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Reflect

On this page:

The Ombudsman's view

Catherine Wolthuizen

"The total number of cases at the end of the 2024 calendar year was 19,412, a 14% increase compared with 2023 (17,079)."

The start of the calendar year is an opportunity for EWOV to take stock of trends and look ahead. In this, we are helped enormously by conversations I have with many members through January and February where senior counterparts share their reflections on the past year, and what they are anticipating and planning.

With world events creating uncertainty in international markets and local communities facing ongoing cost of living challenges, it’s likely that energy policy settings and prices will remain in sharp focus this year.

Our casework through the 2024 calendar year shows the keen sensitivity among Victorian consumers and businesses to energy costs. While cases in Q2 FY25 were down compared with the same quarter in 2023, the total number of cases at the end of the 2024 calendar year was 19,412, a 14% increase compared with 2023 (17,079).

Billing complaints remain a strong driver of escalations, comprising 2,624 cases this quarter, as consumers query, and challenge, their bills and the quality of hardship relief provided by some providers. We see differentiation in the market in respect of the responsiveness of retailers to consumer hardship and encourage businesses to ensure their frontline customer support functions are trained and resourced to appropriately help customers in need.

Similarly, we see variance in the quality of Internal Dispute Resolution, with some members struggling to resolve matters at first instance or after referral back from EWOV. This is contributing to a sustained increase in investigations, with 745 cases progressing to investigation this quarter, reflecting a 58% increase compared with the same quarter last year (471).

Other scheme members have leaned into the challenges of this time, ensuring their staff are empowered to understand, resolve and learn from the complaints which their customers bring. We see enhanced awareness of EWOV as an important driver of this improvement, borne out in the complaint practices of businesses in Victoria and elsewhere who have already moved to include Ombudsman contact details on customer bills.

In the context of ongoing affordability challenges, EWOV has been engaging with the Essential Services Commission’s (ESC) review of the Energy Retail Code of Practice to help ensure Victoria’s energy rules are fit-for-purpose. In November, we made a substantial submission to this review, setting out recommendations for changes which we consider would support improvements to consumer outcomes across the energy retail market, including that EWOV should be required to be included on bills.

At the same time, we have been dealing with volume generated by issues at two members who have experienced disruptive events. We expect these to continue to generate escalations to EWOV and have been engaging with both members to encourage early resolution of these complaints by clearly setting out our expectations and dispute resolution approach.

The effect of these events can be seen in a sharp increase in backbill and billing delay complaints, and a higher volume of water cases.

We also observed the emergence of provision cases, related to an existing connection, as a top issue in Q2 FY25. Many of these cases involve issues consumers experience when seeking to abolish or disconnect gas. This is not generally a prominent cause of complaints. We’re also seeing more cases related to Consumer Energy Resources (CER) such as solar and batteries, where all or part of these cases may be outside EWOV’s jurisdiction.

These issues highlight the challenges consumers face when seeking to engage in a transitioning market, and the need for strong consumer protections - including external dispute resolution – to protect consumers from harm. Where consumers cannot quickly and easily seek a remedy for a problem, they may lose trust and confidence in the market, risking our progress towards Net Zero. EWOV continues to share our unique insights with policymakers to shape the design of a fit-for-purpose consumer protection framework for the renewable energy transition

This included a response to the Department of Energy, Environment and Climate Action (DEECA)’s CER Consumer Protections Review Directions paper. This submission supports the introduction of licensing and regulatory regime for CER providers, recommends a CER definition that covers the broad suite of current and future CER products and supports the introduction of a general consumer duty. In particular, we welcome DEECA’s proposal that EWOV provide external dispute resolution for all regulated CER activities.

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.

