The Confederation of Employers Concordia offers an alternative scheme to support vulnerable consumers, which includes a voucher for the purchase/replacement of energy-intensive appliances in the household, a voucher for improving the energy efficiency of a building, a tax credit for buildings included in certain energy efficiency grades, the possibility of escalating high bills during the year, special payment mechanisms for vulnerable consumers, such as the flattening of the consumption curve and access opportunities for vulnerable consumers with the possibility of granting discounts to ensure access to energy supply.

According to the Concordia document, the alternative support scheme should be governed by the following principles:

1. Energy poverty is purely a social problem, not a problem specific to the energy sector. The collection of funds necessary to support the Support Scheme must be fair to the industry in question, which requires an adequate level of solvency and economic benefit to be able to maintain a constant level of investment. Furthermore, the energy sector should not be the sole source of income to support the fund designated for the Vulnerable Consumer Support Scheme.

2. The achieved level of household income should be the main criterion for the right to receive financial support, as well as the criterion for achieved energy consumption, respectively, responsible energy consumption. Even if, in the context of the energy crisis, the share of costs in the energy bill has increased significantly for all household consumers, there is still a segment of the population for whom the price of energy is still acceptable. Similarly, end users with atypically high household consumption may be excluded from financial support.

3. There is a need to distinguish between the affordability of energy prices in the context of the energy crisis and the susceptibility to the phenomenon of energy poverty at different levels of vulnerability. Against this background, it is possible to consider a measure applicable to a wider range of consumers, with clearly defined acceptance criteria. One such measure, which does not interfere with existing energy contracts, is the reduction of VAT for a larger part of the population than vulnerable consumers, only during the manifestation of an energy crisis.

4. The support scheme should contain a combination of measures combining direct (subsidy type) and indirect financial support and aimed at increasing energy efficiency:

a) voucher for the purchase/replacement of energy-intensive appliances in the household;

b) a voucher given to improve the energy efficiency of the building;

c) preferential tax for buildings included in certain levels of energy efficiency.

5. Indirect financial support measures should not be neglected, as they are particularly useful for improving the impact of energy bills: a) the possibility of billing in stages during the year; b) special payment conditions for vulnerable consumers, such as leveling of the consumption curve; c) means of access for vulnerable consumers with the possibility of providing discounts to ensure access to energy supply.

6. Efforts to form vulnerable consumers are a joint responsibility between the relevant state apparatus, which assumes a coordinating role, and relevant subjects in the energy sector (suppliers, distributors, etc.). At the initial stage, the competent authorities could facilitate the formation of a preliminary list of vulnerable consumers for income reasons. Subsequently, distribution operators and suppliers, through access to a series of data1 useful for efforts to improve energy consumption, can contribute to the segmentation of the pool of vulnerable consumers based on consumption efficiency criteria.

7. Differentiating consumers from vulnerable takes time, but it is imperative that the approach to classifying end consumers in this category begins immediately. Delays in identifying vulnerable consumers will contribute to ineffective public policies to address energy poverty and even measures to strengthen the fiscal regime and taxation applied in the energy sector.

8. Introduction of the “gradual introduction – gradual termination” approach of subsidy-type measures aimed at improving household energy efficiency and/or restoring responsible energy behavior. It is necessary to support vulnerable consumers, including financially, so that they can get out of the situation of energy insecurity. However, the provision of direct financial support should be time-limited and dependent on progress in improving the energy efficiency of the household in which they live.

9. Establishing annual targets for two important targets: finalization of the list of vulnerable consumers (maximum 3 years) and annual targets for reducing the phenomenon of energy poverty, taking into account relevant sub-criteria for this at the national level, such as: average level of energy intensity per household, actual amount vulnerable consumers, etc.

10. Acquiring responsible energy behavior by launching large-scale information campaigns at the national level with the involvement of all relevant stakeholders (Ministry of Development, Public Works and Administration, Ministry of Energy, ANRE, local government bodies, employers’ associations, non-commercial organizations, suppliers, distributors ‘jutors, etc.).

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