Overview

The Essential Services Commission is reviewing the way the energy payment difficulty framework has been implemented since it came into effect two years ago and invites you to contribute to this review.

We are commencing the review in September 2021. Between September and March 2022, we will use data and insights we have already collected and directly engage with community and industry stakeholders. We aim to better understand consumers’ experience of the framework and how it has been implemented by energy retailers. We also seek to better understand the challenges retailers have faced during implementation, as well as how consumers can be better supported to engage.

You will be able to engage with us through focused workshops, targeted one-on-one interviews and discussions, or by providing us with a submission on this Engage Victoria page. Our aim is to co-design solutions that can make implementation of the framework more effective over time, and we intend to work with our partners to design specific actions from 2022.

Submissions to our key review questions have now closed. If you wish to provide information to the review team, please email us at PDFreview@esc.vic.gov.au.

Key facts

The payment difficulty framework is a set of energy rules to better protect and support residential customers that are anticipating or facing payment difficulty. The framework was developed in 2017 in response to high numbers of residential customers being disconnected for non-payment.

The framework’s objectives are that:

  • customers are supported to pay their ongoing energy use, repay their arrears and lower their energy costs
  • customers are only disconnected for non-payment as a last resort and
  • customers avoid getting into arrears with their retailer.

We now have an increased awareness that the barriers to getting help are exacerbating the experience of vulnerability.

When we established the framework, we committed to review how it was working in practice two years after it came into effect.

We will evaluate and assess the operation of the framework in meeting its objectives. We will gather customer experiences directly, and information on whether the implementation of the framework has been effective. We will also draw on insights and data from the community, regulated businesses, and our partners across government to inform the review.

We will evaluate and assess the operation of the framework in meeting its objectives. We will do this by gathering and using customer insights, data and other supporting information for the to identify whether implementation of the framework has been effective.

Based on this assessment, and our findings, the review will also identify options for improving the operation of the framework such as:

  • working with interested stakeholders to design practical solutions to the issues raised in the review
  • developing guidance notes or industry education material to further support implementation of the payment difficulty framework.

We are not, at this stage, proposing major reforms to code obligations or to revisit the policy rationale behind the framework (which was substantively consulted on in 2017).

The review is focused on the implementation of the framework and will not consider reforms to associated government programs and policy.

We invited submissions on our proposed approach from 2 September to 19 September 2021. This initial period of engagement focused on the appropriateness of the scope and purpose of the review. We received eleven submissions from a variety of stakeholders including community representatives, energy retailers and energy consumers.

There was a general level of comfort across the submissions about the scope of the review and the appropriateness of our review questions. Many submissions emphasised the need to refer to both quantitative, as well as qualitative data, throughout this review and welcomed our proposed collaborative approach to stakeholder engagement. All submissions received can be found under the 'Review documents and submissions' tab of this web page.

We were also provided with a number suggestions of areas or issues for us to consider such as:

  • other sources of information to refer to
  • the application of the framework rather than the framework itself
  • addressing any issues or discrepancies in the current framework
  • the interaction between customer debt and customer engagement.

After considering this early feedback, and given the level of comfort expressed in submissions, we have not changed our proposed approach to the review or our key review questions.

Read our early observations

These observations come from our preliminary analysis of quantitative data submitted by retailers, and consumer insights from various case-studies, surveys and research. If you would like to provide comments or feedback on our early observations, please do so via the feedback form on this page.
Payment difficulty framework implementation review - early observations, November 2021
PDF (247.95 KB)
Payment difficulty framework implementation review - early observations, November 2021
MS Powerpoint (73.39 KB)

Our engagement so far

Our approach

We invited submissions on our proposed approach from 2 September to 19 September 2021. This initial period of engagement focused on the appropriateness of the scope and purpose of the review. We received eleven submissions from a variety of stakeholders including community representatives, energy retailers and energy consumers. After considering this early feedback, and given the level of comfort expressed in submissions, we have not changed our proposed approach to the review or our key review questions.

Our key review questions

Between 19 September and 30 November 2021, we invited your feedback on our key review questions. We are now analysing those submissions along with the data and insights we already have. The information from these submissions will inform our findings report, planned for release in March 2022.

  • How are the entitlements under the framework communicated to customers (from a single retailer, and across the sector)? From your experience, are the ways they are communicated clear and consistent?
  • How much do you think customers are aware of, or understand, their entitlements?
  • How helpful and practical has the payment difficulty assistance provided to customers been?
  • How confident are you when advocating on behalf of someone to access support under the framework?
  • Have you observed a change in customer satisfaction of their engagement with retailers about their entitlements? If so, to what extent and why?
  • Have you observed a change in customer engagement from diverse and hard-to-reach customers about their entitlements?
  • What aspects of the framework have been working well?
  • Have you, as a consumer representative, energy retailer, or other stakeholder, encountered any barriers or difficulties during the implementation of the framework?
  • Are there areas of the framework that you found confusing or unclear?
  • Are there other strategies or approaches retailers have considered (within or outside the framework) that can better help customers and achieve the framework’s objectives? If so, what are these strategies or approaches?
  • Are there other problems faced by energy customers that may not be covered by the payment difficulty framework?

Privacy 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.

We will publish your submission

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.