Stronger rules for electricity and gas retailers

Submission on the Energy Retail Code of Practice Review

As regulator of the energy sector, the Essential Services Commission (ESC) has demonstrated a commitment to significantly improving outcomes for Victorian energy consumers experiencing vulnerability. Measures like the Payment Difficulty Framework (PDF) have raised the standard of assistance that consumers are entitled to and ensured that disconnections are only ever a measure of last resort. Recent processes to align protections in other jurisdictions with the Victorian PDF show that the ESC has been leading the way. But we can still do better.

Household energy is an essential service. You cannot live without it, even if you are unable to pay for continued use and will accrue significant debt. Despite this, several factors including market failure have been allowed to push energy prices sky-high over several years. Often even with tailored assistance under the PDF, customers end up accruing unmanageable amounts of debt.

Compounding this, retailers are often failing to deliver adequate assistance to customers. VCOSS is consistently told that there is deep inconsistency between retailers and amongst retailer customer support staff in terms of the quality of assistance, the knowledge of staff, and the treatment that customers in energy hardship receive.

Structural barriers such as digital exclusion and language are poorly addressed by retailers, exacerbating the impacts of energy hardship. For victim-survivors of family violence, retailers often place barriers in the way of financial recovery and even customer safety, for example, by referring energy debts to debt collection agencies.

In this context, VCOSS welcomes this timely review of the Energy Retail Code of Practice (ERCOP).

Our submission has been written with input and support from VCOSS member organisations in the community sector, and from other energy consumer advocates. Uniting Vic.Tas and Ethnic Communities’ Council of Victoria are signatories to this submission.



VCOSS is the peak body for Victoria’s social and community sector, and the state’s premier social advocacy body. We work towards a Victoria free from poverty and disadvantage, where every person and community experiences genuine wellbeing. Read more.

We welcome the opportunity to provide this input.

This work is authorised by VCOSS CEO Juanita Pope.


VCOSS acknowledges the Traditional Owners of Country, and we pay respect to Elders and Ancestors. Our business is conducted on sovereign, unceded Aboriginal land. The VCOSS offices are located on Wurundjeri Woiwurrung land in central Naarm.