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Consumer Action Law Centre strongly supports the proposed reforms outlined by the Essential Services Commission (ESC) in the Regulatory Impact Statement (RIS). We consider that these reforms will provide significant relief to Victorian consumers experiencing payment difficulty, vulnerability and/or barriers to engaging with the complex energy market, both by addressing unfair prices for consumers stuck on legacy offers and protecting consumers from paying unnecessarily high prices for energy.

In this submission we provide insights from our frontline work assisting Victorians on the National Debt Helpline (NDH), to provide context regarding people’s experiences navigating energy affordability and growing debt. We also highlight issues regarding retailers’ current practices in engaging with Victorian consumers to highlight the risk that the proposed disconnection threshold is not high enough to protect consumers not yet receiving payment difficulty assistance from the risk of disconnection. Lastly, although outside of the scope of this process, we have included a section on further opportunities for structural reform that we believe will improve protections, reduce unreasonable prices and lower energy bills.

In support of this submission, we attach our submission to the Australian Energy Regulator’s (AER) draft decision of the minimum disconnection amount. We include this submission with the aim of supporting an integrated and complementary approach across jurisdictions, ensuring strong protections for all Australian energy consumers.

A summary of recommendations is available at Appendix A.

Read the full submission (PDF).