reconnection.
CRU Decision
The CRU acknowledges that non-cash payments may be faster and more cost-effective but feels
that customers should also be given the option of cash payments as some customers might not
be able to access an alternative payment option.
Suppliers can promote non-cash payments but must facilitate cash payments for customers who
wish to use that payment channel.
6. Reconnection timelines
The consultation sought views on the CRU proposal on the requirement for swift reconnection and
the allocation of responsibilities for different parties of the process to suppliers and ESBN.
The CRU proposed to split the overall backstop time for reconnection in such a way that the
supplier is responsible for t1 and t2 in Figure 1 and ESBN remains responsible for t3, with the
following backstop times:
• Suppliers will be responsible for ensuring that the remote re-energisation request is
successfully sent to ESBN within 15 minutes following a successful purchase, irrespective
of the top-up channel, including cash top-up in a retail outlet.
• ESBN will be responsible for re-energising any smart meter within 15 minutes of receiving
a re-energisation request from the supplier
CRU Decision
Having considered the responses, the CRU has decided that the total reconnection time will be 1
hour and 15 minutes. This includes all steps in the process t1 – t3 as illustrated below.
4An Coimisiún um Rialáil Fóntais Commission for Regulation of Utilities
Figure 1 - Swift reconnection process for Smart PAYG customers
Where:
• t1 is the time between the customer completing the purchase and the supplier receiving
the top-up information. This may heavily depend on the payment channel (30 minutes
max).
• t2 is the time between the supplier receiving the top-up information and ESBN receiving
the re-energisation request (30 minutes max).
• t3 is the time between ESBN receiving the re-energisation request and the smart meter
being re-energised. ESBN must complete this step in no longer than 15 minutes.
Whilst t1 above is likely to be influenced by entities who are not direct CRU licensees, it remains
important for the customer experience that an overall timeline is set. Therefore, it remains a
requirement of the licensed entities (suppliers and ESBN) to ensure that each of the timelines are
met.
7. Emergency Credit
The consultation requested views whether the current policy which sets out time-based emergency
credit is appropriate or whether stakeholders would prefer an arrangement that includes monetary
credits. The consultation also requested views whether customers should be able to “trigger”
emergency reconnection through e.g., an app.
CRU Decision
The CRU is of the view that monetary based emergency credit would be a preferable option since
it limits the level of debt that can be build up by the customer to a specific amount. When compared
to the time-based emergency credit option the customer could accumulate debt for a number of
days. Therefore, the CRU has decided that a monetary level of the emergency credit of €10 be
applied to Smart PAYG products – the same level as it is currently.
The CRU is of the view that it should not be made mandatory for suppliers to offer the option to
de-energised customers to request an emergency re-energisation to get reconnected for a limited
period of time. Suppliers can at any point decide whether to offer this option to their customers on
a case-by-case basis and based on customer circumstances.
5An Coimisiún um Rialáil Fóntais Commission for Regulation of Utilities
CRU Mission Statement
The CRU’s mission is to protect the public interest in Water, Energy and Energy Safety.
The CRU is guided by four strategic priorities that sit alongside the core activities we undertake to
deliver on the public interest. These are:
• Deliver sustainable low-carbon solutions with well-regulated markets and networks.
• Ensure compliance and accountability through best regulatory practice.
• Develop effective communications to support customers and the regulatory process.
• Foster and maintain a high-performance culture and organisation to achieve our vision.
6An Coimisiún um Rialáil Fóntais Commission for Regulation of Utilities
Public Impact Statement
Smart meters are the next generation of energy meters, replacing older analogue meters which,
when fully operational, will deliver benefits for customers, the environment, and the economy. The
National Smart Metering Programme (NSMP) involves the nation-wide replacement of over two
million gas and electricity meters over a six-year period. The smart meter upgrade will transform
how energy consumption is measured, managed, and paid for.
Smart Pay-As-You-Go (Smart PAYG) is a model of prepayment that will provide customers with
ESBN smart meters the opportunity to pay up-front for their energy without the need for an
additional meter or device in the home. The deployment of smart meters and the introduction of
smart services is following a phased approach and Smart PAYG functionality is planned to go live
at the end of Phase 2 in September 2023.
Currently, customers in debt and in genuine financial hardship can avail of an ESBN keypad meter,
at no additional cost to them. With the introduction of smart meters, customers with a smart meter,
that has a sufficient connectivity level, will be able to use the Smart PAYG service without an
additional meter having to be installed. A customer in financial hardship with a smart meter and
with the required meter connectivity level (CTF 4) will be able to access a ‘hardship’ service via
the ESBN smart meter. If their meter does not have sufficient connectivity, or they wish to avail of
a less granular service which does not require sharing their half hourly data, these hardship
customers can still avail of an ESBN ‘keypad’ meter in line with the current process. This means
that an additional option will be available to hardship customers who have a smart meter installed.
