The Council of European Energy Regulators (CEER) published its first Handbook for National Energy Regulators on Retail Market Assessment in 2017 and introduced 25 indicators for national regulatory authorities (NRAs) to assess the functioning of retail electricity and gas markets. Since then, the energy landscape and legislation in Europe have undergone significant changes – from the 2019 Clean Energy Package to the new directives on market model changes from 2024 – which necessitated an update of the handbook. In October 2025, CEER published a revised handbook in which the indicators were expanded to 28 and their definitions were clarified.

Overview of the methodology and framework

CEER’s framework for assessing the retail market: The CEER handbook uses a three-tier framework of Guiding Principles, Key Characteristics and Indicators/Measures (now supplemented with specific indicators) to assess the functioning of the retail market. The two guiding principles are ‘Competition and Innovation’ and ‘Consumer Participation’, within which eight key characteristics of a well-functioning retail market are defined. Each of these is linked to one or more quantitative or qualitative indicators.

In the 2025 revision, CEER introduces additional metrics for each indicator – specific data or questions – to facilitate and guide NRAs in their market assessment.

Key characteristics and indicators (2025 vs. 2017): The table below summarises the eight key characteristics and corresponding indicators in the original 2017 Guidelines compared to the updated 2025 Guidelines.

Characteristic	2017 indicators (C16-SC-52-03)	2025 indicators (C25-RMR-173-05)	Key changes
I. Low concentration (within the relevant market)	1. Herfindahl-Hirschman Index (HHI)	1. Herfindahl-Hirschman Index (HHI), concentration ratio (CR) and number of active suppliers	Revised: Includes CR and number of suppliers (not just HHI) to better reflect market structure.
II. Low barriers to market entry	2. Regulatory and legal requirements for market access 3. Time and costs for accessing wholesale markets and licensing/balancing regimes 4. % of consumers served by ‘vertically integrated’ DSOs (distribution + supply) 5. % of consumers with regulated energy prices 6. Common data standards or existence of a centralised data hub 7. Availability of electricity meters for time-of-use (TOU) metering (additional payment/tariffing for TOU metering)	2. Regulatory and legal requirements for market access 3. Time and costs for access to wholesale markets and licensing/balancing regimes 4. Types of DSOs and their role (including % of consumers served by integrated DSO+supplier) 5. % of consumers with public intervention (non-market interventions) in price setting (regulated prices) 6. Common data standards and standards for contracts between DSOs and suppliers or national data centre 7. Availability of smart meters (with hourly (interval) metering capability)	Revised: – Indicator 4: Expanded to take into account the separation and roles of DSOs, not just % of consumers of integrated network operator+supplier – Indicator 5: Reformulated as public intervention on prices (includes any form of non-market influence and price regulation) – Indicator 7: Simplified to the availability of smart meters (with the possibility of time-of-use/hourly pricing).
III. Linking wholesale and retail prices	8. Correlation between wholesale and retail prices 9. Retail mark-up over wholesale prices	8. Correlation between wholesale and retail prices 9. Mark-up between wholesale and retail prices	Largely unchanged: The indicators are retained to measure the effectiveness of price transmission and market signals from wholesale to retail markets.
IV. Range of offers (including response to consumption)	10. Variety of pricing and billing options 11. Value-added services for implicit demand response and prosumers 12. Availability of online offers 13. Contracts guaranteeing the origin of energy from renewable sources (green offers) 14. Offers for explicit demand response	10. Variety of products, prices and billing options 11. Value-added services for implicit demand response and prosumers 12. Information on the origin of energy from renewable sources and the role of the NRA in disclosing the fuel/energy mix 13. Offers for explicit demand response	Revised/Added: – Indicator 10: Now includes a variety of products (e.g. dynamic, green, bundled offers) – Indicator 12: Replaces “online offers” with a requirement for transparency regarding the origin of energy and disclosure of the fuel mix (reflecting consumer interest in green energy).
V. High level of awareness and trust	15. % of consumers who know they can switch suppliers 16. % of consumers who are aware of the role of DSOs (continuity of supply and metering) 17. % of consumers who trust the energy market	14. % of consumers who know they can switch suppliers 15. % of consumers who know the responsibilities of DSOs (continuity of supply, metering) 16. % of consumers who trust the energy market	The indicators have been renumbered from 14 to 16 in 2025, with the focus remaining on the results of the consumer survey on awareness and trust.
VI. Availability of consumer empowerment tools	18. % of consumers with access to ≥1 independent, verified price comparison tool (PCT) 19. % of consumers with access to online information on their historical consumption 20. % of consumers with access to a standardised switching process (and its duration and complexity)	17. % of consumers with access to ≥1 independent comparison tool and online customer services 18. % of consumers with access to online information on historical consumption 19. % of consumers with access to a standardised switching process (and its duration)	Revised: – Indicator 17: The availability of online customer service portals is now taken into account in addition to comparison websites (reflecting progress in the digitisation of processes and consumer behaviour). – Indicators 18 and 19 remain unchanged.
VII. Sufficient consumer engagement (activity)	21. Percentage of supplier switching 22. % of inactive consumers (have never switched supplier)	20. Percentage of supplier switching and percentage of inactive consumers 21. Percentage of prosumers, energy communities, energy sharing groups, etc.	Revised/New: – Indicator 20: Combines the switching rate and inactivity rate into a single indicator to reflect the overall level of consumer engagement – Indicator 21 (NEW): Introduces monitoring of consumer-producers, energy communities and sharing groups, in line with the emerging roles of consumers within the clean energy package.
VIII. Appropriate protection of vulnerable and protected consumers	23. Time between notification of unpaid bill and disconnection 24. % of supply disconnections due to non-payment 25. % of suppliers complying with minimum information standards in bills/brochures (not explicitly separated in 2017, partially covered in consumer rights) 26. Protection of vulnerable and energy-poor customers 27. Alternative dispute resolution (ADR), complaint handling and the role of NRAs in consumer protection	22. Time between notification of non-payment and disconnection and % of disconnections due to non-payment 23. Minimum standards for key information in brochures and bills (percentage of suppliers complying with the standards) 24. Protection of energy-poor and vulnerable customers 25. Alternative dispute resolution, complaint handling and the role of NRAs in protecting consumer rights 26. Supplier of last resort (SOLR) agreements 27. Market resilience and supplier stability 28. Cybersecurity and data protection	Revised/New: – Indicator 22: Combines the duration and frequency of supply interruptions into a single indicator to provide a comprehensive view of non-payment issues – Indicator 23 (NEW): Adds an indicator for transparency in billing/ s (compliance with standard information requirements) – Indicator 24: (Unchanged focus on vulnerable customers). – Indicator 25: (Unchanged focus on ADR/complaints). – Indicator 26 (NEW): Introduces monitoring of last resort supplier provisions (to protect customers in the event of a supplier’s bankruptcy). – Indicator 27 (NEW): Introduces market resilience – assessment of suppliers’ financial stability and risk management in light of the 2021–22 energy crisis. – Indicator 28 (NEW): Introduces an indicator for cybersecurity and data protection, reflecting the increasing digitalisation of retail markets.

