2022 CSA – RSP feedback on draft mark-up


In April we provided a customer update which confirmed we were narrowing the scope to essential regulatory changes and outlined our high-level indicative timeline to January 2022, when the proposed changes are intended to take effect. 

We believe it is important to continue our collaborative engagement with RSPs in finalising the changes for which we seek CIP’s formal approval. With that in mind, we also shared the draft mark-up of proposed changes for your review and feedback. 

The consultation period closed on 31 May. Over the past few weeks, we have had the opportunity to review and collate the feedback received.


Summary of RSP feedback

The feedback provided on the draft mark-up was mixed, with a range of views regarding the scope of changes proposed. We received questions and feedback on a range of topics including change, security, and the upcoming regulatory changes. You can find more details about the feedback we received on our dedicated webpage. 


The details

It is important to note that the scope of change we can make under the Required Change mechanic is limited to:

  • essential regulatory changes; and
  • updating existing legislation references to ensure we refer to the most up to date legislation.

Our immediate focus is on ensuring the 2022 CSA is fit for purpose under the new regulatory regime from 1 January 2022, however this will not be the last opportunity to review. We are open to a wider review once the Commerce Commission’s Retail Service Quality review is complete and a decision on approach finalised. 

While the security clauses are not proposed to change as part of this transition, we remain committed to the interim policy change. The timeline and details of this can be found here. We will manage this separately from the 2022 CSA transition, as the changes to security fall outside of scope for the Required Change mechanism.

Over the past month we’ve also undertaken a review of the supporting documents, including operations manuals and service descriptions. This is to ensure the changes made to the general terms are consistent throughout all documentation. A high-level summary of the proposed amendments is available to be viewed here.


Next steps

We are working towards finalising the mark-up for which we seek CIP’s formal approval. We will share the final version with you ahead of the formal request being submitted. 



If you have any queries, please contact us at