The big picture

  • We received 4,574 cases this quarter. This was slightly down from the same quarter last year (4,668) and down 26% from the previous quarter (6,159).
  • Despite this, the total volume of cases for the 2024 calendar year (19,412) was up 14% compared with the total number of cases in 2023 (17,079).
  • We observed an 85% increase in water cases (624) compared with the same quarter last year (337) and up 34% from the previous quarter (466). This increase is primarily driven by cases related to one water provider’s known billing system issues.
  • Electricity cases (2,160) were down 11% compared to the same period last year (2,432) and down 34% from the previous quarter (3,266), following a typical seasonal pattern.
  • Gas cases (1,737) followed a similar trend, down 7% compared with the same quarter last year (1,863) and down 26% from the previous quarter (2,359).
  • High bill complaints continue to be the top billing issue for the quarter (885). Cases were up 9% compared to the same quarter last year (812), and down compared to the previous quarter (1,410), following a typical seasonal uptick over the winter months.
  • Cases involving billing errors are also a top issue this quarter (420), a similar volume to the same quarter last year (414) and down 20% compared to the previous quarter (522).
  • We saw a significant increase in the number of cases relating to billing delays (138), up 53% compared to the same quarter last year (90). Similarly, we received 116 backbill cases this quarter, a 21% increase compared to the same quarter last year (96). Water cases are the biggest driver of these increases, comprising 85 billing delay cases and 46 backbill cases.
  • Credit issues continue to be a key concern for consumers, with payment difficulty cases the third highest issue this quarter (287). Cases involving collections (165) were up 19% compared to the same quarter last year (139) and slightly up from the previous quarter (154).

Cases can sometimes be amended, reopened and reallocated — for these reasons, there may be discrepancies between the previous quarter and the information presented in past editions of Reflect.

Quarterly trend over time

Issues watch

Billing system issues drive an increase in billing delays and backbills cases

We have observed an increase in some billing categories because of one water provider’s billing system issues. In the October-December quarter, we received 138 cases about billing delays, in which consumers were concerned that they had not received a bill from their provider. This was similar to the previous quarter (135), but a 53% increase compared with the same quarter last year (90). In many cases related to this water provider’s billing system issue, consumers were concerned in anticipation of high catch-up bills.*

Catch up bills, also called backbills, refer to bills for an amount owing from a previous period. This quarter, we received 116 cases about backbills. This was a 43% increase from the previous quarter (81) and a 21% increase from the same quarter last year (96). Almost 40% of these cases relate to the water provider billing system issue, reflecting general concern and confusion about the bill delay and backbilling arrangements. Many cases involved secondary concerns such as anticipating payment difficulty and confusion about how direct debit arrangements would be affected.  

EWOV continues to engage with this provider to ensure fair and reasonable outcomes for consumers affected by this billing system issue.


* Please note, as the majority of these cases are resolving at referral, analysis of these cases relies on facts reported to EWOV by consumers and the provider at referral stage rather than facts determined through investigations.

Consumers experience friction when seeking to adapt existing connections

Cases involving issues with connections was a top issue this quarter (Provision> existing connection: 266), a similar volume compared with the previous quarter (264) but up 18% compared to the same quarter last year (225). This category typically captures issues such as delays with upgrades to gas or electricity meters due to meter relocations, building works, or supply upgrades. Cases involving delays or issues with disconnecting existing supply for consumers moving house or demolishing properties are also typically captured in this category and made up the bulk of complaints this quarter.

However, EWOV is seeing more cases in this category that indicate consumers experiencing friction when actively engaging with the energy transition.

Some cases this quarter involved consumers experiencing issues abolishing or disconnecting their gas supply, following a decision to electrify their home. The most common issue was delays with abolishment. A small number of consumers reported that they believed their gas supply had been abolished, but then received a bill with supply charges. This may indicate consumer confusion about the differences between gas account closures, gas abolishment and disconnection.

We also observe consumers experiencing difficulties relating to the connection or configuration of their new solar and home batteries to receive a solar feed-in tariff. Examples of such cases include consumers reporting they had solar panels or a battery installed, but subsequently faced delays with their meter being configured. Other examples involved consumers having solar installed for years before realising their solar was not configured for export, which suggests difficulty understanding billing. In a couple of cases, consumers reported concern that they had received unexpectedly high bills after installing solar. Following their complaint to EWOV, they were informed that the relevant paperwork had not been submitted by their solar installer, so their meter was not appropriately configured.

More consumers are taking up new and emerging CER products, however many of the issues that arise for consumers – including installation or configuration - sit outside of EWOV’s jurisdiction. We continue to engage with policymakers about the need to ensure consumers can access free, fair and independent external dispute resolution (EDR) services when a consumer encounters a problem with their CER.

