The Consumer Action Law Centre (Consumer Action) welcomes the opportunity to comment on the payment difficulty framework amendments to the Compliance and Performance Reporting Guideline draft decision. The implementation of the payment difficulty framework in 2019 will signal a significant step forward towards making disconnection a last resort and improving outcomes for people facing payment difficulty in Victoria. It is important that the Essential Services Commission (ESC) and the public have access to information to monitor successes and gaps when the framework is put into practice.
We generally support the amendments to the guideline proposed in the draft decision as they appropriately reflect the significant changes from 2019. However, there are several areas where further information from retailers should be reported to improve insights into the framework’s operation. We also have a list of activities that we intend to actively observe under the new framework that are not included within the proposed guideline.
Our comments are detailed more fully below.
180619 SUB CALC Reporting Guidelines