This paper outlines the CRU decision around Smart PAYG policy. The programme plan is that
from 2023 customers with smart meters can avail of Smart PAYG tariffs, either as a debt recovery
solution or as a lifestyle choice, and in time this new form of prepayment will offer a more flexible
but equally robust alternative to current (non-smart meter supported) PAYG solutions. The Smart
PAYG service will enable most customers with a smart meter to avail of a PAYG service without
an additional meter being required.
In addition, Smart PAYG will allow customers to receive regular balance messages. Instead of
receiving low balance alerts from the meter, customers will receive low balance alerts from their
supplier through other channels, for example, through text or an app. Similarly, disconnection and
reconnection will not be performed by the meter but remotely by the supplier, and so Smart PAYG
will require high meter connectivity. Customers will also be able to access €10 emergency credit
which will allow for consumption up to that level to ensure supply, giving the customer a chance to
top-up their balance.
7An Coimisiún um Rialáil Fóntais Commission for Regulation of Utilities
Table of Contents
Executive Summary ................................................................................................. 1
CRU Mission Statement ........................................................................................... 6
Public Impact Statement .......................................................................................... 7
Glossary of Terms and Abbreviations.................................................................... 9
1. Introduction ...................................................................................................... 10
1.1 Background ................................................................................................................. 10
1.2 Purpose of this Decision Paper..................................................................................... 13
1.3 Related Documents ..................................................................................................... 14
2. PAYG Services in the Irish Market ................................................................. 15
2.1 Requirement to Provide Smart PAYG Services .............................................................. 15
2.2 Smart Meter Connectivity............................................................................................ 17
2.3 Data Sharing ............................................................................................................... 17
3. Customer Communications ............................................................................ 19
3.1 Mandating the SST for Smart PAYG Customers ............................................................. 19
3.2 Customer Messaging ................................................................................................... 20
3.3 Payment Processing .................................................................................................... 21
4. Disconnection and Reconnection .................................................................. 23
4.1 Swift Reconnection ..................................................................................................... 24
4.2 Emergency Credit ........................................................................................................ 25
5. Conclusion and Next Steps ............................................................................ 28
6. Appendix .......................................................................................................... 29
6.1 Consultation Questions ............................................................................................... 29
6.2 Summary of Responses to Consultation ....................................................................... 30
8An Coimisiún um Rialáil Fóntais Commission for Regulation of Utilities
Glossary of Terms and Abbreviations
Abbreviation or Term Definition or Meaning
CEP Clean Energy Package
CTF Communications Technically Feasible
ESBN ESB Networks
HLD High Level Design
NSMP National Smart Metering Programme
PAYG Pay-As-You-Go
SoLR Supplier of Last Resort
RBM Regular Balance Message
Smart PAYG PAYG services enabled by ESBN smart meters
SST Standard Smart Tariff
ToU Time-of-Use
9An Coimisiún um Rialáil Fóntais Commission for Regulation of Utilities
1. Introduction
1.1 Background
1.1.1 The Smart Meter Upgrade
The smart meter upgrade is a project to transform how electricity and gas retail markets operate.
Older, mechanical electricity and gas meters will be replaced with updated digital meters. Smart
meters will provide many benefits for energy customers by eliminating the need to use estimated
meter readings, making new products and services available like time-of-use tariffs (where the
price of electricity varies with the time of the day), and empowering customers to make more
informed choices regarding their energy needs by providing customers with more granular
information about their consumption. The upgrade to smart meters will also provide more
information to the network companies to allow them to better manage the grid and ensure security
of supply.
The CRU’s decision to rollout electricity and gas smart meters for all residential and smaller
business customers was announced in July 20125. The CRU conducted further analysis on the
design of the smart metering solution throughout 2013 and 2014 which culminated in the
publication of the High-Level Design (HLD)6 in October 2014. The HLD set out the broad
parameters of the overall design of smart electricity and gas meters in Ireland to be procured by
ESB Networks (ESBN) and Gas Networks Ireland. Since the publication of the HLD the CRU has
developed customer policy in a number of areas like transition to time-of-use tariffs, Smart PAYG,
and the provision of information to customers. Smart PAYG is described in more detail in Section
1.1.3.
The HLD was revised in 20177 at which point the deployment of smart meters and the introduction
of smart services was divided into three phases. The allocation of smart electricity meters follows
ESBN’s deployment plan. Approximately 250,000 meters were installed in Phase 1 (2019-2020)
and a further 500,000 meters are planned to be installed each year in Phase 2 (2021-2022) and
Phase 3 (2023-2024).
Smart services will also be introduced in a phased manner. Smart services for electricity such as
time-of-use tariffs, smart bills, access to historical consumption information went live on 26
February 2021. Note that smart services currently include smart electricity services only. The gas
smart metering solution is planned to be delivered in Phase 3.
