AGL recently responded to the Australian Energy Regulator’s (AER) issues paper that considered additional retailer requirements to include in their upcoming hardship guideline.

In October 2018, the Australian Energy Market Commission (AEMC) made a Rule to allow the AER to issue a Guideline on retailer hardships that contains action statements for the minimum requirements of the National Energy Retail Law (NERL). These action statements are to create greater consistency in the application of retailers’ hardship policy to improve consumer consistency in support across retailers. AGL supported the Rule and has provided feedback to the AER on the proposed action statements.

The AER’s issues paper sought feedback on what other matters stakeholders considered should be included in the Guideline (in addition to the action statements). We continue to see the role of the AER as providing guidance for the minimum requirements retailers must meet for hardship policies to be approved under the NERL, in line with the recent AEMC final rule change for strengthening protections for customers in hardship.

The content of the Issues Paper represents important elements for retailers to consider in developing and delivering their hardship programs to customers. However, including these matters within a mandatory guideline goes beyond the intent and scope of the Law. We instead encourage the AER to consider releasing guidance material for retailers to help improve practices and delivery, and to be guided by industry insights on better practice methods.

You can read our full submission here.