As the table shows, the core framework of 8 key characteristics remains, but the 2025 revision adjusts many indicators in response to new EU legislation and market developments. In particular, the indicators now take into account the provisions of the Clean Energy Package (e.g. rights of active consumers and energy communities), the 2019 Electricity Directive (e.g. clearer standards for billing information, dynamic pricing rights) and reforms to electricity market design (e.g. hedging and sustainability requirements for suppliers). The CEER’s objective is to ensure the relevance, adequacy and clarity of the indicators and to provide comprehensive guidance to national regulators.

Analysis of indicators

The updates generally reflect three factors:

(a) consistency with new legal requirements for retail markets and consumer rights,

(b) lessons learned from recent market developments (e.g. the energy price crisis) and

(c) the changing nature of energy consumers (digitalisation, communities, prosumers, etc.).

Low market concentration (indicator 1)

Indicator 1 (market concentration): In the 2017 handbook, the Herfindahl-Hirschman Index (HHI) was used as the sole concentration indicator. The 2025 update expands this indicator to include the concentration ratio (CR) for leading suppliers and the total number of active competing suppliers. Implications: In practice, using all three indicators provides a more complete picture of the market structure. For example, a market may have a moderate HHI but still have only a few active suppliers – a nuance captured by the CR and the number of suppliers. The inclusion of multiple measures of concentration is consistent with competition practices and helps NRAs to identify dominant or oligopolistic conditions more clearly. For regulators, this means looking not only at how concentrated the market is, but also at how much choice consumers actually have.

Low barriers to market entry (indicators 2–7)

Indicator 2 (Regulatory and legal barriers to entry): This indicator remains essentially the same in 2025, but with an updated context. It examines whether onerous licensing requirements, compliance costs or administrative burdens hinder the entry or expansion of new suppliers into the market. The 2025 handbook places a new emphasis on financial soundness requirements as potential barriers, with the noting that rules aimed at ensuring the stability of providers (e.g. capital adequacy or hedging requirements under new EU rules) may inadvertently raise the costs of market entry. Implications: Regulators need to balance market integrity with market opening. CEER explicitly invites NRAs to carefully analyse whether recent measures (such as Article 18a on supplier sustainability) are “perceived as barriers to existing or new suppliers”. In short, the update to indicator 2 reminds policymakers that regulations born of good intentions (to protect consumers or the system) must be reviewed for proportionality so that they do not block innovation or competition.

