Joint Submission: National Energy Retail Amendment (Improving the application of concessions to bills) Rule 2025: Draft Determination

PWDA joined organisations to respond to the AEMC’s Draft Determination on Improving the application of concessions to bills.

Thursday 14 August

The Justice and Equity Centre, Australian Council of Social Service, ACT Council of Social Service, Combined Pensioners and Superannuants Association, Ethnic Communities Council of NSW, Financial Counsellors Association of NSW, People with Disability Australia, Queensland Council of Social Service, South Australian Council of Social Service and St Vincent de Paul Society NSW welcomed the opportunity to respond to the AEMC’s Draft Determination on Improving the application of concessions to bills.

Our organisations represent the interests of energy consumers, households and communities across NEM jurisdictions. We specifically represent the interests of low-income households, pensioners and other households and communities experiencing disadvantage and affordability issues.

Energy services are essential. They are critical enablers of health, wellbeing and social and economic inclusion. Concessions and rebates are crucial contributors to more equitable consumer outcomes in energy services, improved energy affordability and the avoidance of energy payment difficulty, debt and disconnection. Ensuring rebates and concessions more consistently reach those who need and are eligible for them is an important and overdue reform.

Accordingly, our organisations broadly support the preferred rule changes and the draft recommendations. Our submission provides comment and recommended amendments to further strengthen consumer outcomes in application of concessions to bills.

Recommendations

• Recommendation 1 – Require retailers to ask consumers whether they may be eligible for rebates, concessions or relief schemes at the time of sign-up and minimum once every 12 months (encouraged to check more regularly).
• Recommendation 2 – Explore harmonisation of practical aspects of concessions and rebate schemes, in consultation with consumer and community stakeholders. Efforts to harmonise should ensure no loss of protection or benefit for eligible consumers, and should consider improving equity and adequacy of concessions.
• Recommendation 3 – Develop guidance and update the Better Bills Guideline and the Exempt Selling Guideline.
• Recommendation 4 – Establish a cross-agency forum to resolve:
  • Verification issues
  • Verification of renewed cards
  • Services Australia Explicit Informed Consent requirements
  • Flexibility for address changes
  • Ongoing verification for permanent concessions; and
  • Other administrative and process barriers to eligible consumers accessing their concessions and rebate entitlements.
• Recommendation 5 – Development of retailer systems capable of applying concessions or rebates to an account if anyone living in the home is eligible for a concession or rebate, not only the account holder. This may be best progressed through the cross-agency forum.

Organisations Supporting:

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