Through Resolution No. 22, Series of 2025, the Commission lowered the eligibility threshold for the Retail Competition and Open Access (RCOA) and Retail Aggregation Program (RAP) from 500 kilowatts (kW) to 100 kW of average monthly peak demand.
The resolution took effect on June 26, 2026. These two mechanisms — direct supplier choice and demand pooling — finally open the contestable electricity market to a much wider base of consumers.
Two doors, one threshold
RCOA allows qualifying end-users to bypass their local distribution utility and contract directly with a Retail Electricity Supplier (RES) of their choice.
Meanwhile, RAP enables smaller consumers—such as businesses within the same franchise area or even households—to combine their electricity demand into a Retail Aggregated Group (RAG), allowing them to collectively meet the eligibility threshold.
Previously, both programs required at least 500 kW, a threshold that only large industrial players could meet.
By lowering it to 100 kW for both programs simultaneously, the ERC has effectively unlocked the market from two directions: businesses that individually qualify can contract directly with an RES, while those that do not can aggregate their demand to become eligible.
Why this matters for consumers
The numbers are compelling. Industry estimates suggest this opens the market to new participants across Luzon, the Visayas, and Mindanao — mid-sized manufacturers, hospitals, hotels, commercial buildings, and even clusters of households.
These consumers gain access to something previously reserved for industrial giants: the ability to negotiate fixed-rate supply contracts, shop competitively, and shield themselves from the unpredictable swings of generation charges that have driven recent bill spikes.
This is competition doing what competition is supposed to do—pressuring suppliers to offer better prices and service, rather than leaving captive consumers at the mercy of a single distribution utility's pass-through cost.
The ERC got the sequencing right — mostly
To its credit, the Commission paired this policy with an eight-month transition period, giving distribution utilities and retail metering service providers time to install the Advanced Metering Infrastructure (AMI) needed to support new participants. That’s a lesson learned from past rollouts, where infrastructure lagged behind policy.
Still, this is not a frictionless win. Reaching 100 kW collectively under RAP requires coordination — finding partners, appointing an aggregation lead, and navigating registration with both the ERC and IEMOP.
Smaller players without an aggregator’s help may find the paperwork daunting. As IEMOP officials have noted, more participants in the contestable market also means more exposure to seasonal price volatility, which cuts both ways without careful contract terms.
Bottom line
This is a structural reform, not a symbolic one — it materially redraws who gets a seat at the competitive electricity table. The ERC deserves credit for finally treating RCOA and RAP as two complementary on-ramps to the same destination.
The next test is execution: whether distribution utilities install meters on schedule, whether aggregation support reaches consumers who need it, and whether the promised savings actually show up on bills after June 26.
A power industry expert with over 40 years in experience as chief executive officer in firms ranging from banking, power, and advisory services.