Consumer stories

Retailer fails to provide tailored assistance to consumer in significant payment difficulty

Marshall* contacted EWOV about a disconnection. Marshall told us he had received a disconnection notice in February and had contacted his retailer to try to resolve the issue. He asked his retailer to set up a payment plan to manage his outstanding arrears of almost $8,000. In response, the retailer suggested Marshall switch retailers, offering to waive part of the debt if he did so, which left Marshall feeling pressured and frustrated. With no payment difficulty assistance in place, Marshall was disconnected a few days later. At the time of contacting EWOV, Marshall was disconnected for approximately two months.

As part of our investigation, we learned that Marshall had an acquired brain injury and a serious back injury, which affected his ability to secure ongoing employment. He had previously been registered with the retailer as a life support customer, but the retailer had removed his details from its register. He also had reported to the retailer that his phone had been stolen and could only make contact with the retailer via a public phone and did not have a support person.

We considered whether the retailer had provided sufficient customer service and payment difficulty assistance that could have prevented the disconnection from occurring. After reviewing call recordings and contact notes, the retailer had identified Marshall as a vulnerable consumer. Despite this, the retailer failed to offer Marshall the assistance he was entitled to under the Energy Retail Code of Practice (the Code). When the retailer did offer Marshall assistance, it was conditional upon repayment amounts and timeframes unsuitable for Marshall’s circumstances and was therefore not compliant with the Code. We found that the retailer’s conduct caused Marshall significant distress, frustration and inconvenience due to delays, inadequate advice, procedural deficiencies and a lack of empathy and support in engagement. The disconnection and mishandling of Marshall’s life support status further exacerbated these issues.

Separately, EWOV also investigated whether the disconnection was wrongful and whether Marshall was entitled to a Wrongful Disconnection Payment (WDP). We found that the retailer did not follow the law when it disconnected the electricity, and a WDP was payable. The retailer agreed with our assessment, and since Marshall was off supply for over 61 days, he was entitled to a WDP of over $30,000, which the retailer subsequently paid.

We considered it was fair and reasonable for the retailer to provide over $3,500 in compensation for non-financial loss, reflecting the missed opportunities to provide assistance and to compensate for the harm caused to the consumer. We also considered it fair and reasonable that the retailer remove Marshall’s default listing and commit to ensuring compliance with all relevant requirements under the Code in future engagement with Marshall. Both Marshall and the retailer agreed with our assessment, and the case was closed.


* Names have been changed

Consumer frustrated that solar system has not delivered electricity bill savings

Oscar* contacted EWOV about an existing Photo Voltaic (PV) solar system, issues with solar export and unexpected costs. Oscar told us he had used a government rebate to install a 5kWh solar system on his property, hoping to save on electricity bills and benefit from export. He was dissatisfied with his distributer, who had told him that due to oversupply, he could not be connected to export to the grid in his area, but the distributor had approved the installation of the solar system. Oscar was advised by the retailer and solar installer that he could request a manual assessment to see if a connection could be made, which would cost $300 with no guarantee of connection. He sought an explanation from his distributor about why his system could not be configured for export immediately and when he could next apply for approval for solar export.

As part of our investigation, the distributor told us it is responsible for allowing customers to export excess solar unless network constraints exist. In Oscar’s case the installation was approved but the application for export was not approved pre-installation because the distributor’s substation was already at maximum capacity. The distributor advised that there was a tool the solar installer or the consumer could use on the distributor’s customer portal to monitor future changes in export capacity. It confirmed Oscar could request a manual assessment for $300, to thoroughly assesses all available information, including the proposed solar system and technical view of infrastructure and network. However, due to network capacity, it was unlikely to deliver the outcome Oscar was seeking. The distributor suggested that a 5kWh battery may be an alternative option for Oscar to gain additional benefits from his solar installation.

Although this was not the outcome Oscar was hoping for, he agreed there was nothing further EWOV could do, and the complaint was closed.


