Unlocking Consumer Energy Resources: Addressing data sharing barriers with retailer participation

As Australia accelerates its transition to a decarbonised energy system, the role of Consumer Energy Resources (CER) has become central to the reliability, affordability, and resilience of the system.  Rooftop solar, batteries, electric vehicles and smart appliances are no longer niche, they are fast becoming critical system resources. 

But without effective data sharing frameworks, the full value of CER cannot be realised for system operators, distribution businesses, retail and wholesale markets, or for consumers. 

The recent consultation paper on Data Sharing Arrangements to Inform Planning and Enable Future Markets (Priority M.2 of the National CER Roadmap) has identified the (six) core barriers to effective data sharing.  It says these barriers compromise system performance, impede innovation, and delay market reform.  

At eighty pages it’s a dense document, seeking to inform “an effective data sharing framework that can enable CER flexibility that supports informed consumer choices, efficient market interactions, the entry of new and innovative products and service providers, scalability and integration of future CER, and reliable and secure system operation.”  So, with that remit it’s ambitious too.  And it probably will need to be broken down again into more discrete work parcels. 

Retailers, as consumer-facing market participants and increasingly active orchestrators of CER services, are uniquely placed to address many of these challenges, provided they are supported by clear policy direction and regulatory alignment. 

We take a look at some of the major barriers identified in the consultation paper; Common Practices, Interoperability and Data Quality.  And the future role of retailers in addressing each. 

The Data Sharing Barriers, possible Implications and Policy Considerations 

1. A Lack of Common Practices 

Where data sharing occurs through bespoke, bilateral arrangements, with no sector-wide agreement on formats, permissions, or exchange protocols it can have consequential impacts: 

• High transaction costs and duplicated effort 
• Delays in onboarding or verifying CER assets 
• Inefficient coordination between actors 

Adopting standardised formats for device onboarding and orchestration and aligning those digital processes with DNSP systems and other shared data exchange platforms is very much a good idea, for several reasons: 

Reduced Integration Costs

Where every retailer or aggregator that wants to enrol a new CER device has to build a bespoke interface to each DNSP’s portal or API, there is merit in standardising on a common data model that means a “build once, deploy everywhere” outcome.  This has the benefits of faster time to market for new products, lower development and maintenance costs, and fewer one off fixes. 

Improved Data Quality and Consistency

With a single, agreed schema for things like inverter technical specs and connection point identifiers the chance of mismatches or missing fields drops dramatically.  This means higher confidence forecasting, more accurate network assessments, and fewer customer support escalations when data isn’t where it’s supposed to be. 

Scalability and Innovation 

Standardisation lowers the barrier for new retailers, aggregators, or software vendors to enter multiple regions.  They simply implement the one standard API rather than ten different ones for each DNSP.  This delivers a more vibrant market for the likes of novel VPP products or energy management systems that can scale nationally. 

Stronger Alignment with Future Market Reforms 

The Consultation Paper explicitly calls for clarity and consistency in device level data and market mechanisms.  It argues that locking in a standard now ensures today’s “no regrets” reforms won’t become tomorrow’s costly rework, as could happen if left unchecked and a distribution level market or independent DSO starts mandating its own formats.  The clear benefit that is seen is the lower risk of rework as integration layers build. 

Policy focus for common practices

Retailers support the development of common API standards, data templates, and governance structures for interoperable data sharing across jurisdictions.  In practice, this means adopting standardised formats in onboarding and orchestration services, along with aligning the digital processes of DNSPs and data exchange platforms.   

2. Poor Interoperability 

Devices such as rooftop solar inverters, batteries, electric vehicle (EV) chargers, and home energy management systems are often developed using proprietary software and hardware platforms.  Whilst we don’t want to stifle innovation, these platforms don’t necessarily adhere to common communication protocols, making it difficult for devices from different manufacturers to interact or respond collectively.  It creates a kind of paradox.  Early smart home devices for example, each implemented slightly different ZigBee profiles, leading to interoperability nightmares.  Consumers who bought one brand couldn’t integrate sensors or controllers from another, slowing overall market growth until more universal standards emerged.  But what emerged from the chaos were more efficient and more secure alternatives,So, did those early interoperability problems actually drive innovation? A rigid protocol choice makes it harder to adopt newer ones.  Where’s the “no regrets” sweet spot? 

