Submission to the AER’s Retail Exempt Selling Guideline

PIAC made a submission to the Australian Energy Regulator’s (AER) Retail Exempt Selling Guideline (‘the Guideline’) review 2021-22. In this submission we highlight aspects of the Guideline we support and identify areas where further improvements are required, including in relation to:  

• Regulation of hot and chilled water and the need for consumer protections, transparent and regulated pricing, and access to ombudsmen services. 
   
• Payment difficulties and changes required to the Guideline and the exempt seller hardship policy template (the ‘hardship policy template’) to improve clarity and balance, align better with the National Energy Consumer Framework (NECF) and ensure they better reflect the changing understanding of payment difficulties and vulnerability. 
   
• Improving the factsheet on embedded networks to make it clearer and more balanced between the potential difficulties of accessing competition and the potential detriment faced by staying with the exempt seller. 
   
• The need to ensure residential consumers are not included in deemed exemption categories.