Indicator 3 (Time and cost to enter wholesale and balancing markets): Retained from 2017, this indicator assesses how easy it is for a new retailer to participate in energy supply and balancing arrangements. The 2025 handbook continues to emphasise equal, non-discriminatory access to wholesale and balancing markets for all suppliers. One slight change is the guidance to collect qualitative information from market participants (surveys, etc.) on their market entry costs. Significance: By 2025, many markets have implemented standardised market entry procedures, but CEER encourages NRAs to verify practical market access. The importance of this indicator is highlighted by regional market integration efforts – if access to a neighbouring country’s wholesale market is difficult or cross-border balancing is expensive or slow, this represents a barrier. Regulators should use this indicator to identify hidden barriers (e.g. long processing times, high collateral requirements) that can be removed.

Indicator 4 (Role of DSOs and network access): In 2017, the focus is on the percentage of customers served by ‘integrated’ DSOs, i.e. distribution system operators that are still integrated with the energy supply company. The 2025 indicator is expanded to “Types of DSOs in the market and their role”, explicitly taking into account the unbundling status of DSOs and their participation in competitive (non-monopoly within the meaning of their licence) activities. This reflects the evolving European norm that DSOs should be neutral market facilitators. Implications: NRAs must now assess not only how many consumers are served by vertically integrated companies, but also whether DSOs are acting in a way that affects retail competition. For example, if a DSO is involved in data management or billing on behalf of suppliers, is it doing so impartially and efficiently? The updated indicator encourages careful scrutiny of any structural advantages that incumbent suppliers may retain through network companies of the same structure. It is also linked to data centres (indicator 6) – for example, if the national centralised data hub is managed by the distribution system operator, the regulator must ensure equal access for all suppliers.

Indicator 5 (Price regulation – public intervention in pricing): The 2017 indicator simply tracks the share of consumers with regulated prices. The 2025 version reformulates this as ‘percentage of consumers with public intervention in pricing’. The meaning is the same – essentially measuring what share of the retail market is still subject to price controls or tariffs set by the government – but the wording is in line with EU policy to phase out general price regulation, allowing only targeted (and temporary) interventions. Implications: This indicator remains a critical indicator of market liberalisation. A high percentage here often correlates with a low degree of switching to another supplier and low competition. By extending the term to “public intervention”, CEER covers not only classic regulated tariffs, but also all indirect price control mechanisms. NRAs should interpret a decline in this indicator (fewer regulated customers) as positive for competition, provided that consumer protection measures are in place (see key feature 8).

Indicator 6 (Access to data – common standards/centralised data hubs): This indicator remains unchanged between 2017 and 2025, reflecting its continued importance. It checks whether there are common standards for data exchange and/or a centralised data hub for customers’ energy (market) data. Such infrastructure reduces barriers to market entry by simplifying the way new suppliers obtain meter readings, switching information, etc. Significance: The continued inclusion of this indicator by CEER sends a clear message that data is the new lifeblood of competitive markets. The existence of a centralised data hub or standardised interfaces also leads to greater consumer awareness, enabling a smooth switch to another supplier and innovative services.

Indicator 7 (Smart metering / Availability of hourly/interval metering): The 2017 handbook describes this as the availability of hourly electricity meters and whether consumers have to pay extra for hourly metering compared to traditional meters. By 2025, the indicator has been simplified to “availability of smart metering”, assuming that smart meters enable time-of-use pricing by default. This reflects the progress in the roll-out of smart meters across Europe and new legislative targets. Implications: Regulators need to monitor what proportion of consumers can actually benefit from dynamic or time-differentiated pricing. The mention of additional charges has decreased, probably because EU rules (and many national regulators) no longer encourage or even prohibit any additional charges for consumers who choose a smart meter or time-of-use tariff. The consequence is that the universal roll-out of smart meters is a policy goal; if a country is lagging behind, this indicator will reflect that. In the analysis, the low score here should be compared with indicator 10 (product diversity) and indicator 13 (clear demand-response offers), as these cannot develop without smart meters.

Close correlation between wholesale and retail prices (indicators 8–9)

Indicator 8 (link between wholesale and retail prices) and indicator 9 (retail mark-up over wholesale prices): These two indicators have been carried over from 2017 without any change in their definition. Together, they measure how well retail prices reflect changes in wholesale energy prices and the size of the gross margin or additional charges in the retail price. Significance: The continued use of these indicators highlights their importance for assessing market efficiency and competition. In a well-functioning market, retail prices should broadly follow wholesale price trends (high correlation), and excessive mark-ups and surcharges should be eliminated through competition. On the other hand, a large gap or increasing mark-up may signal problems – perhaps insufficient competition or the existence of old regulated tariffs that protect consumers from wholesale price fluctuations (thus reducing the correlation).