5 Decision on the National Rollout of Electricity and Gas Smart Metering (CER12008)
6 Smart Metering High Level Design (CER/14/046)
7 Update on the Smart Meter Upgrade (CER/17/279)
10An Coimisiún um Rialáil Fóntais Commission for Regulation of Utilities
1.1.2 Debt Management in the Irish Retail Market
Rules around debt management in the Irish Retail Market are set out in the Electricity and Gas
Suppliers’ Handbook, Code of Practice on Disconnections. The Handbook sets out that “suppliers
are required to implement procedures for dealing with customers having difficulty paying” their bills
and must have “options available for these customers in order to avoid disconnection of supply”.
While suppliers have their own processes set out in their Codes of Practice, the general options
available to customers in debt are to agree on a payment plan with their supplier and gradually
repay their debt with each bill, or to receive a PAYG meter and gradually repay their debt with each
top-up. The Handbook sets out that “disconnection of a customer due to non-payment of account
must only be carried out as a last resort.”
The requirement to offer a PAYG meter to customers who have difficulty paying their energy bills
was introduced by the CRU in 2010 with CER/10/2038. The context for the decision was that the
economic backdrop at the time resulted in increasing numbers of domestic disconnections and an
interim solution was necessary until smart meters with prepayment functionality became available.
CER/10/203 provided a definition for customers in financial hardship: “A customer is taken to be
in genuine financial hardship if they are unable to make payments against their bills without
assistance and are finding themselves in constant arrears. In order to identify customers who need
these meters suppliers are expected to work with MABS and St. Vincent DePaul who are best
placed to identify individuals in need of this level of assistance.”
Furthermore, the CRU accepted a proposal that “customers with debt outstanding for more than 6
months and above a value of €700 should be considered eligible for a budget controller”, but also
emphasised that “customers should also show signs of being in financial hardship”.
For customers who are in genuine financial hardship and struggle to manage their electricity bills
ESBN installs a keypad meter instead of the “meter of record” at no additional cost to the customer.
ESBN keypad meters are offline meters which means that these meters do not communicate
through a telecommunications infrastructure. The customer can purchase a top-up through a
variety of payment channels (cash, phone, website, app), depending on the supplier. Following
top-up, the customer receives a top-up code and enters that top-up code manually into the meter
to adjust the credit balance on the meter.
1.1.3 Smart Pay as You Go for Electricity
Apart from ESBN keypad meters offered by suppliers as a debt management solution, many
suppliers in the market provide ‘lifestyle’ products using their own meters that are installed in a
property in addition to an ESBN meter9. Some meters are offline, with the same or similar
functionality as the ESBN keypad meter. Others have built in smart functionality, which allows top-
8 Guidelines for Budget Controllers (CER/10/203)
9 The ESB Networks meter is the ‘meter of record’. Consumption recorded by this meter is used for billing.
11An Coimisiún um Rialáil Fóntais Commission for Regulation of Utilities
up codes to be transmitted to the meter (instead of typing them in manually), allow the collection
of consumption data which customers can use to better monitor their electricity consumption, or
allow the customer to avail of emergency credit through the suppliers’ app.
Customers have multiple PAYG solutions to choose from. If they are in debt and in genuine
financial hardship, they can avail of an ESBN keypad meter, at no additional cost to the customer.
Otherwise, they can choose a supplier that offers a lifestyle PAYG product and purchase a
‘lifestyle’ PAYG meter. If telecommunications are not appropriate at their location to facilitate smart
functionality or they are reluctant to share their granular consumption data with their supplier, they
can choose an offline meter which does not transmit any data (ESBN keypad meters are also
offline meters). Altogether, PAYG products are quite popular in the Irish electricity market with an
overall market share (hardship and lifestyle combined) of approximately 12%.
The NSMP will introduce changes to the prepayment services available to customers because the
smart meters that are currently rolled out by ESBN across Ireland are capable supporting PAYG
arrangements as well. Enabling Smart PAYG functionality via the ESBN meter from 2023 will
enable the expansion of PAYG services to customers without the need for an additional meter.
Suppliers will be able to develop PAYG products without needing to invest in a meter themselves
and the focus will likely shift to a model based on customer-supplier interaction. This will also
remove technical obstacles to switching between prepayment and credit billing options.
Smart PAYG, that is, a PAYG service facilitated through the ESBN smart meter, will have key
differences compared with existing PAYG solutions. Current PAYG meters store and display
balance information on the meter and de-energise/re-energise the customer’s premises
automatically, based on that balance information. In contrast, smart meters on Smart PAYG tariffs
will not store balance information. Instead, the supplier will calculate the customer’s credit balance
in their own system, using meter reads (delivered remotely from the smart meter) and customer
top ups (delivered from their payment provider, or through the suppliers’ own systems). Smart
PAYG customers will no longer add credit directly to the meter, as the credit will be added to the
customer’s balance. This change will impact balance messaging as balance alerts will no longer
be driven by the meter but will rather be established by suppliers based on customer needs.
