Regulating with consumer vulnerability in mind: Essential Services Commission’s draft strategy

Consumer Action welcomes the opportunity to comment on the Essential Services Commission’s (ESC) draft consumer access and equity strategy, Getting to fair: Breaking down barriers to essential services.

We commend the ESC for its work championing this strategy and we strongly support the intention behind it: to improve access to essential services for consumers experiencing vulnerability.

As noted in the introduction to the draft, this strategy is not something that has typically been employed by economic regulators in Australia. We believe this strategy sets an important precedent for other regulators to ensure that people are treated fairly and equitably in essential service markets.

We have made a number of suggestions where proposals contained in draft could be strengthened in order to improve outcomes for Victorians experiencing vulnerability. These include:

  • Expanding the definition of consumer vulnerability to explicitly name barriers, including market factors
  • Maximising the use of open and inclusive language in all communications, by all stakeholders
  • Expanding the barriers named in the draft to recognise the specific barriers facing First Nations people
  • Adding an initiative to address high levels of energy disconnections among First Nations people
  • Including more discussion around the need for a culture change among regulated businesses.

Our comments, including several recommendations to strengthen the draft, are detailed in our submission below.

Read the full submission (PDF).

210620 SUB – ESC vulnerability strategy
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