Diversity of offers and innovation (indicators 10–13)

Indicator 10 (Diversity of products, prices and billing options): Previously focused on prices and billing options, this indicator now explicitly includes product diversity. In practice, ‘products’ can mean different types of contracts (fixed vs. variable, spot-indexed, green tariffs, bundled services, etc.). The 2025 extension takes into account the fact that innovation in retail markets has led to the emergence of many new types of offers that go beyond billing frequency or payment method. CEER monitoring shows that across Europe, consumers in most countries can choose between different pricing structures (fixed, variable, capped, time-of-use, etc.) and value-added products. Implications: NRAs should assess whether their market offers a wide choice or whether most consumers are tied to the same contract. A low score (limited choice) may indicate barriers to product innovation or dominance by incumbent operators offering only basic regulated plans.

Indicator 11 (Value-added services for implicit response to consumption and prosumers): This indicator remains unchanged and tracks the availability of services such as smart meters, energy efficiency advice, solar panel installation offers, etc., which help consumers adjust their consumption or produce their own energy. Significance: The continued focus here is in line with the EU’s green transition goals. By 2025, many countries are seeing growth in rooftop solar panels, home batteries, smart home devices, etc., which are often offered through or in partnership with suppliers. NRAs observing low availability of such services may identify issues in the regulatory framework or market design that hinder innovation. For example, if Bulgarian suppliers do not yet offer solar panel leasing programmes or consumption management programmes, this may be due to regulatory uncertainty or the lack of a favourable framework (such as dynamic pricing or clear rules for aggregators). The indicator encourages regulators to create an environment in which companies feel confident to introduce these new services – ultimately to help consumers save energy or integrate renewable energy sources.

Indicator 12 (Information on RES origin and fuel mix disclosure): This is a new indicator for 2025, replacing the 2017 indicator, which simply checked whether there were contracts guaranteeing green energy. The scope is now broader: it checks whether consumers have access to information on the origin of the electricity supplied (i.e. how ‘green’ it is) and the role of NRAs in ensuring accurate disclosure of the fuel mix. The change reflects a greater emphasis on transparency and the prevention of “greenwashing”. Implications: NRAs are expected to monitor how suppliers communicate the source of their energy to their customers and whether guarantees of origin are being used correctly. This indicator is in line with recent CEER work on reliable green offers. For Bulgaria, where the penetration of renewable energy sources is growing but consumer awareness of green tariffs is still limited, this indicator is an incentive to improve disclosure. The regulatory authority may need to issue guidelines or enforce EU requirements for electricity suppliers’ bills to show the energy mix and associated CO₂ emissions. A high score on indicator 12 would mean that consumers can easily find and trust information, for example on what percentage of their electricity comes from renewable energy sources, enabling them to make informed choices.

Indicator 13 (Explicit demand-response offers): This indicator remains the same, focusing on whether consumers can participate in demand-response programmes. These are schemes in which consumers are rewarded for shifting or reducing their consumption at the request of the system (often through an aggregator or capacity markets). Significance: Its inclusion in both 2017 and 2025 indicates that demand response is still an evolving part of retail markets. Many countries have made progress in facilitating demand response (e.g. by allowing independent aggregators), but accessibility for small consumers remains limited. Regulators should interpret this indicator in relation to the deployment of technologies (smart meters) and market rules. If indicator 13 is low (few or no such offers), this may be due to the lack of necessary regulatory frameworks or signals (e.g. lack of DR programmes or markets that are not open to aggregators). In Bulgaria, there are virtually no explicit DR offers for households to date. The continued presence of the indicator signals the expectation that even countries that do not currently have such programmes should plan them as part of a well-functioning market by 2025. This is both an indicator and a target – to encourage NRAs to integrate demand-side flexibility into retail markets.

Consumer awareness and trust (indicators 14-16)

Indicator 14 (Consumer awareness of switching) and indicator 15 (Awareness of the role of DSOs): These are measured through consumer surveys: the percentage of consumers who know they have the right to switch suppliers and who understand that the DSO (distribution system operator) is responsible for continuity of supply (and metering), not the supplier. The indicators themselves have not changed between 2017 and 2025, but their importance has undoubtedly increased as markets have matured. Implications: Low awareness can be a serious barrier to competition – if people do not know they can switch suppliers, or mistakenly attribute supply interruptions to their retailer, they are less likely to engage with the market. CEER’s continued focus in this area suggests that NRAs should regularly commission or obtain survey data to track these rates. Improving these indicators often requires consumer awareness campaigns. The 2025 handbook, which links these indicators to consumer outcomes, emphasises that a well-informed consumer base is key to a well-functioning market.

