Every Victorian relies on essential services. From having clean drinking water, to affordable lighting and heating, sustainable council rates, or accessing energy efficiency products, all Victorians use the services we oversee and are affected by our work.

We are developing a strategy to ensure consumer voices are reflected in our work. This getting to fair’ draft strategy will provide us with a consistent, long-term approach for addressing consumer vulnerability in Victoria’s essential services markets.

We released our draft strategy on 6 May 2021 and received submissions until 20 June 2021.

How this strategy could benefit you

The difficulties people experience can be long or short term. By working to minimise or remove barriers to access to essential services, all Victorians will have better access to support at the times they need it. By implementing this strategy, we hope to see an increase in consumer engagement with retailers and the market. A decrease over time in debt held by customers is also possible.

Our strategy: providing a definition of ‘vulnerability’ and addressing eight key themes

Our legislative framework refers to ‘vulnerable consumers’. Because of this, we need a clear working definition to outline what we mean by ‘vulnerable’. We developed the following definition:

A person experiencing vulnerability is someone who experiences barriers to participating in the essential services markets we regulate or administer. As a result of those barriers that person experiences economic and social exclusion or harm.

We repeatedly heard during our research and engagement phase that ‘vulnerable and ‘vulnerability’ are terms that people don’t like to use to describe themselves.

We are sensitive to this issue on language, so when we communicate, we will use language they have suggested such as resilience, wellbeing, equity, accessibility, inclusion, and fairness.

We heard there are different factors that prevent people participating in essential services markets. These can be caused by:

  • life events such as illness, job loss, financial stress, death of loved one, natural disaster, the global pandemic
  • language barriers, age, disability, regional limitations, digital literacy (what we call systemic factors)
  • documentation that is inadequate or too complex and targeted exploitation (what we call market-based factors).

We identified eight areas for us to focus on. These areas best reflect the experiences of consumers accessing our regulated markets and will be used to group our work to ensure we meet the needs of Victorians.

Our themes for this strategy are:

  • Theme one: Consumers are receiving inappropriate, inconsistent or inaccessible communications.
  • Theme two: Consumers are not engaged in a way that is universal or inclusive, leading to less accessible services.
  • Theme three: Consumers do not trust the market or feel empowered to make choices or seek support.
  • Theme four: Consumers who need support are not being identified and supported effectively.
  • Theme five: Support offered to consumers is inconsistent, which means it is often inappropriate or inflexible.
  • Theme six: First Nations consumers receive limited support and engagement and face increased rates of disconnection.
  • Theme seven: Government, industry and community organisations don’t coordinate effectively to address issues across the system.
  • Theme eight: Sudden, acute and unexpected challenges can have significant impact on consumers in the short, medium and long term.

Our research and engagement process formed the backbone of our strategy. It ensured that the work was representative of the Victorian market and community.

To gather feedback, we held:

  • seven community roundtables
  • ran a deliberative community panel with 37 Victorians that represented a cross-sector of our community
  • stakeholder reference group with representatives from mental health, disability, multicultural, financial counselling and consumer advocacy organisations
  • cross-industry workshops
  • webinar on universal and inclusive engagement.

Key research tools included:

  • interviews with community workers (conducted in partnership with the Consumer Policy Research Centre and Monash University)
  • data analysis from ACIL Allen
  • guidance paper on universal and inclusive engagement developed in partnership with the University of Melbourne’s Social Equity Institute.

We also used several external reports to help inform our research.

Have your say

We invite your feedback on the strategy but have created consultation questions to help frame feedback.

  • How well does our definition of vulnerability align with contemporary understandings of consumer vulnerability and its causes and impacts?
  • Given that ‘vulnerability’ is widely used and easily recognised by businesses, is the hybrid approach (where we are using our legislative language where needed, but more inclusive language in general) the best approach for the commission to take when communicating with stakeholders?
  • Do the themes, goals and initiatives we have identified and proposed provide an appropriate pathway for the commission to respond to the barriers currently being faced in the market?
  • Are there other considerations we should include in our strategy?

You can contribute in several ways. You can have your say on this page by:

  • providing general comments
  • uploading a submission document/s
  • attend our public forum on 11 May 2021 (a recording of the forum will be made available soon).

You may like to attend our sector workshops:

  • The energy workshop for the draft strategy on vulnerability was held on 15 June 2021.
  • The water workshop for the draft strategy on vulnerability was held on 24 May 2021.

Submissions closed on 20 June 2021.

General comments

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Collection notice

As part of making a submission, we need you to provide personal information, such as your name, email address, town of residence and postcode. We may use this information to send you updates about this review. We may also collect personal information when you contact us with a query. Aside from any exceptions in relevant privacy legislation, we will not use or disclose the information you provide for any purpose other than to progress and respond to your query. You have the right to access personal information we hold about you. We may ask you to pay a small fee for this. You can also request that we correct your personal information in our records at no charge by contacting communication@esc.vic.gov.au.

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Unless you tell us otherwise we will publish your submission the on the Essential Services Commission website. This process may involve publishing your personal information (your name, not your address). We generally do not accept anonymous submissions. If you have concerns about your identity being made public, please consider making your submission confidential rather than submitting it anonymously.

Requesting confidentiality

If you believe your submission contains information that should be confidential or commercially sensitive you must let us know why in writing. If we agree the information is confidential or commercially sensitive you will need to provide us two copies – one complete and one redacted version (preserving page numbers etc by not simply deleting information). If you make your submission public (e.g. by giving it to the media) we will assume confidentiality no longer applies and publish the unredacted version.

Read more information about our submissions policy.

About us

The Essential Services Commission is an independent regulator that promotes the long term interests of Victorian consumers with respect to the price, quality and reliability of essential services. We regulate Victoria’s energy, water and transport sectors, and administer the local government Fair Go Rates system.