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Catherine Wolthuizen

"Credit and billing complaints remained high in the January to March 2023 quarter."

Energy and water consumers can teach us valuable lessons about the important issues taking place in the community. While news headlines give us an indication of the broad changes, the voice of individual consumers helps us understand, in detail, how these changes are affecting people. It can also give us insight into the flow-on effects of many other factors which can exacerbate social and economic changes, and helps us to identify where good practices are working well and where improvements are needed.

Our data shows that cost-of-living issues remain of most concern to consumers. Credit and billing complaints remained high in the January to March 2023 quarter. Credit cases made up 14% of all cases in the quarter and Billing cases accounted for 49%. Combined, Credit and Billing cases comprised 63% of all cases. We also saw an increase in complaints about solar products and services, reflecting continued consumer-driven interest in renewable energy options to help manage their energy costs.

We watch our investigations closely to uncover any systemic issues that could affect a significant number of consumers in the state, cause or compound new consumer harms or affect some groups of people more than others. As part of this work, we’ve been looking into cases involving victim-survivors of family violence and their interactions with the energy and water markets, exploring common issues for these members of our community. Several years on from the introduction of family violence protections in energy and water, our latest analysis of our consumer insights has identified concerns about privacy and account security, access to payment assistance, credit activity, billing issues, and customer service. Find out more about this and other issues we’re keeping an eye on in the Issues Watch section of this report.

Read on for more detail in the latest edition of Reflect. As always, you can find more data relating to our casework in the Data Hub.

Issues watch

Increased energy prices in the context of broader global and cost-of-living pressures are leading to significant affordability issues for consumers. Cost pressures are being felt by mortgage holders which creates flow-on effects for people who rent. In this context, many of our cases in recent quarters have reflected consumers’ billing and payment difficulties, and indicate increasing consumer price sensitivity as they seek to juggle household and other expenses. Credit and billing-related complaints made up the majority of the top issue types in the January-March quarter. Billing cases made up 49% of all cases in the January-March quarter and Credit cases made up 14%, a combined total of 63% of all cases.

The current price sensitivities make it more important than ever that providers’ communication with consumers is clear and reliable. We have heard from consumers about experiences where scheduled price increases have been communicated in ways that do not accurately reflect the actual price increase, or in ways that are not as clear or accessible as they could be.

A range of important protections are in place in Victoria for energy and water consumers who are victim-survivors of family violence – implemented in 2018 for water and 2020 for energy. The protections mean energy and water providers have certain important responsibilities in the areas of account security, training, debt collection and other elements of their business to assist consumers affected by family violence. Alongside these protections, it is vitally important that consumers are protected by and benefit from safely designed systems, business practices and approaches when they interact with energy and water providers.

At EWOV, our ongoing analysis of our unique consumer insights has noted that there are important opportunities for energy and water providers to improve how some systems and practices support victim-survivors at this important time. To facilitate continuous improvement, we are monitoring further insights, engaging with providers and other market stewards to improve outcomes in a range of ways, including in:

  • Payment assistance: ensuring victim-survivors have access to financial and family violence supports they are entitled to, particularly when they are experiencing payment difficulty. Ensuring safely designed and delivered supports in this area can also improve outcomes overall and reduce the incidence and recurrence of debt accumulation and disconnection.
  • Customer service: ensuring system and service design, delivery and training supports victim-survivors to easily contact their provider, and ensuring there are no unreasonable barriers that prevent access to both provider and other supports.
  • Privacy and account security: particular care needs to be taken in the provider’s system and service design and delivery to ensure confidential and personal information is kept safe, and the systems for capturing and sharing information are safely designed.
  • Complaints case handling: providing professional and independent interpreting services for CALD consumers, utilising the No Wrong Door approach, increasing awareness of family violence rules and entitlements through training, and protecting against compassion fatigue.

By improving business practices, and safely designing and delivering systems, providers play an important role in ensuring consumers are protected and also benefit from both the spirit and the letter of Victoria’s important family violence protections.

Delays in consumers receiving bills and the issuing of backbills are causing concern for a number of consumers, who are already facing affordability constraints. There are important opportunities for providers to ensure IT system updates do not adversely affect billing calculations and related consumer communications.

We are aware of some instances where IT updates unintentionally affected billing practices and communications for approximately 9,000 consumers across a number of providers.

Implementing new billing systems is a complex task and one that providers must encounter as part of business to deliver overall improvements, however, the potential financial impact on consumers is high at times of economic instability. It is important to also consider the impact of related customer service issues that can arise when upgrades have unintended consequences. Our case data suggests that, when consumers are unable to reach their provider or reach a solution after a few attempts, they contact EWOV to file a complaint because they believe their issue is not being responded to.

Billing delays can also have impacts on consumers’ ability to track their usage and make adjustments to reduce usage, as well as consider if they are on their provider’s best offer. These issues can have financial impacts on the consumer and affect the competitiveness of the market.


We focus on community outreach and engagement to increase the accessibility and awareness of EWOV, to improve Victorians’ experiences of energy and water markets. Our outreach work helps to build relationships with organisations that work with Victorian energy and water consumers who may be at the greatest risk of experiencing financial and other vulnerabilities

In the first quarter of 2023, we attended ‘Bring Your Bills’ days in Glenroy, Flemington and Craigieburn. We spoke to local residents who were having difficulty with both interpreting their bills and affording them. Many consumers shared their experiences of struggling to communicate with their utility company because they were from culturally and linguistically diverse backgrounds. We explained their rights and responsibilities as Victorian consumers and helped by raising complaints where appropriate. We also reminded many residents of the interpreter service offered by EWOV.

In early March, we travelled to Morwell in regional Victoria. We attended an event specifically offered for Aboriginal women and their families, and provided valuable information about consumer rights and the assistance available under the Victorian Payment Difficulty Framework. We accepted several complaints at this event and listened to the lived experiences of the women in attendance. We highlighted the importance of maintaining communication with utility companies and encouraged consumers to discuss their concerns as they arise.

We continued to expand our reach by engaging with community groups and other service providers and we were pleased to share our knowledge and expertise with them. Cost-of-living pressures continued to be the main concern for our community partners and the Victorians they support.

Scheme participant data

In our Data Hub, you'll find the latest quarterly case data for all of EWOV's scheme participants.

Public submissions

Privacy Act Review Report consultation

We provided a combined comment on the Commonwealth Attorney-General’s Privacy Act Review Report, in conjunction with other state energy and water ombudsman schemes. We provided support for measures such as clarifying the purpose of the Act and modernising the Act, and emphasised the need to balance privacy rights with practical issues, including consumer expectations and evolving technology. We also emphasised the need for clarity and transparency in the proposed changes, particularly with regard to the proposed External Dispute Resolution (EDR) exception.

Read the submission

Unlocking CER benefits through flexible trading rule change - Consultation Paper

We provided a joint submission with other state energy and water ombudsman schemes on the Australian Energy Market Commission’s consultation paper on potential flexible trading arrangements for consumer energy resources (CER). We provided comments and case studies to support recommendations about the need for consumer protections, including dispute resolution, and other considerations when implementing CER.

Read the submission

Victorian Default Offer 2023-2024: Draft Decision Paper

We responded to the ESC’s draft decision paper about the Victorian Default Offer (VDO) for 2023-2024 for residential and small business consumers. We noted that a reasonable price through the VDO is key to ensuring consumers who are unable to engage with the market are not disadvantaged. We also called for other safeguards to be considered around awareness of how to resolve issues and facilitate the direct application of concessions, grants and other supports.

Read the submission


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