Indicator 16 (Consumer confidence in the energy market): This indicator, also derived from surveys, measures the share of consumers who express confidence in the energy market as a whole (that it works fairly for them). There are no changes to its definition. Significance: Trust is a general sentiment that can influence the willingness to switch suppliers or accept new offers. It can be influenced by many factors (price increases, news of supplier bankruptcies, scandals or misinformation, etc.). The fact that the indicator remains the same shows that CEER still considers it a useful high-level barometer. It is a little more difficult for regulators to directly “move the needle” on trust, but the existence of this indicator means that NRAs should monitor it and perhaps use it as a measure of the results of their policies. If trust is low or declining, this may signal problems such as poor customer service, frequent disputes or negative publicity surrounding the market.

Consumer empowerment tools (indicators 17–19)

Indicator 17 (access to comparison tools and online services): This indicator was expanded in 2025. In 2017, it reflects the percentage of consumers who have access to at least one independent and verified price comparison tool (PCT). In 2025, it further examines whether consumers have access to online customer services (e.g. the ability to manage contracts or queries online). Implications: The expansion reflects the digitalisation of retail services. The verified comparison tool remains essential – it helps consumers shop easily. Many EU countries already have official or accredited comparison websites (often managed or certified by NRAs). The 2025 Handbook clearly states that this should be a universal requirement. The addition of ‘online customer services’ recognises that, in addition to finding a deal, consumers benefit from digital self-service (viewing bills, consumption, changing plans via web/app). For NRAs, a high score of 17 means that most consumers are aware of the comparison website and can use it, and that large suppliers offer online account management.

Indicator 18 (Access to consumption data – historical consumption): This indicator remains the same, measuring what percentage of consumers have access to information about their past consumption in online format. It is linked to the requirements of the EU Electricity Directive, according to which consumers are entitled to timely data on their energy consumption. Significance: If smart metering (indicator 7) progresses, this indicator should also improve, as smart meters are usually accompanied by consumer data portals or at least detailed bills. For regulators, monitoring this indicator ensures that consumers can make informed decisions (e.g. use their data to choose the best tariff or identify energy saving opportunities). A low score may mean that either IT systems are lacking (no portals or poor functionality) or that data is available but not easy to use, so consumers do not use it. The inclusion of this indicator in 2025 emphasises that access to data is a consumer right and NRAs should enforce it. Furthermore, with the emergence of third-party energy management services, consideration could be given in the future to ensuring that consumers can download or transfer their consumption data to other applications (with their consent).

Indicator 19 (Standardised process and speed of switching): This indicator also remains from 2017 and checks whether there is a fast and uniform process for switching to another supplier and what proportion of consumers have access to it. “Access” essentially means that the process is accessible to all (not just some) and works effectively. The duration of the switching process is explicitly stated, in line with EU targets. Implications: CEER’s continued focus on this indicator shows that in some countries there are still cumbersome switching procedures (taking weeks or involving heavy documentation) that hinder consumer mobility. By measuring this indicator, NRAs can determine whether existing provisions are an obstacle to the switching process. Ideally, close to 100% of consumers should have access to a simple and quick switch (meaning that the framework is national), and the average time to switch to another supplier should be no more than one or two days. If this is not the case, regulatory or technical improvements are needed (e.g. centralised switching platforms, better coordination between old and new suppliers, etc.).

Levels of consumer engagement (indicators 20-21)

Indicator 20 (switching rate and inactivity rate): In 2017, the switching rate and the inactivity rate were two separate indicators. The 2025 update combines them, as they are two sides of the same coin. This indicator shows how many consumers switch to another supplier in a given period (annual switching rate) and how many have never switched to another supplier (inactivity). Significance: By combining them, CEER emphasises the importance of looking at the overall distribution of engagement. For example, an annual switching rate of 5% may seem modest, but if 80% of consumers have never switched supplier, this means that the market is still largely inert. Conversely, if many consumers have switched at least once but switching has slowed down recently, this suggests that the market is mature and consumers are likely to be satisfied. Regulators should use this indicator to assess whether interventions are needed to stimulate competition – for example, if inactivity is extremely high, targeted outreach to consumers or removal of perceived barriers (such as complex procedures, as per indicator 19) may be necessary.

