Energy Retail Code of Practice Review

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We welcome the opportunity to provide a submission to the Essential Services Commission’s (ESC) Energy Consumer Reforms Discussion Paper. We would like to commend the ESC for their work and endorse their outlined objectives.

As detailed throughout COTA Victoria’s submission, our overarching recommendation is to include a specific commitment toward achieving equity among diverse groups within the broader population of those disadvantaged or struggling to pay. This emphasis on equity could open the door more explicitly to complementary solutions that address various specific challenges, such as age, disability, language barriers, and digital exclusion.

In the last year, COTA Victoria has undertaken consultation and research projects12 to better understand the energy needs and concerns of older Victorians. Our consumer research highlights a range of issues that affect older Victorians’ ability to manage energy bill payments and inform our recommendations.

Drawing on this research, COTA Victoria identified four key trends relating to energy security and the transition to cleaner energy within the population of older Victorians.

These are as follows:

  • COTA Victoria found that utility bills represent the single largest category of expenses that older people struggle to pay, impacting 11% of the older Victorian population.
  • In addition to financial strain, there are significant trust-related concerns. Older Victorians frequently express suspicion regarding unsolicited outreach from energy retailers, often viewing such contact as confusing or overly promotional. In line with this, there is a strong preference for clear, factual information to support decision-making about utility plans, with many wanting straightforward, unbiased information rather than persuasive messaging.
  • Many older individuals harbor fears about potential risks associated with changing plans, such as the possibility of losing existing benefits or concessions. Although energy concessions and rebates are highly valued and can motivate change, older Victorians often feel reluctant to inquire about or request these discounts directly, even when eligible.
  • These findings underscore the importance of clear, accessible information and a respectful, fact-based approach to communication, which could better support older consumers in navigating their energy needs and options.

In reflection of these key trends, COTA Victoria proposes the recommendations and actions in line with the five areas of proposed reform.

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