Energy Consumers Australia welcomes the opportunity to provide feedback to the Australian Energy Regulator’s (AER) Default Market Offer 2024-25 Issues Paper. In the context of continued cost-of-living pressures on households and small businesses, robust price protections are critical to ensuring consumers have access to an essential service at a fair and affordable price.

For this reason, we again highlight the need to ensure the DMO remains centred around the reason for its introduction: to protect consumers. We reiterate arguments made in our previous submissions (see here) that a retail margin of 10% for residential consumers and 15% for small businesses does not give adequate weight to the AER’s objective to protect consumers from unreasonable prices.

In addition to amendments within the scope of this review, we also draw attention to issues which are making the intended protections of the DMO apply to an increasingly small cohort of consumers. These issues include:

• Consumers on market offers are not protected by the price cap,
• The changing energy market is reducing the relevance of the reference price,
• Changing usage behaviour is complicating the determination of an annual usage amount,
• The objectives of the price cap and reference price differ when determining an annual price.

Read our full submission here.