The Quantum State of Irish Energy Pricing
I'm writing about a structural problem in how the Irish energy market is regulated. Not a billing error. Not a dodgy salesman — though I got one of those too. A system that is designed, whether intentionally or through neglect, to make it nearly impossible for consumers to compare what they're actually paying.
This piece makes three observations and proposes three actions. The observations are mine. The actions should be the CRU's.
Last year a door-to-door salesman signed me up to Bord Gáis Energy. He asked to see my bill, compared my existing rate against his discounted rate, and showed me his was cheaper than everyone else. I signed up.
Here's what never occurred to me at the time: every provider offers discounts. He was comparing his discounted rate against competitors' base rates. His 20% off Bord Gáis looked cheaper than what everyone else was offering — but Energia were offering 37% off a lower base rate at the same time. It's an obvious trick once you see it. At the door, with a salesman doing the maths on your actual bill, it doesn't feel like a trick. It feels like a transparent, expert comparison. That's what makes it effective.
I've a high-usage household — 9,500 kWh of electricity annually (electric vehicle) and 16,000 kWh of gas. Based on a detailed spreadsheet of my actual consumption, I paid approximately €1,700 more over the past year than I would have under Energia's publicly available Smart plan. Most households won't lose €1,700, but the mechanism is the same for everyone. The scale just increases with usage. I would have saved over €500 with Electric Ireland’s flat rate.
This may have been a failure to do my homework. The salesman did the homework for me, with my numbers, at my front door. The system gave him no obligation to compare against the best available rate. Different base rates, different discount percentages, no standardised way to compare actual cost. He had access to every provider's rates. I didn't. The discount model is what makes this possible — and as long as it exists in its current form, it will keep happening.
Bord Gáis were simultaneously running different discount tiers on the exact same tariff. On the EV Smart Dual Fuel product, some new customers got 10% off gas and electric, some got 20% off. Others got 29% off gas. Same product. Same customer category. Same time period.
And it's not even a matter of online vs. door-to-door or broker vs. direct. The same rep can offer me 10% and my neighbour 20%. There's no published criteria, no transparency, no logic. It's literally luck.
Two households on the same street, with the same provider, on the same tariff, consuming the same gas from Gas Networks Ireland and the same electricity from the Single Electricity Market, paying materially different unit rates. The product arriving at every house on my street is physically identical. The only variable is the margin each provider takes, hidden behind a "discount" off a base rate that nobody actually pays.
Around 400,000 Irish households switch energy provider every year. This is usually trotted out as proof of a healthy, competitive market. I'd argue it proves the opposite: that the market requires constant vigilance and annual switching just to avoid being overcharged. That's not competition. That's a tax on attention.
But here's the deeper problem: there's no evidence that switching annually actually gets you the best deal. The discount model is so opaque that even an engaged consumer comparing offers can't be confident they've found the lowest rate. The system doesn't reward diligence — it rewards luck and persistence, and penalises everyone else.
That churn has real costs: sales teams, call centres, door-to-door commissions, switching administration. Those costs get baked into everyone's rates. The market has created a self-sustaining cycle where complexity drives switching, switching drives cost, and cost drives complexity. The consumer advice is "switch every year" — which is another way of saying "the market doesn't work, so you'll have to."
Ireland has already fixed this exact problem in another sector. The Central Bank banned price walking in insurance in 2022 — the practice of charging loyal customers more than new customers for the same product. Their own review confirmed it's working. The energy market has the same disease, arguably worse, because the differential pricing extends even to new customers on the same product.
Three actions:
1. Ban price walking in energy, in line with what the Central Bank did for insurance. No more charging different unit rates for the same product to customers in the same category — whether based on sales channel, negotiation, or luck.
2. Require all energy sales — door-to-door, phone, online — to quote the effective unit rate after discount, not a percentage off an opaque base rate. Let people compare like with like. I'm literally talking about buying the exact same electrons from two different retailers.
3. Require that any comparison made during a sale references the competitor's best publicly available discounted rate, not their base rate. If you're going to do the maths at my door, do it honestly.
The current framework doesn't just fail to prevent misleading sales — it actively enables them. The discount model gives salespeople the tools to perform a comparison that looks transparent but is structurally dishonest. If it isn't intentional, it's negligent. I don't know what's worse.
I'm happy to provide my actual consumption data, a detailed cost comparison, and screenshots showing simultaneous discount tiers on the same Bord Gáis tariff if any of this would be useful to a review. You know switcher.ie exists, so you know there's issues here.
I've done a bit of reading on this topic, so I've shared a curated selection of articles below which I feel are very helpful for anyone who needs to make a judgement on whether what I'm saying is right, or absolutely completely obviously right.