Indicator 21 (Prosumers, energy communities and sharing groups – new): One of the notable new indicators in 2025, indicator 21 measures the percentage of consumers who are prosumers (producing their own electricity, for example through rooftop solar panels) or participants in citizen energy communities or energy sharing schemes. This stems directly from the definitions of active customers and energy communities in the Clean Energy for Europe Energy Package. Significance: By including this indicator, the CEER recognises that consumer engagement is not limited to switching suppliers, but also includes new ways of participating, such as self-generation and collective schemes. Regulators are encouraged to track how many consumers are taking advantage of these opportunities. A higher percentage indicates a more active and engaged consumer base, possibly with more innovation and greater competition (prosumers can reduce demand from suppliers or even become suppliers themselves). For NRAs, improving this indicator could involve easing administrative barriers to installing photovoltaic panels, allowing trading between equal participants or community projects, and ensuring fair network tariffs for prosumers.

Consumer protection and market sustainability (indicators 22–28)

Indicator 22 (Disconnection for non-payment – time and frequency): The 2025 Handbook combines two related consumer protection indicators into one. It looks at the time between the notification of late payment and the actual disconnection, as well as the percentage of customers disconnected for non-payment. In 2017, these were separate indicators, but combining them allows for an integrated analysis of disconnection practices. Significance: This indicator reflects how suppliers and the system treat vulnerable customers or those experiencing payment difficulties. A long period between notification and disconnection (e.g. a generous grace period) and a low disconnection rate are usually signs of a protective approach, possibly imposed by regulators or achieved through supplier policies. CEER has probably combined them to encourage NRAs to establish a link between the two indicators: if the disconnection rate is high, what is the notice period? If the notice period is very short, this may contribute to higher disconnections, and so on. Regulators should use this to ensure that national rules are adequate – for example, requiring a minimum notice period, payment plans or intervention by social services before disconnection. For Bulgaria, energy poverty is a real concern (it has one of the highest shares of the population experiencing difficulties in paying their utility bills in the EU). The indicator is also a measure of social impact: a rising percentage of disconnections would be a signal that affordability problems are increasing or that protection measures need to be strengthened.

Indicator 23 (Minimum standards for information in offers and bills – new): This new indicator checks what percentage of suppliers comply with the prescribed standards for information disclosure in their marketing and billing. EU directives list the information that must appear on bills and in advertisements (e.g. price breakdown, energy mix, complaint channels, etc.). Significance: By adding this indicator, CEER emphasises consumers’ rights to clear and sufficient information. It encourages NRAs to actively monitor and enforce transparency and clarity in bills, and to ensure that advertisements for energy offers include key facts (preventing claims that are “too good to be true”). A high compliance rate indicates that consumers are likely to receive understandable bills and reliable advertising, which in turn can improve trust (indicator 16) and engagement. If compliance is low, regulators may need to impose sanctions or issue more detailed guidance. In summary, indicator 23 adds a qualitative aspect of consumer protection to the handbook – it is not just about whether consumers have choice, but whether they are well informed about that choice.

Indicator 24 (Protection of vulnerable and energy-poor customers): This indicator remains essentially the same, assessing the existence and effectiveness of measures to protect vulnerable consumers (e.g. those using life-support equipment, low-income households, etc.). It may include monitoring of special tariffs, social tariffs, safeguards against disconnection, or financial support schemes. Significance: Retaining this indicator emphasises that a market cannot be considered well-functioning if it leaves the most vulnerable behind. CEER has updated the annexes to the 2025 Handbook to reflect consumer rights in the new Electricity Directive and gives an idea of what this indicator covers (e.g. the right to last resort supply, assistance for the energy poor, etc.). Regulators need to both implement existing safeguards and assess whether they are adequate. Indicator 24 will guide NRAs in reviewing these national measures. If the data show an increasing number of households meeting the criteria for ‘energy poverty’, the regulatory authority may need to coordinate with the government to expand assistance, which would involve further policy recommendations.

Indicator 25 (Alternative dispute resolution and complaint handling): Carried over from 2017, this indicator checks whether there are effective ways to resolve consumer complaints (through procedures with the supplier, regulator or independent alternative dispute resolution body) and the role of NRAs in protecting consumer rights. Significance: The continued inclusion of this indicator means that NRAs must track the number of complaints, resolution times and the availability of ADR (e.g. energy ombudsman or mediation procedure) for their market. This is often less a quantitative indicator and more a matter of regulatory oversight: ensuring that suppliers have standards for handling complaints and that unresolved issues can be escalated through a clear and effective procedure. A well-functioning market should have relatively low levels of escalated complaints and accessible dispute resolution. The CEER framework could encourage, for example, the publication of an annual report on complaints (categories, outcomes) or the creation of a dedicated energy ombudsman where one does not exist. Ultimately, this indicator is about trust: if consumers know that their problems will be looked at and sorted out fairly, they’ll have more confidence in the market.

