Energy Consumers Australia supports the proposed Rule 48A to increase customer awareness of changes in retail market contracts by requiring retailers to give customers notice of the end of benefit periods under those contracts. Given the difference between the best and worst deal in the retail market – a difference that can amount of many hundreds dollars – consumers can experience significant financial detriment if their discount expires without being properly notified by the retailer.

These additional requirements augment the current obligations retailers provide customers note at the end of a fixed term market retail contract under Rule 48.

We also welcome the decision to expedite the consideration of this rule change. After a ten-year period where the energy prices have doubled, consumers are now facing further, very significant price rises. At a time when there is an acute concern about energy affordability, it is critical that consumers have the information, tools and support they need.

In terms of form and process, we note that the notice from the retailer to the customer under proposed Rule 48A is either by letter or email and must be separate to the bill to the customer. Furthermore, it must clearly state that:

• The fixed benefit period is due to expire.
• The date on which the fixed benefit period will expire.
• The nature of the benefit in dollar terms.
• Loss of the benefit in dollar terms.
• That the customer may view all available offers through the Australian Energy Regulator’s price comparison website Energy Made Easy.
• Any termination charges that the customer would be required to pay if they terminated the contract.

This rule change is part of an important package of retail market reforms being driven by the Prime Minister, and through the Australian Competition and Consumer Commission (ACCC) Electricity Supply and Pricing Inquiry. At the heart of this work is the expectation that retailers take responsibility for their customers’ energy outcomes.

The full submission including full citations can be read here.