Similarly, de-energisation and re-energisation will not be performed automatically by the meter but
will be triggered remotely by the supplier in line with the requirements set out by the CRU.
In line with the ‘Phased Approach’, Smart PAYG functionality will be available from the end of
Phase 2 in September 202310. Once live, the Smart PAYG functionality will support additional
options for customers who wish to avail of a PAYG product without the need for an additional
meter. It is envisaged, that over time as customers and supplier offerings evolve, that Smart PAYG
may replace some of the other PAYG products, for example, ESBN keypad meters.
10 Smart Meter Upgrade Phase 2 Scope (CRU21074)
12An Coimisiún um Rialáil Fóntais Commission for Regulation of Utilities
1.2 Purpose of this Decision Paper
In 2020 the CRU issued a call for evidence11 to seek views from the public, and market participants,
on Smart PAYG policy items that had previously been identified by the CRU as requiring further
consideration before Smart PAYG services ‘go-live’ in September 2023. The paper focused on
items that were intentionally left open at earlier stages of the programme to be finalised later if
necessary, and on items that the CRU viewed may have significant impact on customers. While
respondents welcomed the opportunity to contribute to the discussion on Smart PAYG
functionality, many concerns were raised regarding the proposed solution. For example, these
concerns included guarantees around timely reconnections, constraints around providing real-time
balance information, or the requirement for an advanced IT and customer service infrastructure to
provide the same quality of service that PAYG customers are used to. Concerns were also raised
around customers in financial hardship who are not eligible for a Smart PAYG service because of
low meter connectivity or do not want to share their half-hourly consumption data. Respondents
offered a variety of suggestions which the CRU appreciated and considered while drafting the
consultation on Smart PAYG (CRU21046) which explored the following topics:
• How Smart PAYG will fit into existing debt management options.
• Access to PAYG products for all customers.
• Offering the Standard Smart Tariff to Smart PAYG customers.
• Customer messaging around credit balances and payment channels.
• Swift reconnection and guarantees around supply.
• Emergency credit.
While the CRU recognises that the new Smart PAYG solution to be delivered in 2023 will offer a
different PAYG service and some customers may prefer to be served by some of the existing
PAYG arrangements, the CRU considers that for many customers the new PAYG solution will
provide more flexible and economical alternatives to prepayment.
The NSMP and provision of Smart PAYG functionality in 2023 will enable suppliers to offer a Smart
PAYG service to their customers that leverages the smart metering infrastructure and provides
benefits like access to time-of-use tariffs or information on historical consumption to PAYG
customers as well. These decisions, where necessary, will be incorporated in the next review of
the Electricity and Gas Suppliers’ Handbook in 2021.
11 Call for Evidence on Smart Pay-As-You-Go (CRU20169)
13An Coimisiún um Rialáil Fóntais Commission for Regulation of Utilities
1.3 Related Documents
• ESB Networks - Service Level Agreements (CER 04/345)
• European Third Package Directive (EU Directive 2009/72/EC)
• Guidelines for Budget Controllers (CER/10/203)
• Decision on the National Rollout of Electricity and Gas Smart Metering (CER12008)
• Smart Metering High Level Design (CER/14/046)
• Smart Pay as You Go (CER/15/054)
• Rolling out New Services – Time-of-Use Tariffs and Smart Pay as You Go (CER/15/136)
• Rolling out New Services: Time-of-Use Tariffs (CER/15/270)
• Rolling out New Services: Smart Pay-As-You-Go (CER/15/271)
• General Data Protection Regulation (Regulation (EU) 2016/679)
• Empowering & Protecting Customers (CER/16/125)
• Update on the Smart Meter Upgrade (CER/17/279)
• Customer-Led Transition to Time-of-Use (CRU19019)
• Electricity and Gas Suppliers' Handbook 2019 (CRU19138)
• Phase 1 Checkpoint Review (CRU20075)
• Call for Evidence on Smart Pay-As-You-Go (CRU20169)
• Comparison Tools for Time of use Tariffs (CRU20146)
• Consultation on Smart Pay-As-You-Go (CRU21046)
14An Coimisiún um Rialáil Fóntais Commission for Regulation of Utilities
2. PAYG Services in the Irish Market
A variety of PAYG services are available to electricity customers in the Irish Market. Some
customers may prefer a PAYG service as a lifestyle choice, others may require a PAYG service
as a debt management solution. Since the CRU’s decision in 2010, all suppliers are required to
offer a PAYG service to customers in genuine financial hardship.
In the past 5 years several new entrants to the market have sought not to provide PAYG services
to electricity customers in financial hardship. The basis was that in most cases establishing and
managing a third-party service was resource intensive and involved in particular a significant
upfront cost while at the same time, the NSMP would enable Smart PAYG services from Phase 2.
In that context, the CRU has allowed some suppliers not to provide PAYG services. From a
customer protection perspective, such suppliers were restricted from disconnecting customers in
debt.