Indicator 26 (Supplier of last resort – new): This is a new indicator that focuses on supplier of last resort (SOLR) provisions. SOLR is a mechanism that ensures continuity of supply if a supplier goes bankrupt or if a consumer has not chosen a supplier in a fully liberalised market. Significance: Its inclusion is driven by the recognition that with the opening of markets and the emergence of smaller suppliers (some of which may go bankrupt, as seen during the energy crisis in 2021), the existence of a robust SOLR scheme is vital for consumer protection. For NRAs, this indicator means that they need to review and possibly stress test existing DPI agreements. For example, are consumers switching to DPI subject to significantly higher tariffs and, if so, for how long? Is the customer transfer process running smoothly? A potential challenge is to ensure that DPI prices are fair (market-based but not punitive), but also that consumers are encouraged to switch from DPI to competitive market offers. This indicator is closely linked to consumer engagement (if many consumers remain on the IUP by inertia, this is not a good outcome in the long term). The role of NRAs, as indicated by CEER, may include supervising or managing the IUP appointment process and monitoring the impact on consumers.

Indicator 27 (Market resilience and supplier stability – new): Added in response to the 2021–2022 energy crisis, this indicator assesses the financial stability of the retail market. CEER notes that during the crisis, several suppliers across Europe left the market for financial reasons. Indicator 27 includes indicators such as the supplier exit rate (number of supplier bankruptcies per year), the existence of hedging requirements and whether suppliers comply with them, rules on suppliers’ financial obligations (capital adequacy, guarantees) and risk management practices (stress tests, credit balance protection). Significance: This is an important new area for NRAs. It effectively asks the question: is the retail sector healthy enough to withstand price shocks without chaotic bankruptcies? Regulators need to monitor not only consumer-related indicators, but also suppliers’ business models and their exposure to risk. CEER explicitly refers to the new provisions of the Electricity Directive (Article 18a), which require suppliers to manage risk (e.g. by hedging their wholesale commitments). A high frequency of supplier bankruptcies or a lack of hedging would result in a low score on this indicator and would signal that regulatory measures are needed (tightening licensing conditions, requiring stress tests, etc.). The advantage of focusing on sustainability is consumer protection through prevention – avoiding situations where tens of thousands of customers suddenly find themselves with a DSO because their supplier has gone bankrupt. CEER’s objective for this indicator is a financially sustainable market that benefits consumers by reducing the likelihood and costs of widespread bankruptcies – it encourages NRAs to take on a more proactive supervisory role, similar to that of financial regulators, which marks an evolution in regulatory responsibilities.

Indicator 28 (Cybersecurity and data protection – new): The latest new indicator takes into account the increasing digitalisation of retail energy. With smart meters, data centres and digital services, energy companies collect and process vast amounts of consumer data. Indicator 28 refers to the measures put in place to protect these data and systems from cyber threats. It covers the existence of cybersecurity requirements for suppliers/DSOs, reported incidents, protocols for data access breaches, etc. Implications: This indicator introduces an emerging but critical issue in the assessment of the retail market. Consumers will not accept smart, digital energy services if they fear that their privacy will be violated or that their supplier’s IT system could be hacked (leading to outages or fraud). CEER notes that the roll-out of smart meters has ‘increased the volume of digital energy data’ that needs to be protected. For NRAs, indicator 28 may be challenging, as oversight of cybersecurity is often the responsibility of other authorities (e.g. national cybersecurity agencies). However, the regulatory authority can coordinate actions to ensure that the energy sector meets high standards — possibly by applying the requirements of the EU Network and Information Security (NIS) Directive to energy, certifying data processing procedures, etc.

