The ESC has released a draft Guidance Note on the Payment Difficulties Framework which will take effect in January 2019.

AGL has a history of designing evidence based solutions for customers facing payment difficulties and in our view, the current Guidance Note is likely to hinder innovation due to it's prescriptive nature. This is likely to result in retailers 'ticking the box' to ensure compliance, instead of ensuring the right outcome is achieved for each unique customer scenario. We recommend the ESC shift their focus in the Guidance Note, to highlight the outcomes they expect retailers to achieve, aligning these to the objectives of the Framework.

Please see our full submission here.