On 15 March 2023, CCW published a review of business customer experience of the water retail market five years in.
As the operator of the non-household water market, MOSL has chosen to publish a response setting out our high level views on the report and our feedback on its specific recommendations.
MOSL looks forward to working with CCW and other market participants to deliver any recommendations that will enable the market to deliver better outcomes for customers, the market or the environment.
Some of the key points from MOSL's response are listed below:
- We now know the challenges we need to overcome – while CCW’s review rightly acknowledges it is no longer a fledgling market, the market has come a long way since market opening. Some customers (mainly large water users) are benefitting and we now have a better insight and understanding of the challenges we need to overcome to enable the market to deliver value to all customers to the extent anticipated.
- Making the market work for all customers – MOSL believes the priority (and where energy and time should be spent) is to make the market work for smaller customers rather than taking these customers out of the market. We question the switching and renegotiation metrics proposed by CCW to determine if outcomes have improved as alternative competitive offerings will be restricted by the Retail Exit Code (REC) price caps.
- Complaints, switching and retailer failure – after a small spike at market opening, the trend in customer complaints to retailers and CCW has reduced. In a healthy market customers would switch from retailers not providing a good service and inefficient retailers would fail. These things are not currently happening. We would therefore have welcomed more focus in CCW’s recommendations on the structural barriers at play in the market and how these can be resolved.
- Timelines for delivery – with the BR-MeX (business customer and retailer measure of experience) performance commitment due to come into force after a trial period in April 2025 and the reformed Market Performance Framework (MPF) from April 2024, time will be needed for the value to be obtained for these new mechanisms and other changes proposed. We therefore believe April 2025 will be too early to fully reassess whether the market is delivering for smaller customers, particularly in relation to CCW’s proposal that it could call for these customers to be removed from the market at that time.
MOSL's full response can be found here. CCW's review is available here.
If you have any questions on our response please email
