ESIA Submission: IPART Consultation - Operational changes to scheme participant compliance processes, 19 April 2024
Annual reporting is too delayed for the ESS following the compliance year. This is not helpful for keeping all stakeholders informed and can result in missed market opportunities.
ESIA members have raised concerns.
Background on compliances dates for the ESS and PDRS
- Due to the COVID-19 pandemic, the ESS compliance date was pushed back to allow obligated parties more time to meet their requirements.
- This change was not reversed after the pandemic.
- The PDRS first compliance year was launched in 2022-2023 and the compliance date was not initially aligned with the ESS.
- The PDRS compliance date was then adjusted to align with the ESS date, even though it has not been re-adjusted back to when it had been pre-COVID.
Current state of play proposed by IPART to be continue – unattractive features from and ACP perspective:
- The compliance report is released for the ESS 1.5 years after the compliance period. Vital market information is not made available to the market in a timely manner.
- The compliance report dates for the PDRS are ok as they are and the ESIA appreciates that they cannot be brought into line with the ESS pre-COVID dates as June-July is too soon after the 31 March compliance period end date of the PDRS.
Impacts on obligated parties:
- Obligated parties are accustomed to dealing with varied compliance calendars, for example the RET which is based on calendar year.
- The RET reporting schedule, in relation to the ESS, means that obligated parties have all the information they need to be able to report in a timely manner even if the dates were to be re-adjusted back to pre-COVID dates.
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