From a system perspective any lack of interoperability means that each device may operate in isolation, even when physically co-located or enrolled in the same orchestration program.  This can have real life impacts, for example: 

• A retailer running a demand response program may have to build and maintain separate APIs for each battery brand it supports.  This significantly raises the cost of orchestration and limits the program’s scalability. 
• A customer installs a high end battery with a proprietary control platform.  Later, they want to join their new retailer’s VPP but the platform doesn’t support the device in a VPP, meaning the customer has to forgo participation or replace hardware. 
• During an emergency voltage event, some batteries and solar inverters automatically curtail, while others remain online, worsening the problem.  The system operator cannot issue a unified control signal. 

To mitigate these risks today, open and widely adopted protocol standards with modular gateways that can translate between protocols should be sought. 

Policy Focus and opportunities: 

Poor interoperability could create a critical bottleneck to realising the full value of CER.  There are opportunities for retailers to lead in this space whereby: 

• Retailers preferentially procure or partner with interoperable CER manufacturers. 

• Retailers educate consumers on the benefits of open systems and future-proof technologies. 

• Retailers continue to participate in industry working groups and trials that promote balanced standardisation (e.g. Project Symphony, Project EDGE). 

Retailers would like to see policy and retail market alignment, to avoid the risk that we risk build a patchwork energy system where flexibility is constrained, innovation is stifled, and consumers are locked out of emerging services.  Enabling interoperability is foundational to an open, secure and affordable energy future.   

Retailers have a role to ensure that bundled CER products and services adhere to open and widely adopted standards that enable customers to switch retailers or aggregators without reinvestment in hardware. 

3. Low Data Quality 

Accurate, complete and consistent data is foundational to integrating Consumer Energy Resources (CER) effectively.  And we can learn from experience here.  The AEMO Distributed Energy Resources (DER) Register was established to provide a centralised national database of small scale energy systems like rooftop solar, batteries, and other consumer energy resources.  Its core purpose was to improve visibility of DER installations across the grid, supporting better forecasting, system planning, and operational decisions.  By capturing consistent data on the location, size, and capabilities of these systems, the register aimed to help AEMO, DNSPs, and market bodies manage the growing impact of DER on the electricity system, including during peak demand or emergency events.  And if this all sounds familiar; it’s pretty much what this current project is about too. 

Beyond operational needs, the DER register was also intended to support the safe integration of DER into market services such as virtual power plants, while promoting consistent data standards across the sector.  It was designed to enable more coordinated digital processes between installers, DNSPs, AEMO, and potentially retailers, helping to future-proof the grid for a two-way energy system where consumers are both users and suppliers of electricity. 

Yet data quality issues are widespread across the system.  The DER Register has only partially succeeded. It has improved visibility, but the data quality is mixed, with accuracy, completeness, and consistency still major concerns.  The Energy Security Board and AEMO have publicly acknowledged the shortcomings.  Back in 2018,  the AEC argued for a governance model where responsibility for data collection lay with the DNSPs, who already managed all customer connections.  On reflection, maybe a retailer led model could have been a better choice. 

Low data quality still matters.   

Without quality data: 

1. System forecasting and planning becomes unreliable 

• DNSPs, TNSPs and AEMO depend on CER visibility to model demand, forecast rooftop solar output, and to assess hosting capacity. 
• Inaccurate location or capacity data can lead to under or overestimation of net load, compromising dispatch decisions and investment plans.

2. Emergency response is weakened

• During critical events (e.g. extreme weather or voltage excursions), poor visibility of DER location and characteristics reduces the effectiveness of coordinated emergency controls or curtailment.

3. Customer switching and service access becomes cumbersome

• If retailers or aggregators can't verify device details, customers may be blocked from joining VPPs or switching to flexible export tariffs. 
• Errors in meter/CER linkage can result in billing mistakes or delays in activating new services. 

