QCOSS made a couple of submissions to the National Energy Retail in 2018.
The first was in response to the National energy retail amendment (Preventing discounts on inflated energy rates) Rule 2018.
We welcome the recognition that retailer pricing practices that involve percentage discounting are causing confusion and poor outcomes for customers in the retail electricity market. Through our community engagement QCOSS can confirm from that current percentage discounting practice is especially detrimental for people who are on a discount market offer that was based on an inflated base price. These customers are struggling to pay their bills on time which means they will lose their discount, possibly incur a late payment fee and ultimately pay more. Our view is that percentage discounting practices are too complex and confusing and lead to unfair outcomes. We had a number of recommendations, which you can read in the full submission.
QCOSS also made a submission to the National energy retail amendment (Strengthening protections for customers in hardship).
Under the current hardship rules, the Australian Energy Regulator (AER) provides guidance to help retailers meet their hardship obligations under the National Energy Customer Framework (comprising the National Energy Retail Law, Regulations and Rules). This guidance is provided through the Hardship Guidelines. The current Hardship Guidelines provides guidance to retailers on the kind of information to include in their customer hardship policies, or to submit as supplementary information to the AER, when seeking approval of their customer hardship policy. The information in the Guidelines is meant to assist retailers to demonstrate that their policy satisfies all the minimum requirements and obligations specified in the Retail Law and Rules.
The hardship obligations are to:
• Implement an approved hardship policy that meets the minimum requirements.
• Report on performance against hardship program indicators.
The current guidelines lack clarity and certainty and this leads to ineffective hardship policies that provide inadequate consumer protections, inconsistent hardship practices, poor
outcomes for customers and are difficult to enforce. Reform is required to provide greater certainty for retailers, customers, their community advocates, and regulators through
improved guidance about what the minimum requirements mean in practice. Hardship policies should not be approved if they are inconsistent with the guidelines. Improved hardship guidelines would result in more effective hardship policies that provide strong consumer protections, consistent hardship practices, improved outcomes for customers and improved compliance and enforcement. We had a number of recommendations, which you can read in the full submission.