Draft AER Customer Hardship Policy Guideline submission

Publication date:
1 March 2019
Resource type:
Submission

PIAC lodged a submission in response to the AER’s draft Customer Hardship Policy Guideline.

PIAC supports the development of a Customer Hardship Policy Guideline but regards the process and the draft guidelines as an interim step and that a more fundamental re-evaluation of the framework for supporting and assisting consumers is needed.

PIAC provides a range of recommendations on ways the AER could develop the Customer Hardship Policy Guideline so that it reflects retailers’ responsibilities and obligations to consumers. In particular, PIAC highlights early identification of customers experiencing payment difficulties, the broadening of training on hardship issues to cover all staff who deal with customers or their accounts, removal of gatekeeping language in retailers’ hardship policies, better communication of how to access retailers’ payment assistance programs, and the formal adoption of the sustainable payment plans framework and inclusion of it in retailers’ hardship policies as important steps to be included in the Policy Guideline.

PIAC also made recommendations regarding the wording of the standardised statements including discontinuing the use of the term ‘hardship’ or ‘hardship program’, and recommending that the AER more closely reflect the approach taken in the Victorian Essential Service Commission Payment Difficulty Framework.

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