For nearly three months now I’ve been at Swedenergy’s office in Brussels and I have immersed into the Electricity market directive and regulation. One of the articles, article 18 and Annex II, is about billing and billing information. From my long experience in this business I strongly believe, and so does Swedenergy, that the invoice should be simple to the customers to understand and only contain the most basic information about the cost. Regulation on extensive information on the bill will lead to more complexity, confusion and even dissatisfaction among customers. In today’s digital society there are more suitable ways to inform customers other than on the bill. Thus, detailed information about consumption and variables influencing the cost could be provided through other channels and at different frequencies depending on customer needs and preferences.

Generally, the customers just see the invoice as a bearer of energy costs and not a bearer of other information which is not directly related to the costs. This has been verified in several market studies. The customer becomes more and more digitalised and request information in other ways, like in apps, webpages and even devices installed in their own homes. In the market design trilogues, the council’s approach has been to have an as clean and simple invoice as possible, and the information which is not directly related to the energy cost can be obtained from for example websites. Within the parliament, however, there are several parties who argued for further regulation regarding what should be included in the invoice and how it should be designed.

Swedenergy believes that in a competitive market, the design and format of the bill should be treated as a means of competition and therefore should not be regulated and standardised. Furthermore, in a more and more digitalised world we believe that creating outdated detailed regulation risks hindering innovation and new solutions.

Finally, an agreement has now been found on billing and the provisions have unfortunately been made more prescriptive than in the commissions original proposal. However, there seems to be a positive development allowing information to be delivered electronically, which is something that Swedenergy has fought for. To my understanding it varies between member states (MS) how the actors communicate with customers, and with that in mind I really hope that the final interpretation of the text will leave it up to each MS to decide on how to deliver the required information to the customers.

Birgitta Rasmussen (Visiting Star at Swedenergy’s Brussels office)

External Analysis

Mälarenergi AB