2.1 Requirement to Provide Smart PAYG Services
The CRU sought feedback on the requirement to provide a hardship prepayment service in its
consultation. A number of the respondents set out their view that the IT infrastructure required to
provide a Smart PAYG service is going to be complex to build and quality assure, and some
respondents highlighted that the cost of establishing such a system could disproportionately impact
small suppliers as it involved in particular a significant upfront cost, similar to the existing
prepayment solution.
As a solution, several respondents suggested the establishment of a Supplier of Last Resort
(SoLR) for PAYG. The concept in summary was that some suppliers should either not be required
to offer any PAYG services and direct their customers to a ‘SoLR for PAYG’ who can offer a
suitable PAYG product for them, or only be required to offer Smart PAYG, maybe even with limited
functionality (for example, without cash top-up), and if their customers would prefer an ESBN
keypad meter, direct them to the SoLR for PAYG. The CRU notes that the Clean Energy Package
(CEP) will likely transform the retail market and this type of innovative solution is welcome but may
not be deliverable by 2022 especially since the market wants policy clarity around Smart PAYG
policy by the middle of 2021.
The CEP is a set of European Union level legislative acts that will bring considerable benefits to
customers, industry, and the environment and underlines EU leadership in tackling global warming.
The CRU is cognisant that the CEP has set out an evolution roadmap for the retail electricity market
and market participants. It is anticipated that more diverse energy actors will enter the market over
the coming decade and the regulatory framework may need to change to reflect their business
activity. In that context, the CRU understands that a balance between customer protections and
new entrant costs must be met.
15An Coimisiún um Rialáil Fóntais Commission for Regulation of Utilities
The CRU considered the responses to the call for evidence and within its consultation the CRU
put forward three proposed alternatives for providing prepayment services for customers in
financial hardship, seeking the view of stakeholders. The CRU also asked stakeholders to outline
how these alternatives would impact them and their customers.
CRU Decision
Having considered the responses and the insight provided by smaller or newer entrants, the CRU
has decided that new suppliers entering the market as well as suppliers currently in the
market with customer numbers below a certain threshold will not be required to provide
PAYG services i.e. a prepayment option for customers in financial hardship. Operating a
hardship PAYG service in the Irish market requires financial investment by suppliers with third
party operators in the energy market, which could disproportionately impact small suppliers as it
involves in particular a significant upfront cost.
This decision is in the context that the Commission considers it appropriate to recognise the
diversification of supply activities in the Irish market which has crystalised over the past few years.
In addition, the Clean Energy Package (CEP) will require changes to the regulatory framework that
facilitates new actors (suppliers) in the market. The CRU has commenced work on policy relating
to Citizen Energy Communities that will set the pathway for more engaged consumers and this
option for suppliers, who will no longer be required to provide PAYG services is a response to the
challenges presented by the current requirements for these new actors in advance of a broader
review of the regulatory framework.
The customers of suppliers who do not provide PAYG services will be advised on sign up that the
supplier does not offer prepayment services and that if the customer gets into financial hardship
they will need to switch to another supplier to avail of a hardship prepayment service.
Suppliers who do not provide PAYG services are currently unable to disconnect non-engaging
customers who are in debt. From the end of phase 2 of the NSMP these suppliers will be required
to advise financial hardship customers that a prepayment option may be best for them. If the
customer decides to switch to a supplier who provides a PAYG service, the losing supplier will
retain the debt and they will not be permitted to raise a debt flag. This means that a supplier who
chooses not to invest in PAYG services will have to absorb the debt and from the end of phase 2
of the NSMP cannot charge a termination fee if the customer chooses to leave while ‘in contract’.
The customer can also choose not to switch to a hardship prepayment solution with another
provider. In this case, the supplier can offer a payment plan for the debt. If this is not fulfilled by
the customer and the customer is not engaging with the supplier, from the end of phase 2 of the
NSMP, the supplier can initiate a disconnection in line with the existing policy and process.
Responses to the comments received in the consultation are included in the Appendix in section
6.2.1.
16An Coimisiún um Rialáil Fóntais Commission for Regulation of Utilities
2.2 Smart Meter Connectivity
The Smart PAYG service will require sufficient meter connectivity to be able to meet the service
requirement set out in earlier decisions. This means some customers may not be eligible for a
Smart PAYG service if meter communications are consistently unreliable at their location. Within
the call for evidence the CRU asked how respondents view a PAYG service should be facilitated
for customers in financial hardship who need to avail of these services but may not be eligible for
Smart PAYG because of low meter connectivity at their premises.
The CRU considered the responses to the call for evidence and within its consultation the CRU
put forward three proposed alternatives for providing prepayment services for customers in
financial hardship, seeking the view of stakeholders. The CRU also asked stakeholders to outline
how these alternatives would impact them and their customers.