Challenges in the CEER 2025 methodology

• Challenges related to data availability and quality: The handbook assumes that NRAs can obtain data for each indicator, but in practice this may be difficult. For example, indicators such as consumer trust or awareness are based on surveys that not all regulators conduct regularly. Smaller NRAs with limited budgets and administrative capacity may not have the resources to conduct annual surveys with statistical precision. Similarly, indicator 27 (financial sustainability of suppliers) requires access to companies’ financial and hedging information, which may be commercially sensitive. CEER acknowledges to some extent the historical problem of data completeness and expects improvements with digitalisation (smart meters, etc.).However, a gap remains: the methodology does not provide specific guidance on approaches or frequency of data collection. It is unclear whether NRAs should measure each indicator annually, biennially or on an event-driven basis. For Bulgaria, the EWRC will have to establish new data collection processes and may face initial uncertainty or inconsistencies.
• Comparability versus national specificities: The indicators aim at a harmonised assessment, but not all indicators are equally relevant for all countries at all times (CEER itself noted that not all aspects are a reality in all markets, e.g. prosumers, dynamic pricing, etc.). In the case of Bulgaria, some indicators (such as explicit offers for DR or energy communities) are future-oriented. The methodology does not clearly indicate how to treat indicators that are practically zero, as the concept is in its infancy – should this be considered a market failure or simply noted as “not yet applicable”? This ambiguity could lead to misinterpretation. A country may receive a ‘poor’ rating for something that is not yet expected to be developed. Each NRO must contextualise such indicators (e.g. a low score on indicator 13 for Bulgaria is not a failure in itself in 2025, but a target for 2025–2030). This nuance is not well reflected in the assessment in the handbook.
• Weight and interactions of indicators: The handbook presents the indicators as separate elements under key characteristics, but in reality they interact and are interrelated. For example, high concentration (indicator 1) may lead to a low degree of supplier switching (indicator 20), or extensive price regulation (indicator 5) may lead to a low correlation between wholesale and retail prices (indicator 8). The methodology does not specify any weighting or composite index. However, this may be seen as an omission for those who want to get an overall picture of the state of the market: there is no single assessment or threshold for a ‘well-functioning’ market. NRAs must make a qualitative assessment of whether improvements in some indicators compensate for stagnation in others. Uncertainty arises as to how to balance the indicators when making decisions for the purposes of measuring effectiveness and changing policies. For example, is a market with excellent consumer awareness and engagement (indicators 14-20) but moderate concentration considered better than a market with low engagement but many offers and low prices? The CEER framework leaves this interpretation open. Each NRA must determine internally which indicators are most important for the national context. Clearer guidance on interpreting the results of the multi-criteria approach would be useful in future versions.
• Lack of a direct affordability indicator: It is noteworthy that the indicators do not explicitly include price levels or affordability for the average consumer (except indirectly through mark-ups or outage rates). A market may meet all the criteria for “well-functioning” but have very high prices (due to external factors), which is a politically sensitive issue. CEER has omitted the price level in order to focus on structure and process rather than on outcomes influenced by global markets. For national regulators, however, affordability is a key issue. This seems like an omission – the lack of an indicator that reflects energy affordability or the prevalence of energy poverty. CEER includes the protection of vulnerable customers and supply interruptions, which are proxies, but it could be argued that a direct indicator (such as ‘% of household income spent on energy by the average consumer’ or similar) could complement the set. Bulgaria, for example, may have a highly competitive market, but if prices double and incomes do not, it is difficult to say that it is functioning well for consumers. NRAs will monitor affordability through other means (national statistics), but this is beyond the scope of the CEER handbook.
• Complexity and practical application: With 28 indicators (compared to 25 previously), the complexity of the framework has increased. There is a risk that NRAs will treat it as a compliance checklist rather than a strategic tool. CEER adds and combines indicators for greater clarity, but some indicators remain complex in themselves (indicators 27 and 28, in particular, are almost mini-frameworks in themselves). For NRAs, assessing all 28 indicators is a significant task. It could be argued that the methodology would benefit from clearer prioritisation of indicators or modular application. CEER probably expects NRAs to focus first on the most relevant indicators, but the guide itself does not classify them. With limited administrative capacity, NRAs should concentrate their resources on the indicators that reveal the most pressing problems (e.g. competition and consumer protection in the early years of liberalisation) and not burden themselves with those that are less urgent. This is more a practical consideration than a shortcoming, but it suggests that future CEER guidelines could include case studies on how to phase in the assessment.
• New trends not explicitly covered: The updated indicators add prosumers, energy communities, sustainability and cybersecurity. However, energy markets are evolving rapidly and it is foreseeable that additional aspects will emerge that will become relevant. For example, the integration of electric vehicles – tariffs for charging electric cars or the participation of electric cars in demand response mechanisms – is not explicitly mentioned, but will soon become important for retail markets. Similarly, innovative business models such as local flexibility markets may need to be assessed against indicators in the future. Although the handbook cannot cover everything, this raises uncertainty about scope: at what point do new phenomena get their own indicators? CEER recognises the dynamic nature and that it will review the indicators periodically. However, regulators need to remain flexible.
• Comparative analysis and sufficiency: The handbook raises questions about the relevance, sufficiency and clarity of the indicators during consultations. It is questionable whether 28 indicators are sufficient to declare a market ‘well-functioning’, or whether some critical intangible aspects remain untouched. For example, the quality of customer service (waiting times, quality of complaint handling) is not measured directly, except through complaints (indicator 25) or trust in a broad sense. Furthermore, innovation is partly reflected in the variety of offers and services, but it could be argued that there is no indicator for ‘technological innovation in retail’, except for implicit mentions. As the energy transition progresses, it may be necessary to introduce indicators of how retail markets facilitate decarbonisation (e.g. percentage of green products).