Consumer Action welcomes the opportunity to comment on the Department of Justice’s Regulatory Impact Statement (RIS) for the proposed Victorian Civil and Administrative Tribunal Fees Regulations.
In summary, we submit that:
- the RIS fails to give appropriate weighting to the impact of increased application fees on access to justice;
- insufficient analysis has been undertaken in relation to the other assessment criteria proposed by the RIS;
- the RIS has not considered the impact of large fee increases on competition and market outcomes;
- the RIS is unclear about the scope of the proposed fees for alternative dispute resolution;
- the RIS has not considered alternative fee models that might address concerns about access to justice; and
- improvements could be made to fee waiver processes.
Consumer Action’s primary recommendation is that Option 1 of the RIS (fees retained at existing levels) should be the approach adopted, and any new fees regulations should be based on that approach.
To read our submission in its entirety, click here: Victorian Civil and Administrative Tribunal Fees Regulations.