Low data quality has practical impacts: 

When the data is incomplete, inconsistent or just plain wrong, the real world fallout can be significant.  Here are some possible practical impacts, illustrated with examples: 

• A DNSP calculates hosting capacity for a feeder based on registry data showing 500 kW of rooftop PV — but due to poor data capture, there is actually over 800 kW installed. The mismatch leads to voltage management issues and unplanned curtailment. 
• A customer switches retailers and signs up for a dynamic export plan — but their new retailer cannot verify the customer’s inverter is standards-compliant because the installation record is incomplete. The service is denied or delayed for weeks. 
• During a bushfire-related emergency, AEMO issues curtailment instructions to aggregators but due to missing or mismatched asset IDs, a significant portion of devices cannot be reached, or respond incorrectly. 
• A VPP operator attempts to bid into FCAS markets but fails to meet telemetry and asset conformance requirements because serial numbers and firmware details in its fleet database are unreliable or unavailable. 

In practice, these impacts compound over time. That’s why data quality is so critical. It ensures that everyone can make the right decisions, safely, efficiently, and with confidence. 

Policy priorities and recommendations 

There are underlying causes of low data quality that must be addressed or the experience of this costly new data sharing capability will mirror that of the current DER Register.  This requires: 

• Removing manual, paper-based commissioning processes still used by many installers. 
• Requiring mandatory validation of CER registration fields. 
• Proper coordination between installers, DNSPs, retailers and customers. 
• Real-time asset update mechanisms (e.g. for firmware or operational status). 
• New obligations or incentives for data stewardship beyond installation. 

We should not be repeating the mistakes of the DER Register. 

Enabling secure, role-based access to CER data via a national CER Data Exchange with clear consumer consent and privacy protections is the obvious priority.  To achieve this, firstly there must be an established national CER data quality and governance framework, coordinated through AEMO, to define: 

• Minimum data fields required for all CER devices. 
• Validation procedures at installation and registration. 
• Role based responsibilities for ongoing data maintenance. 
• Data sharing obligations under privacy and consumer consent safeguards. 
• Harmonised jurisdictional and market body processes to reduce data mismatches. 

In establishing this foundation, we lay the groundwork for a more transparent, efficient and resilient energy system.  By embedding robust governance and data quality standards into every stage of the CER lifecycle, we not only safeguard privacy and choice, but also unlock the full potential of distributed energy resources to deliver reliable and cost effective outcomes.  

Retailer role and opportunities 

Retailers will act as data agents on behalf of customers, and will collaborate with data exchange platforms to streamline access for authorised purposes. Retailers have a critical operational role in improving data quality, particularly through: 

• Their onboarding and switching processes: validating customer CER details (e.g. device type, standards compliance, control capability) before enrolling customers in new services. 
• Integration with asset registries: interfacing with CER register and the CER Data Exchange to ensure the most up to date information is used. 
• Collaboration with installers and OEMs: standardised information flows at the point of commissioning to ensure accuracy from the start. 

Low data quality is not a minor administrative issue, it’s a risk that affects planning, pricing, emergency response and customer experience.  Fixing low quality data requires coordinated reform across the CER network, and retailers are well placed to lead improvements to data collection and quality through their digital systems, customer touchpoints, and growing orchestration capabilities. 

Retailers can improve data capture and validation at onboarding and at switching, and participate in national asset registration or data exchange initiatives.    

Final Considerations for Policy Makers 

There are genuine capacity constraints to addressing each of these and the many more changes required.  The anticipated squeeze on retailer innovation and competition costs in the DMO review fails to acknowledge that expected returns to retail operations are key factor in driving innovation. In as much as Retailers need to have confidence that they can incur the development costs necessary to meet future data quality requirements, and then in this case share the additional value these create with their customers, whilst earning a return on the investment.  The current and future level of the DMO is clearly a factor in decisions on expected returns, and investment in data quality is no exception. 

Getting data quality right is a national infrastructure priority.  Retailers are not and should not be defined as passive intermediaries in the energy market.  They are increasingly involved in active load management, aggregation, and real-time optimisation of customer assets, and retailer systems and processes are critical to the success of any CER integration strategy.  Without quality data and effective data sharing frameworks, the full value of CER cannot be realised for system operators, for markets, or for consumers.