Submission to AER on Benefit Change Notice Guidelines Issues Paper

The AER’s Benefit Change Notice Guidelines will guide retailers in how they notify their customers when a benefit (such as a discount) in their retail offer changes.

While in general, PIAC supports measures which make engaging with retail offers easier for those customers who wish to become more engaged, they must not place the onus on consumers to become more engaged merely to receive a fair and reasonable energy retail offer. PIAC agrees with the AER that in order for it to be effective, the Guidelines must result in consumers being provided with better information, not just more information. 

PIAC argued that customers should be notified of any change in benefits, irrespective of whether it is beneficial or detrimental to the consumer – this may provide a useful prompt for consumers and it removes the subjectivity of what a retailer considers to be ‘beneficial’ or ‘detrimental’ to the customer.

The notice to customers must also include a clear and consistent comparison of the customer’s bill with and without the benefit, with the two values calculated for the same period and the same level of consumption. It must also highlight the values necessary to enter into the AER’s Energy Made Easy website, such as the billing period and energy usage, to help customers compare their current retail offer with alternatives.