CRU Decision
The CRU considers that where the customer has a suitable CTF they should be offered a hardship
service via that the ESBN meter. If the customer would prefer an ‘ESBN keypad’ meter this should
be provided free of charge as is the current process.
This option should be offered from the end of phase 2 of the NSMP when the Smart PAYG
functionality is planned to ‘go-live’. As a result, all suppliers who currently provide PAYG services
will be required to offer this service through the ESBN Smart Meter infrastructure.
The CRU will continue to consider future options in the context of the Clean Energy Package,
including those licensees that are not required to provide a PAYG service.
2.3 Data Sharing
In line with the policy decisions set out in the 2015 decision paper on Smart PAYG12, ESBN will
collect Midnight Readings from smart meters every night at midnight. These readings will contain
half-hourly consumption data and will be provided to suppliers every day enabling them to calculate
Midnight Balances and balance estimates which will be shared with customers through Regular
Balance Messages.
The CRU notes that the bulk of the smart metering policy was defined before GDPR13 and
envisaged that all customers would share their half-hourly consumption data to have quicker
access to better information about energy usage and costs. In that context, the current smart
metering infrastructure supports the provision of a Smart PAYG service to customers who choose
12 Rolling out New Services: Smart Pay-As-You-Go (CER/15/271)
13 General Data Protection Regulation (Regulation (EU) 2016/679)
17An Coimisiún um Rialáil Fóntais Commission for Regulation of Utilities
to share their half-hourly (interval) data with both ESBN and their Suppliers. In the call for evidence
the CRU asked respondents to provide their views on data sharing.
The CRU considered the responses to the call for evidence and within the consultation the CRU
asked stakeholders for their views on the requirement for suppliers to provide PAYG services to
customers who do not wish to share their half hourly data. This would mean that for customers
who wish to avail of a smart PAYG service but where the customer does not want to share their
half hourly data, that suppliers will only be required to offer payment plans (not PAYG services).
The CRU also asked stakeholders whether they think a PAYG product that requires less granular
data would be appropriate.
CRU Decision
The CRU considers that customers who wish to avail of a ‘lifestyle’ PAYG product via the ESBN
smart meter are making a choice and those who do not want to share their half hourly data can
chose to avail of a different product.
Hardship customers, who require a PAYG service for debt management purpose via the ESBN
smart meter but do not want to share their half hourly data can avail of a keypad meter. This service
operates without half hourly data.
In relation to the granularity of data appropriate to operate a PAYG product, the CRU considered
all views received and is of the view that half-hourly data provides the necessary level of
information to ensure an appropriate customer experience which allows customers to effectively
manage their expenditure, consumption, and debt more efficiently, as their supplier would will be
able to provide more personalised accurate information and balance estimates. Customers will
need to confirm their agreement to share their half-hourly data with ESBN and their supplier. This
could be done at customer sign-up, where the supplier may require the customer to confirm that
regardless of the tariff structure they sign up for, if they should accumulate debt, and required a
PAYG service they agree to share their half hourly data for the purpose of providing the Smart
PAYG service. Customers who decide that they do not want to share their half hourly data, which
is a requirement for Smart PAYG, can still avail of a debt management solution via a payment plan.
If a customer is in financial hardship they can request, free of charge, an ‘offline’ keypad meter,
which operates without half hourly data.
Responses to the comments received in the consultation are included in the Appendix in section
6.2.2.
18An Coimisiún um Rialáil Fóntais Commission for Regulation of Utilities
3. Customer Communications
While the previous section discussed topics around eligibility for Smart PAYG as a debt
management option and the condition for availing of the service (data sharing), this section
explores questions around customer communications like offering Time of Use (ToU) tariffs,
balance messages, and available payment channels.
3.1 Mandating the SST for Smart PAYG Customers
In earlier communications the CRU outlined the benefits of ToU tariffs. ToU tariffs will enable
customers to save money and participate in protecting the environment by shifting some of their
electricity consumption to times of the day when electricity demand is lower. In 2019 the CRU
published its decision paper on a Customer-Led Transition14 that confirmed a gradual introduction
of ToU tariffs to the Irish electricity market with customers having the option to avail of such a tariff
or not. As a first step in this gradual process the 2019 decision set out that “once smart services
‘go-live,’ an electricity supplier must have available a time-of-use tariff for electricity customers,
this can be limited to a supplier’s Standard Smart Tariff”.
In the call for evidence the CRU sought view on whether or not to mandate the SST for Smart
PAYG customers. The CRU understands this question may have been slightly misunderstood and
would like to reiterate that signing up for a ToU tariff will remain the customer’s choice. The
question was whether suppliers should be required to “offer” ToU tariffs to Smart PAYG customers
as well. The CRU also wishes to clarify that if a supplier only serves PAYG customers, then they
already have to offer ToU tariffs to their PAYG customers as per the 2019 decision.
