Systemic Issues Report 2025

Under our Charter, relevant Acts, and an agreement with the Essential Services Commission (ESC), we are required to investigate and report on our scheme participants’ systemic issues.

Our systemic issue work is generally targeted at instances of regulatory non-compliance – that is, where we consider a business hasn’t done what it’s required to do. This work is critical for supporting positive consumer and market outcomes.

We achieve positive outcomes by identifying complaints that harm, or risk harming, multiple consumers, spotting trends to uncover systemic problems for service providers, and then reporting these issues back to the provider.

Our investigations uncover the root cause of the issue, and we encourage the providers to fix it – so it doesn’t happen again.

By reducing the likelihood of the issue occurring, we’re saving more consumers from experiencing the issue and reducing the likelihood of more complaints arising.

Our work also helps more consumers to receive redress, such as a refund or compensation, from their provider, where appropriate. This applies even if the consumers haven’t raised a complaint with us but have nonetheless been impacted by the systemic issue. In this report, we share insights and highlight case studies for some of the most common and impactful completed systemic issue investigations we’ve observed over 18 months, from July 2024 to December 2025.

We also share examples of providers that showcase better practice by going above the minimum standards to support consumers. We encourage all energy and water providers to use this report to assist in improving their practices, to better support positive consumer and market outcomes.

Together, we can raise industry standards.

Fifteen systemic issue investigations finalised that contributed to positive changes. The positive outcomes included:

• 10 providers improved business process, approach and/or policy
• 7 providers introduced better training for staff
• 7 providers made system enhancements
• 6 investigations influenced policy or regulatory action
• 5 providers gave customer redress.

Note: The combined numbers are greater than 15 because, in some cases, the investigation had multiple impacts, for example, a business made improvements to a policy and provided redress to impacted consumers.