Providing complete and accurate information to the Electricity Registry

This case study looks at an industry participant’s obligation to take all practicable steps to ensure that any information it provided to any person (including to customers) was complete and accurate in the Electricity Registry.

A case study where inaccurate information was provided

This case study looks at the relationship between the information required to be populated in the Registry’s static tables and the ICP attributes that rely on this static data.

For this particular scenario, a distributor assigned loss factor codes to ICPs and needed to ensure that each assigned code had corresponding loss factor values available for the entire period it was applied. This highlights the obligation to maintain accurate, consistent data links between Registry static information and ICP‑level attributes.

The distributor in this case used two types of loss factor codes:

  • to reflect static loss factor values (no end date)
  • to reflect seasonal loss factor values (with end dates for specific seasons).

Each year, before May and October, the distributor reviewed and updated the loss factor values for its seasonal loss codes. In September 2023, two loss factor codes reflecting static values were mistakenly given seasonal end dates. Because the distributor’s review process only looked at seasonal codes, the error wasn’t identified and corrected.

When the Registry Manager sent the monthly loss factor codes file to the Reconciliation Manager, the two affected codes were excluded (due to their expired end dates). This caused two reconciliation participants’ May 2024 volume submissions to be rejected, as the Reconciliation Manager's system flagged the loss codes as invalid.

The distributor was notified and applied corrections to the static data within the Registry but did not realise the file loss factor code value file transfer had already occurred between the Registry and the Reconciliation Manager. This caused a further delay while the Registry Manager was requested to rerun and provide a revised file to the Reconciliation Manager. All participants were able to meet the submission deadline therefore there was no actual impact to the reconciliation or market settlement functions.

The Authority began looking into the alleged Cod breach and, during this time, the participant accepted it had breached the Code but had already put in place better controls to prevent future issues.

The Authority determined no further action was required under regulation 11(1)(c) of the Electricity Industry (Enforcement) Regulations.

Analysis

When considering an alleged breach, the Authority considers the participant’s breach history (amongst other matters). The participant in this case had not previously breached this Code provision.

The Authority had to determine whether all practicable steps had been taken by the participant due to the severity of the failure to keep information up to date. During the alleged breach preliminary assessment process, the Authority determined that all practicable steps had not been taken by the participant to ensure the accuracy of its Registry information. If the Registry information had not been corrected, the affected reconciliation participants would not have been able to submit their submission files to the Reconciliation Manager without first removing or amending the affected aggregated records.

The participant subsequently took steps to remedy the situation, which met the requirement under clause 11.2(2) of the Code. The participant also provided details of the additional steps it had implemented to prevent any future recurrence.

Lessons learned

Participants should ensure sufficient checks are implemented and performed regularly to identify and correct any data anomalies before submitting information to the Registry.

Information accuracy is critical for participants (including consumers) that use the Registry data for their functions. When information is inaccurate, it may adversely impact a participant’s ability to switch a consumer, allocate the appropriate pricing plan to a customer, accurately bill a consumer, or accurately submit volume information to the Reconciliation Manager. The Reconciliation Manager also relies on accurate and complete Registry data to carry out its functions.

Ultimately it is the participant’s responsibility to make sure Registry information is complete and accurate. Both in terms of time sliced individual ICP attribute information but also where a participant is responsible for information held in static data tables. The participant must ensure that any ICP attribute assigned to an ICP has a current record in the static data table.

Background

Part 11 of the Electricity Industry Participation Code (Code) provides for the management of information in the Registry and requires participants to take all practicable steps to ensure that information that the participant is required to provide to any person under this Part (including customers) is complete and accurate and not, nor likely to be, misleading or deceptive. Incorrect information could adversely impact:

  • the ability of the Reconciliation Manager to perform its functions
  • market settlement to be accurate and timely with any volume or invoice disputes
  • consumers’ ability to make informed decisions
  • other participants and the participant itself to fulfil their Code obligations in an accurate and timely manner
  • fulfilling Code obligations in an accurate and timely manner.

Code provisions

11.2 Requirement to provide complete and accurate information

(1) A participant must take all practicable steps to ensure that information that the participant is required to provide to any person under this Part (including customers) is—

(a) complete and accurate; and

(b) not misleading or deceptive; and

(c) not likely to mislead or deceive.

(2) If a participant becomes aware that the information the participant provided under this Part does not comply with subclause (1)(a) to (c), even if the participant has taken all practicable steps to ensure that the information complies, the participant must, as soon as practicable, provide such further information as is necessary to ensure that the information complies with subclause (1)(a) to (c).