Consumer & Product Data Act 2025

How will Open Electricity impact retailers and consumers?

A man working on solar panels
  • Insight
  • 3 minute read
  • January 13, 2026

The application of the Consumer and Product Data Act 2025 to the New Zealand retail electricity sector.

What is Open Electricity?

Open Electricity introduces mandatory data sharing for retail electricity providers.

Under the Consumer and Product Data Act 2025 (CPDA) retail electricity is the second sector required to participate in New Zealand’s Consumer Data Right (CDR), following the banking sector.

Later in 2026, under incoming sector specific regulation, retail electricity providers will be required to share specified customer and product data to accredited third-party providers, where explicit customer consent is provided.

Retail electricity providers are expected to be required to:

  • Act as regulated data holders.
  • Provide standardised datasets through secure APIs.
  • Respond to data requests promptly or immediately from accredited third-parties.
  • Provide data at no charge to the requestor.

Open Electricity moves data sharing from voluntary or ad-hoc arrangements to a mandatory, standardised and enforceable regime for the retail electricity sector. 

Open Electricity will mean customers can access data around their electricity consumption and product options quickly, clearly and securely - and be able to share that information securely with others who can help them get the most out of their data. This will help them optimise their energy use and make important household decisions, like whether to install solar or buy an electric vehicle.”

Hon. Scott SimpsonMinister of Commerce and Consumer Affairs

How will retail electricity providers be impacted?

Open Electricity will change how retail electricity providers, aggregators and other energy services providers compete and  operate.

For retailers, Open Electricity is expected to:

  • Driver greater price transparency and comparability requirements.
  • Reduce barriers for customer switching.
  • Lift the importance of customer experience, digital capability and service innovation.
  • Increase new regulatory and data-governance obligations.

For other industry participants:

  • Third party aggregators/virtual power plant (VPP) providers - faster acquisition/onboarding and greater volumes.
  • Solar and battery providers - more accurate economics, higher conversion rates and continuous optimisation.

Open Electricity may lower switching friction and reduce information asymmetry, moving the market away from relationship-based customer retention toward competition on transparent value, personalised insights, and differentiated service offerings.

What actions will retailers need to take?

Retailers will need to prepare for both regulatory compliance and operational change. 

Retail providers will likely need to:

  • Establish clear governance and accountability for Open Electricity obligations.
  • Assess current data, system and API readiness, including metering, billing and CRM platforms.
  • Design and implement secure, standardised data-sharing APIs.
  • Put in place robust customer consent management processes.
  • Verify and manage accredited third-party access to data.
  • Strengthen data security, privacy and incident response controls.
  • Test data accuracy, timeliness and customer-level controls before go-live.
  • Prepare customer-facing teams for increased switching and data-enabled interactions.

Early preparation will reduce delivery risk and allow retailers to make deliberate choices about how they compete in a more transparent market.

What opportunities could it create for retail providers?

Open Electricity could enable retailers to use data more strategically, not just increase compliance requirements.

With customer consent and appropriate accreditation, retailers could:

  • Access richer, more timely usage and demand data across customer portfolios.
  • Improve demand forecasting and load profiling at a more granular level.
  • Design more targeted pricing, plans and incentives based on actual usage behaviour.
  • Develop new customer-facing tools (e.g. usage insights, cost optimisation, alerts).
  • Form partnerships with third parties to extend propositions beyond electricity supply.

For retailers that move early, Open Electricity may support better commercial decision-making.

Key dates for compliance

Open Electricity will be phased in over the next two years, with compliance required by mid-2027, based on sector specific regulation coming into force mid-2026.

Key dates, based on statements from the Ministers of Energy and Commerce & Consumer Affairs, will be as follows:

  • Mid-2026: Open Electricity sector regulations likely to take effect.
  • Mid-2026 to mid-2027: Industry transition and implementation period.
  • Mid-2027: Retail electricity providers required to be compliant with CPDA under sector specific regulation.

This timetable leaves retailers with a narrow window to design, build and operationalise new data-sharing capabilities.

How PwC can help

We’re confident that with our experienced team and our global perspective from countries where CDR has already been implemented, we will be able to support you in your preparations for CDR. 

In particular, we can support you with a CDR ‘course setter’; a diagnostic tool to review your readiness for CDR, help you scope and prioritise CDR-required activities. Our ‘course setter’ brings together our specialists from legal, cyber, data, equity, customer experience, technology and compliance to ensure that you are well-positioned to respond to this transformational change. 

Consumer Data Right

The way consumers share their data is changing. How can you prepare your business?

Contact us

Andrew Wilshire
Andrew Wilshire

Partner, PwC New Zealand

Simon Healy
Simon Healy

Partner, Deals - Corporate Finance & Infrastructure, PwC New Zealand

Robyn Campbell
Robyn Campbell

Partner, Cyber and Privacy - Risk Services, PwC New Zealand

Polly  Ralph
Polly Ralph

Director, Privacy Law Lead, PwC Legal

Aaron Webb
Aaron Webb

Director, PwC New Zealand

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