This submission responds to the Australian Energy Market Commission’s (AEMC) consultation paper on the Transfer Accuracy Rule Change Request submitted by the Council of Australian Governments (COAG) Energy Council. The proposed rule change seeks to address the causes of erroneous transfers and delays when customers are switching retailers in either the electricity and/or gas markets.
The proposed rule change arose out of the AEMC’s 2012 Power of Choice Review and subsequent Review of Electricity Customer Switching in 2014. The 2014 Review found that there was incorrect customer information in the retailer’s centralised Market Settlement and Transfers Solution (MSATS) system relating to a customer’s address or the National Meter Identifier (NMI). As a result, customers can be wrongly transferred or experience lengthy delays in the transfer process. In addition to these errors, there is uncertainty in the National Energy Retail Rules (NERL), the National Energy Law (NEL) and the National Gas Law (NGL) on the role of retailers in addressing these errors.
PIAC believes the rule change request is a positive step towards addressing these issues. Firstly, the rule change recommends that an address standard be implemented where retailers crosscheck the information in the MSATS system. Secondly, the rule change recommends defined retailer obligations in dealing with a transfer error so that customers do not bear the burden of rectifying the error. PIAC believes that clearly defined retailer roles will reduce customer confusion as to which retailer will amend the error.
PIAC supports the rule change request and believes that all customers should experience reliable transfer processes, which in turn will increase consumer confidence in the market. PIAC is also of the view that increased efficiencies in transfer processes will reduce retailer costs associated with dispute resolution and correction of administrative errors.
