Stronger rules for electricity and gas retailers

Recommendations

Strengthening family violence protections

• Strengthen ERCOP protections for victim-survivors of family violence, including the additional measures that are present under the National Energy Retail Rules.
• Align the ERCOP with national rules to prohibit retailers from requiring evidence of family violence.
• Mandate a base level of assistance in cases of family violence, including no disconnections for non-payment, debt waivers as the only realistic method to support financial recovery.
• Require additional protections on customer details in cases of family violence, as basic security questions usually refer to information a perpetrator might know.

Strengthening the Payment Difficulty Framework

• Require retailers to follow a mandatory check list when first contacting a customer in payment difficulty, including a best offer check, concessions eligibility check, and support completing a Utility Relief Grant form. These checks and supports should be a prerequisite to commencing a payment plan.
• Establish a maximum rate of energy arrears as part of the ERCOP rules.

Improving customer support staff training and culture

• Improve mandatory training requirements for retailer customer support staff.
• Training for customer support staff should be delivered by the community sector in partnership with the Energy and Water Ombudsman and the ESC.
• Introduce measures to mitigate the malicious unintended consequences of call centre culture.

Six-month debt holds – only appropriate in specific cases

• Six-month debt holds should only occur in situations where a pause will not compound financial hardship in the long term, for example in cases of small debts, when a customer can pay ongoing costs, and / or a customer is waiting for an URGs payment.
• A better approach is the greater use of debt waivers by retailers, especially in cases where customers are unable to pay for their ongoing usage.

Improving assistance and information on energy efficiency

• Retailers should be prohibited from providing irresponsible energy use reduction advice that endangers the health of customers in payment difficulty and restricted to giving energy efficiency upgrades referrals.
• Ideally, retailers should partner with community service organisations to provide energy efficiency advice, as the current standard of advice provided in-house is unsatisfactory.

Improving information and accessibility

• The accessibility of bills, websites, and staff communications with customers require significant improvement, especially when supporting customers from culturally and linguistically diverse backgrounds. The onus should be placed on retailers to ensure customers understand the information being provided, including through proactive language support services.
• Energy customers experiencing digital exclusion require additional support and alternative avenues of information and communication in the context of increasing digitisation of information and service provision.
• The ESC should hold off on modelling Victorian energy bills on the Better Bills regulation until the AER has had an opportunity to review their effectiveness.
• Contact details for EWOV should be mandated to be on bills.
• Mandate that best offers presented to customers on bills are fully available.

Supporting customers who want to disconnect from gas

• The Energy and Retail Code of Practice should be updated to better reflect and support increasing numbers of voluntary abolishments of residential gas connections.

Strengthening protections for embedded networks

• Align information requirements and customer protections for embedded network customers with general energy retail customers, with protections in cases of family violence as a priority.

Additional recommendations for improvements to the ERCOP

• Retailers should be required to offer proactive support for customers at risk of experiencing hardship based on changes in usage patterns and methods of payment, for example Buy Now Pay Later products.
• Examine the feasibility of automatic switching to best offer, and automatic applications of concessions as part of the ERCOP review process.
• In cost-benefit analyses, the benefits of new ERCOP requirements to consumers experiencing vulnerability must take precedence over corporate profits.
• Consultation for the next phase of the ERCOP review should emphasise diverse voices, reduce barriers to participation, and leave adequate time for responses.