AGL has recently responded to the Australia Energy Regulator (AER) draft Better Bills Guideline consultation. The AER’s draft Better Bills Guideline (the Billing Guideline) sets out the proposed regulatory requirements that energy retailers must comply with when preparing and issuing bills to a small customer. The AER intends that the new billing regulations will simplify energy bills and make them easier to understand for consumers, strengthen the ability of consumers to make informed decisions, enable innovation and effective competition while reducing the costs to serve for retailers as a result of the simplified regulatory framework.(1) The AER’s reforms to the billing regime will fundamentally change the way that energy bills look for residential and small-to-medium business customers across the National Energy Customer Framework states, including New South Wales, Queensland and South Australia.

The new regulatory requirements under Clause 25A of the National Energy Retail Rules (NERR) will replace the existing ‘Bill and bill contents’ provisions under Clause 25(1) of the NERR, and will include:

• Five overarching design principles which must be applied when preparing bills;
• A ‘tiered’ approach to presenting billing information which categorises certain bill elements as either Tier 1, Tier 2 or Additional Information. The tiered approach will determine where different information can and cannot appear on the bill;
• A requirement to present ‘better offer’ information on the first page of the customer’s bill, similar to the Victorian regulatory ‘best offer’ obligations;
• A Standardised Plan Summary which must be presented in the form and using the format, order and terminology prescribed by the AER. The Standardised Plan Summary includes information such as percentage of energy generated by renewable sources, the benefit type and benefit change date under the customer’s contract.

While AGL supports principles-based regulation in order to achieve bill simplification, enable innovation and maximise strong consumer outcomes, a closer reading of the Billing Guideline reveals a highly prescriptive set of regulatory obligations which will adversely limit the retailer’s ability to innovate and present robust bill designs that meet the needs and preferences of consumers in a transforming energy market. AGL makes a number of recommendations to better balance the need for consumer protections with an approach that is compatible with industry innovation and that will continue to resonate with consumers over time. Read AGL’s full submission here.

Australian Energy Regulator, Notice of Draft Instrument – Draft AER Better Bills Guideline, version 1, December 2021, p 6.