The CRU considered the responses to the call for evidence and within its consultation the CRU
put forward proposals regarding offering a Standard Smart Tariff (SST) to all customers with
appropriate meters.
CRU Decision
The CRU considered the views of respondents and decided not to mandate an SST for Smart
PAYG customers.
The rationale for this decision is that an SST might not be suitable for PAYG and particularly
financial hardship customers. Although the CRU believes that all customers should have the option
to avail of a ToU tariff, mandating a tariff based on day/night/peak rates may not be valuable for
PAYG customers who are availing of a product that seeks to provide as up to date as possible
insights on their energy consumption and expenditure.
14 The Customer-Led Transition to Time-of-Use (CRU19019)
19An Coimisiún um Rialáil Fóntais Commission for Regulation of Utilities
Based on the successful launch of a number of ToU products in Q1 2021 by suppliers, the CRU is
confident that suppliers will develop innovative tariffs for their Smart PAYG customers and that the
range available will be driven by market forces and customer demand.
Responses to the comments received in the consultation are included in the Appendix in section
6.2.3.
3.2 Customer Messaging
The 2015 decision on Smart PAYG15 sets out the minimum requirements for customer messaging.
One element of the customer messaging framework is the Regular Balance Messages (RBMs)
and the default frequency for RBMs is weekly. RBMs are regular messages that contain the
customer’s most up to date credit balance and a balance estimate (the estimated period of time
the balance is predicted to last) as well when the estimate is below 7 days.
As mentioned in a 2015 consultation on Smart PAYG16 it is likely that RBMs will be a main driver
for when the customer chooses to top up and because of this the CRU view that it may be
necessary to ensure that the minimum requirements for RBMs always allow customers to plan
their top-ups. However, within the current policy framework, receiving balance estimates in time to
allow planning ahead does not seem to be guaranteed. This stems from two decisions:
• RBMs must be sent weekly by default.
• RBMs must include a balance estimate only if the estimate is below 7 days.
It follows from the above requirements that when a customer receives a balance estimate it may
require the customer to top up within a day to stay connected which does not allow planning ahead.
While the requirements set out in the decision are minimum requirements and suppliers are
expected to meet, if not exceed them, it remains open whether the minimum requirements ensure
an acceptable quality of service for customers.
Within the call for evidence the CRU asked whether stakeholders view the minimum requirements
for RBMs ensure appropriate quality of service or whether the current policy should be amended.
The CRU also asked how suppliers plan to set up messaging with Smart PAYG customers.
The CRU considered the responses to the call for evidence and within the consultation the CRU
asked for stakeholders views regarding the proposal to provide credit balance estimates within
RBMs if the estimate is below 10 days instead of 7 days. The CRU also asked stakeholders to
provide examples that illustrate their view, if they consider the current balance messaging
framework too prescriptive.
15 Rolling out New Services: Smart Pay-As-You-Go (CER/15/271)
16 Rolling out New Services – Time-of-Use Tariffs and Smart Pay As You Go (CER/15/136)
20An Coimisiún um Rialáil Fóntais Commission for Regulation of Utilities
CRU Decision
The CRU considered the views of respondents and decided to increase the period for suppliers to
provide credit balance estimates within RBMs to 10 days instead of 7 days.
Suppliers will need to provide credit balance estimates within RBMs if the estimate is below 10
days, as this will provide sufficient time for the customer to top-up their account. The previous
minimum requirement of weekly balance messages which would contain a balance estimate when
the balance is below 7 days would not offer sufficient protection to customers. This is because a
customer whose balance estimate is 7.1 days for example, will not receive a balance estimate in
their weekly balance message, but a week later when they receive their next balance message,
the message may require urgent action and require them to top up within a day. The new
requirement, however, sets a timeframe which makes it unlikely that a customer will have less than
3 days to top up after receiving the first RBM.
Suppliers can choose to send more frequent balance messages to customers, the CRU decision
sets the minimum requirement.
In relation to the calculation of balance estimates for customers, the CRU view that the availability
of half-hourly data provides suppliers with enough information to calculate personalised balance
estimates with reasonable accuracy that will help their customers plan their top-ups. Although
having access to more frequent meter reads, i.e., two reads per day, may enable suppliers to
provide more accurate estimates for customers, ESBN has advised the CRU that the current meter
configuration does not support this and only one set of meter reads will be available for every 24-
hour period. The CRU acknowledges the limitation arising from the meter configuration and does
not intend to prescribe a desired accuracy for these estimates, the only expectation is that the
estimates should help customers plan their top-ups.
Responses to the comments received in the consultation are included in the Appendix in section
6.2.4.
3.3 Payment Processing
Suppliers offer multiple channels for topping up a customer’s PAYG account, including cash
payment, top-up by phone, or through the supplier’s website, or via an app. Within some of these
channels the customers may interact directly with their suppliers, while others involve
intermediaries.
