Response to CEER Public Consultation on 2021 Guidelines of Good Practice on Comparison Tools

key messages

• We believe information about the CTs should be readily available to consumers, but the bill is not the most appropriate place for that information
• There is concern around protection of consumer data and the ability for informed consent of consumers when it comes to automatic switching
• We feel the focus of the ranking systems should be on objective parameters, like expected price for the consumer, but additional relevant information about each offer should be available for the customer to assess
• The algorithm for CTs should be made public and should clarify how the CT develops its ranking
• There should be separate sections within CTs for different price structures with clear information about the conditions of the different offers (e.g., fixed price contracts, dynamic price contracts)