We support the Victorian Government's objective of placing small businesses at the centre of Victoria's energy regulatory framework and argue that the current approach no longer reflects how many businesses operate as energy use increases through electrification and business growth.
Our submission (PDF, 808.67KB) recommends increasing Victoria's small business electricity consumption threshold from 40 MWh to 160 MWh per year. We argue that many businesses remain small in terms of staff numbers, resources and bargaining power despite consuming more electricity because of energy-intensive operations or switching from gas to electric equipment. A higher threshold would allow more businesses to retain important protections, including access to the Victorian Default Offer and protections under the Energy Retail Code of Practice.
We also support voluntary multi-site aggregation for businesses operating across multiple locations, provided it is strictly opt-in and supported by strong consumer safeguards. Businesses should receive clear information about any consumer protections they may lose if aggregation moves them above the small customer threshold, with informed consent requirements, disclosure obligations and appropriate cooling-off arrangements.
The submission highlights evidence from Energy Consumers Australia's Small Business Energy Consumer Survey showing that rising energy costs continue to place significant pressure on small businesses and that many business owners have limited capacity to navigate complex energy market arrangements.
Our recommendations seek to ensure that regulatory settings continue to deliver affordability, fairness and consumer protections as Victoria's energy transition accelerates.