* Names have been changed

Engagement

This quarter, Ombudsman Catherine Wolthuizen conducted a range of activities to share insights from our Annual Report and raise awareness of EWOV so more Victorians can find us when they need help with their energy and water issues. This included an interview on ABC drive with Ali Moore in October, and briefings with DEECA, the Minister for Energy and Resources and the Minister for Water.

Assistant Ombudsman Wendy Guy also attended the Financial Counselling Victoria Conference, connecting with financial counsellors who play a critical role in supporting consumers in financial hardship with energy and water issues.

Catherine participated in a panel discussion “Are we giving enough priority to fairness and transparency in price formation?” at the Energy Retail Excellence Conference. Also on this panel were Lan Pham from ENGIE, Jo De Silva from Australian Energy Council and Andrew Lewis from the Australian Energy Market Commission.

The EWOV team took part in the Walk Against Family Violence, joining together in solidarity with survivors of family violence. The walk, from Birrarung Marr to Treasury Gardens, was attended by a wide range of organisations and individuals, including other industry organisations such as the Essential Services Commission, AGL, and ENGIE. EWOV also raised $2,894 for Safe. Everywhere. Always.

In December, EWOV launched our Reflect Reconciliation Action Plan (RAP). This is a significant milestone in our ongoing commitment to reconciliation and advancing relationships between Aboriginal and Torres Strait Islander peoples and the broader Australian community.

Submissions and reports

Our latest submissions:

Submission to Consumer Energy Resources Consumer Protections Review – Directions paper

We provided a submission to DEECA sharing case insights that illustrate how rapid expansion of CER products and services promises significant opportunities for emissions reduction, improved health outcomes and long-term consumer financial benefits, but also creates new risks for consumers. We outlined a range of recommendations to establish clear consumer protections, and EWOV’s potential role as a single point of dispute resolution services for CER consumers, helping to address the challenges of complexity, new technology and new providers, and supporting accountability across the consumer journey.

Read the submission


Submission to the Review of the Energy Retail Code of Practice

We provided a submission outlining EWOV’s position in relation to a suite of reforms to the Energy Retail Code of Practice. These reforms, proposed by the Energy and Climate Change Ministerial Council, aim to help households access cheaper energy deals, increase support for consumers experiencing payment difficulty and provide more protections for consumers. We expressed our broad support for improving the ability to switch to the best offer, including specific changes for consumers experiencing payment difficulty, extending protections for consumers on legacy contracts and increasing access to concessions. We also expressed strong support for the ESC’s proposal to include EWOV on bills, providing evidence indicating increased consumer awareness of external dispute resolution by including the relevant Energy and Water Ombudsman on bills in other jurisdictions.

Read the submission


Report on promoting the awareness of dispute resolution

We finalised a report stemming from a joint energy and water Ombudsman initiative to promote improvement in promoting dispute resolution. The initiative involved us partnering with the Energy and Water Ombudsman of New South Wales, Queensland and South Australia (together the EWO Schemes) to carry out a review of the IDR and EDR processes of a sample EWO Scheme members. The review found that whilst some members were adopting better practice standards, overall members were not adequately promoting their IDR and EDR processes and awareness of the EWO Schemes.

Read the report


Submission to the Victorian Energy Upgrades Strategic Review

We provided a public submission to the VEU strategic review, highlighting the current patchwork of pathways to dispute resolution for consumers experiencing an issue arising from a VEU installation, which consider may not be consistent with the policy objectives of the VEU program.

Read the submission


Submission to the Select Committee on Energy Planning and Regulation in Australia

We provided a submission to the Select Committee to consider how to ensure external dispute resolution services have appropriate jurisdiction to handle disputes arising from new CER products and services as part of a fit-for-purpose consumer protection framework.

Read the submission


Submission to the Real-time data for consumers rule change

We provided a submission to the AEMC supporting the introduction of real time data to improve provider accountability for new CER services such as Virtual Power Plants.

Read the submission


Joint submission on the electricity pricing for a consumer-driven future consultation

We provided a submission to the AEMC highlighting the importance of EDR for consumers navigating complex network tariff information. We suggested the AEMC consider consumers’ ability to engage in markets and cautioned any reduction in existing regulation to support innovation.

Read the submission

Glossary

Visit the Data Hub for a full glossary of terms.