The Romanian Energy Suppliers Association (AFEER) claims that although it appreciates ANRE’s initiative to review the regulatory framework applicable to supply, it asks the Authority to modify the new normative acts, according to a statement of the suppliers’ association.
“In order for the measures provided for in the two draft orders to be implemented efficiently and predictably, without generating dysfunctions or distortions in the market, AFEER has sent ANRE concrete proposals for modifying the normative acts.”
The supplier evaluation mechanism must reflect real performance, not the volume of complaints
One of the draft orders introduces a mechanism for evaluating the performance of electricity and natural gas suppliers, by publishing an index associated with a “traffic light” classification system (green, yellow, red), built on the basis of the way complaints made by end customers are resolved.
AFEER supports the objective of increasing transparency and comparability of suppliers’ performance and welcomes any instrument that contributes to better consumer information — a direction that the Association constantly supports, including through the campaign “An informed consumer is a protected consumer”, launched since 2015.
AFEER believes, however, that the methodology must be adjusted so that the public indicator correctly reflects the performance of suppliers. In its current form, the “End Customer Satisfaction Index” does not measure consumer satisfaction, but the supplier’s efficiency in handling complaints. For this reason, the Association proposes replacing the name with “Complaints Management Performance Indicator” (IPGR).
At the same time, AFEER proposes that the calculation of the indicator include only justified complaints attributable to the supplier, given that many complaints concern the activity of distribution or transport operators, consumption measurement or continuity of supply — aspects that are not the responsibility of the supplier. The Association proposes the same rule for complaints addressed directly to ANRE, so that only those resolved as well-founded and attributable to the supplier are taken into account.
The Association also draws attention to the structural differences between suppliers: companies with large portfolios of household customers are naturally exposed to a higher volume of complaints, unlike suppliers oriented towards non-household or industrial customers. Applying the same criteria to suppliers with different customer profiles may lead to irrelevant results and to the unjustified disadvantage of some categories of operators.
In addition, the Association proposes that, if deemed necessary, the new order enter into force on 1 January 2027, with a 12-month testing and calibration phase in which the indicator is communicated exclusively to suppliers, prior validation of the data used, a minimum period of 10 working days for observations and quarterly publication of the indicator.
“It is a good initiative by ANRE, which is in line with the direction constantly supported by AFEER regarding the development of a transparent and competitive market. However, the methodology must be adjusted so that the indicator correctly reflects the performance of suppliers. We also proposed the elimination of the classification based on color codes — such a representation can be perceived as a negative official recommendation, without always reflecting the real differences between suppliers,” said Laurențiu Urluescu, President of AFEER.
Automatic notification of consumption – a necessary objective, conditioned by the measurement infrastructure
The second draft order introduces the obligation for suppliers to automatically send notifications when a customer’s consumption reaches 80% of the consumption estimated by the consumption agreement.
AFEER appreciates ANRE’s objective of providing consumers with tools to help them manage their consumption and energy costs more efficiently. However, the association draws attention to the fact that, under current conditions, the obligation is not technically feasible, as suppliers do not have the information necessary to send such notifications in real time.
Currently, energy consumption is measured by meters managed by distribution operators, and, in the case of conventional meters, their reading is carried out, according to the regulations in force, at intervals of up to three months. Under these conditions, suppliers do not have the information necessary to identify the moment when a customer’s consumption reaches the monthly threshold of 80% of the consumption agreement.
The implementation of such a mechanism would require an extensive smart metering infrastructure and an automatic and continuous exchange of data between distribution operators and suppliers. Even under these conditions, the enforcement of the obligation would remain difficult, given the dynamics of the supply market, the possibility of changing supplier in a short period of time, as well as the frequent modification of consumer agreements.
The national calendar for the implementation of smart metering systems provides that, by the end of 2028, the degree of equipping with smart meters will vary between approximately 33% and 70% of consumption points, depending on the distribution operator — which is why the proposed obligation cannot be applied uniformly to all consumers.
AFEER reaffirms its commitment to contribute, through the expertise of its members, to the development of a modern, predictable and balanced regulatory framework, for the benefit of consumers and the proper functioning of the energy market.
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