Review of payment difficulty protections in the National Energy Customer Framework

Overview

On 15 May 2025, we published the findings from our Review of payment difficulty protections in the National Energy Customer Framework.

Following on from the commitment we made in our Towards energy equity strategy, we considered whether there is a case for change to strengthen protections for customers experiencing payment difficulty to ensure that they are proactively identified, engaged early and supported appropriately with assistance that is tailored to their individual circumstances.

We explored the case for change by considering the effectiveness of current protections, the gaps, failures and unintended consequences of the current framework, and the effectiveness of other potential approaches (drawing on learnings from other frameworks, including the Victorian payment difficulty framework). After 18 months of extensive consultation with stakeholders on these questions, we concluded that the current protections for customers experiencing payment difficulty are not fit for purpose because:

• there is a persistent assistance gap that means some customers are missing out on help
• the quality of information about assistance is inconsistent and can often fail to meet customer needs 
• assistance provided under the framework is often ineffective, places inappropriate expectations on customers and is provided in an inconsistent way across retailers
• disconnection is relied on as an engagement tool, rather than a last resort.

We identified 13 opportunities to improve the framework by:

• making it easier to know who should be receiving assistance
• making it easier for customers to know what assistance is available
• making it easier for customers to access assistance
• making assistance more effective
• making sure disconnection is only used as a last resort
• reducing the harm caused by disconnection.

These opportunities could deliver better energy customer experiences into the future by:

• improving protections and outcomes for customers experiencing payment difficulty
• making customer experiences more consistent, supporting greater awareness and trust 
• simplifying regulatory compliance for retailers due to a simpler eligibility framework, clearer minimum standards and greater consistency across jurisdictions (including greater alignment between the NECF and the Victorian payment difficulty framework)
• reducing the burden of debt in the energy system by better ensuring retailers engage with customers experiencing payment difficulty proactively and effectively.

Background

The Review of payment difficulty protections in the National Energy Customer Framework fulfils action 8 in the AER’s Towards energy equity strategy, in which we committed to consult with stakeholders to consider whether improvements can be made to the NECF to ensure that consumers experiencing payment difficulty receive effective, tailored assistance.

This review has also progressed action 9 of the strategy (through workshops held in June 2024 that explored how to improve engagement to ensure disconnection is truly a last resort) and action 10 of the strategy (by consulting on the effectiveness of the minimum disconnection amount). 

Progress to date

• 14 May 2024: Our issues paper sought feedback on key issues identified through early consultation, preliminary analysis and consumer research.
• 19 June 2024: We held stakeholder workshops with energy businesses and consumer organisations, which explored how to improve engagement with customers experiencing payment difficulty to reduce the risk of debt and disconnection.
• 23 July 2024: We held a listening session with people from culturally and linguistically diverse communities, in collaboration with Voices for Power, Sydney Community Forum and the Afghan Fajar Association Incorporated in Campbelltown, NSW.
• 30 July 2024: We ran a stakeholder forum to provide interested stakeholders with an opportunity to hear the perspectives shared with the AER during our consultation on the issues paper.
• 13 May 2025: We wrote to Energy Ministers to share the findings and recommendations from our review.
• 15 May 2025: We published the outcomes from our review in a findings report and consultation report. We also published a draft decision on a new minimum disconnection amount, in line with opportunity 9 identified in the review’s findings report.