Retail energy markets across Europe are evolving with new products, dynamic pricing, and bundled services. While these changes expand choice and flexibility, they also increase complexity for consumers. Ensuring access to clear, accurate, and comparable information is essential for active participation and effective competition. Transparency and comparability are key elements of well-functioning retail markets and the strengthening of consumer rights.

On April 28, 2026, the Council of European Energy Regulators (CEER) published a report on transparency and comparability in the retail markets for electricity and natural gas. The document identifies the challenges consumers face when comparing energy offers and proposes specific tools to address them

Although many countries have introduced tools to improve transparency, differences still exist in how information is presented to consumers. Price comparison tools are widely used but vary in scope, governance, and functionality. At the same time, increasingly complex offers make comparison difficult.

The findings highlight that:

• Transparency and comparability are essential for consumer engagement and trust.
• Differences in how information is presented can limit effective comparison.
• Price comparison tools play a central role but are not always consistent.
• More complex products create new challenges for consumers.
• Clear, standardized, and accessible information remains crucial.

The recommendations include improving the clarity and standardization of key information, strengthening comparison tools, and ensuring that regulatory frameworks continue to keep pace with innovation and evolving consumer needs.

Taxonomy of Pricing Structures in Energy Contracts

The systematic classification of pricing structures occupies a central place in the document, as the liberalization of the retail market has led to significant diversification of contract models. CEER distinguishes five main categories. Fixed-price contracts guarantee the consumer a unit price known in advance, which remains unchanged for the entire term pursuant to Article 2(15a) of Directive (EU) 2019/944, as amended by Directive (EU) 2024/1711. Flat-rate contracts represent their simplest form, excluding any elements of flexibility. Indexed (variable) price contracts include at least one price component linked to market conditions—typically monthly or quarterly wholesale averages. Dynamically priced contracts, as defined in Article 2(15) of Directive (EU) 2019/944, reflect fluctuations in spot markets at a frequency equal to the settlement interval—up to 15 minutes. Hybrid contracts combine fixed and indexed elements depending on consumption thresholds or time periods. Time-of-use pricing can be added to any of these types, introducing different rates during predefined time blocks.

Key challenges to the comparability of offers

CEER identifies four categories of challenges that compromise the consumer’s ability to make an informed choice. First, the nature of pricing structures makes direct comparison difficult, especially between qualitatively different offers, such as a fixed-price contract versus a dynamically priced contract. Even within the same category, significant differences exist: indexed contracts may be based on different periods (one month, three months), and time-of-use tariffs on different numbers of time blocks.

Second, household behavior and consumption are becoming increasingly unpredictable due to the proliferation of photovoltaic installations, heat pumps, electric vehicles, home batteries, and energy management systems (EMS). The standardized consumption profiles used to date by comparison tools are gradually losing their relevance.

Third, market uncertainty, stemming from both internal factors (volatility of renewable generation) and external ones (international conflicts, pandemics), is undermining consumer confidence in indexed and dynamic offers, even when such offers would provide them with lower costs.

Fourth, the proliferation of bundled offers and the emergence of intermediary platforms add new layers of opacity. Bundled products may contain services whose price becomes unacceptably high once the energy component of the bundle is discontinued, and intermediary platforms often do not disclose their financial models and ranking algorithms, which creates a risk of favoring “sponsoring” suppliers.

Standardization of consumer contracts

Chapter 3.1 of the report proposes an ambitious approach to harmonizing contractual information. Without insisting on a single pan-European template, which would be practically difficult to implement given national differences, CEER proposes a common set of guiding principles and standardized core elements developed nationally within a common European framework. These include clear identification of the supplier and the offer with a unique identification code; explicit specification of the service and the commodity (electricity, gas, or dual-fuel); a transparent description of bundled services and equipment with independent termination rights; a clear distinction between the overall contract term and the period during which the price is guaranteed (e.g., in a 12-month contract where the fixed price applies only for the first three months); terms for renewal and termination with explicitly stated clauses for automatic renewal; early termination fees with a calculation methodology; a standardized breakdown of the price (energy component in €/kWh, fixed fee, network costs, and taxes, separate lines for non-energy services); an indexation mechanism for variable prices with defined reference markets; promotional terms with a clearly stated price upon their expiration and an individual assessment of annual costs.

The models of Portugal, Italy, and Greece, which have developed standardized pre-contractual templates, as well as Spain’s regulatory approach, are cited as particularly successful examples.

Transparency regarding termination fees and dynamic pricing

The report devotes special attention to two technically complex areas. Regarding fees for early termination of fixed-price fixed-term contracts, CEER proposes four principles:

• absolute upfront transparency in the standardized summary;
• a clear calculation methodology with a maximum value specified (based on the Italian model);
• the right to information upon request regarding the specific amount under current market conditions;
• mandatory inclusion of the fee in certified comparison tools.

The Dutch model, which links the fee to the supplier’s actual hedging losses, is recommended as best practice—when market prices rise, the fee is zero, reflecting the “no loss, no fee” principle. Regarding dynamic contracts, informed consent is required, based on an assessment of the consumer’s suitability, taking into account potential opportunities for flexible consumption (electric vehicles, heat pumps, batteries), a simple and transparent reference price linked to the “day-ahead” market, constant and free access to forecast prices prior to consumption with a level of detail equal to the settlement period, a clear bill with aggregated data and access to hourly or 15-minute data, and fair representation in comparison tools through illustrative scenarios and an explicit warning that actual costs depend on the consumer’s ability to shift their consumption over time.

Next-Generation Comparison Tools

Chapter 3.2 revisits the role of comparison tools, which, according to CEER, must evolve from simple ranking interfaces into decision support systems. Four national practices are analyzed.

VNR’s Flemish V-test® stands out for its deep integration with the distribution network operator Mijn Fluvius’s database via API, the use of 15-minute data for real-time comparison, and the ability to simulate scenarios, such as investing in photovoltaics or an electric vehicle.

The Swedish approach by Ei emphasizes consumer education and adaptation to volatility—in 2026, functionality for automation services (smart EV charging, heating) is set to be introduced.

Portugal’s ERSE focuses on time-of-use tariffs in three variants (simple, two-hour, three-hour), but notes low demand for multi-period offers from households.

The Greek energycost.gr by RAAEY, updated in April 2024, offers a comparison of bundled electricity-gas offers with mandatory price verification by the regulator.

The conceptual framework for the next generation of tools includes three principles—embedded layers of transparency (basic and additional information upon request); personalization through smart profiling and data on household assets; and the integration of behavioral forecasts using ranges rather than point estimates, along with clear indicators of forecast reliability, to avoid a false sense of precision in dynamic contracts.

The Role of NRAs and Implications for National Policy

The report highlights the central role of national regulators in three dimensions. First, systematic monitoring, including regular audits of comparison platform algorithms and “mystery shopping” exercises based on the Spanish CNMC model, also implemented in Portugal and Italy to assess the quality of pre-contractual information via telephone and online channels. Second, educational campaigns aimed at interpreting complex price signals, understanding the risk of price volatility, and the requirements for active behavior in dynamic contracts. Third, structured cross-border training and exchange of experience among regulators, as innovations often emerge in one Member State before spreading. CEER concludes that full harmonization is practically difficult, but common principles should be promoted, while their specific implementation remains within the competence of individual Member States. Particular attention is drawn to the regulatory vacuum surrounding intermediary platforms—most NRAs lack the authority to regulate them directly, which requires at least minimal monitoring, transparency requirements for financial models, and the introduction of official “trust marks” for certified tools.

The report Transparency and Comparability in the Retail Market is available here.