The CRU understands that during cash prepayment when customers purchase a top-up in a retail
outlet, the front office providers (An Post, PayZone) receive the payment from the customers and
transfer these payments to the suppliers. There is also an interaction with the back-end provider
Secure Meters who provide the top up codes for customers. The customer then receives a code
21An Coimisiún um Rialáil Fóntais Commission for Regulation of Utilities
from the front office service provider and enters that code into the PAYG meter to top up their
balance on the meter.
The CRU understands that within the current framework interaction with suppliers is through batch
processing of data daily. This means when a customer purchases a top-up in a retail outlet, they
will instantly receive a top-up code which they can use to top-up their balance on their meters, but
the supplier will not receive notification of the top-up until they process vends later during the day.
With the introduction of Smart PAYG, suppliers will have to be notified of transactions more
frequently to allow near-instantaneous adjustment of customer credit balances, for example to
avoid being disconnected or to ensure swift reconnection. According to the High-Level Design17 it
is expected that retail point of sale transactions will be credited to customer credit balances near
real-time but current practices do not seem to be compatible with this decision. This has also been
highlighted by respondents in earlier consultations on Smart PAYG18. The CRU view that the
customer experience around cash prepayment is very important for all PAYG customers and is
particularly important for customers in financial hardship, as they may not have access to other
channels of prepayment.
Within the call for evidence the CRU asked:
• How customers manage top-ups for PAYG meters and specifically if there are any
differences between the available options for hardship and lifestyle PAYG customers.
• Whether the payment infrastructure should be amended to ensure customer experience
around top-ups for Smart PAYG will be equal to or better than it currently is for PAYG
customers.
The CRU considered the responses to the call for evidence and within the consultation the CRU
asked stakeholders for their view of the proposal to require suppliers to suggest specific payment
channels within Disconnection Notification Messages.
CRU Decision
The CRU considered the views of respondents and its decision with regard to the proposal to
require suppliers to suggest specific payment channels within Disconnection Notification
Messages is as follows.
The CRU acknowledges that non-cash payments may be faster and more cost-effective but
considers that customers should also be given the option of cash payments as some customers
might not be able to access an alternative payment option. Suppliers may promote non-cash
payments since these allow reduced reconnection timelines but should also provide the option of
cash payments to those customers who wish to use that payment channel. This is particularly
17 Smart Metering High Level Design (CER/14/046)
18 Rolling out New Services – Time-of-Use Tariffs and Smart Pay As You Go (CER/15/136)
22An Coimisiún um Rialáil Fóntais Commission for Regulation of Utilities
important for financial hardship customers who may not have access to other channels of
prepayment, such as access to the supplier’s website or app. Regardless of the payment method
chosen by the customer, suppliers are required to meet the obligation on reconnection timelines
as specified in section 4.1.
Responses to the comments received in the consultation are included in the Appendix in section
6.2.5.
4. Disconnection and Reconnection 19
The introduction of smart meters will enable remote de-energisation and re-energisation of the
customer’s premises, which will impact both credit and Smart PAYG customers. This new
functionality may change the disconnection process for non-payment of account and may also
compress the timeline for both de-energisation and re-energisation as these procedures will not
require a site visit from an ESBN Technician. The CRU view that compressed timelines for re-
energisation will improve service quality for all credit customers.
Whether remote re-energisation will improve service quality for Smart PAYG customers as well
depends on the reliability of the communications infrastructure. Current PAYG meters do not
require any communications infrastructure to re-energise the customer’s premises. They only
require the customer’s balance, stored on the meter, to be positive. A customer can always top-up
their meter manually through the keypad, which means as long as a customer can acquire an
appropriate top-up code, the meter can re-energise the customer’s premises. Moreover, if the
customer cannot acquire a top-up code but has not used up their emergency credit, they also have
the option to push the emergency credit button and get reconnected immediately.
Compared with current PAYG meters, remote re-energisation with smart meters will always require
the supplier to instruct ESBN to use the telecommunications network to re-energise the customer’s
premises. The dependence on such an infrastructure and the lack of an emergency facility like the
emergency credit button will introduce a new risk for de-energised Smart PAYG customers.
Lifestyle PAYG customers who will continue to use their current PAYG meters to avail of PAYG
services with their suppliers are unlikely to be impacted by remote de-energisation and re-
energisation. Similarly, hardship PAYG customers who will continue to use their ESBN keypad
meters to avail of PAYG services with their suppliers are also unlikely to be impacted. However,
customers moving from their current PAYG arrangements to a Smart PAYG service will likely be
impacted.
19 While “disconnected” meters are physically disconnected from the electricity network during a site visit by ESBN,
smart meters that are remotely “de-energised” by ESBN remain connected to the electricity network. Similarly,
“reconnection” is slightly different from “re-energisation”, but for the purposes of this paper we use these terms
interchangeably to align the terminology with earlier policy documents and we mean the process in which a
remotely de-energised smart meter is remotely re-energised by ESBN.
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