As noted in the Consultation Paper, the selection of energy data access model will affect the cost and operation of the Energy CDR system. The models offer different levels of transparency and control to consumers and the selection of model design will be a direct influence on the consumer experience within the Energy CDR framework. CPRC considers that of the three models included in the Consultation Paper, either Model 2 (gateway) or Model 3 (open banking) would be appropriate. More information on data security, storage and transfer arrangements, as well as consumer consent processes, would be required before a final assessment of either model.
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