The Better Bills Guideline (Version 1) was published on 31 March 2022 and set out requirements for energy retailers to prepare and issue bills to small customers. However, potential drafting ambiguities and concerns were raised by industry stakeholders regarding the calculation and publication of the better offer message on a customer’s bill. In response, on 23 September 2023 the AER proposed amendments to the guideline in a draft Better Bills Guideline (Version 2), including clarifying the requirement for customer read estimates, aligning the better offer check and message requirements, and amending the commencement provisions following a rule change by the Australian Energy Market Commission (AEMC).
The Australian Energy Regulator (AER) received additional feedback from stakeholders and made minor amendments to the guideline, these changes including stakeholder feedback have been further explained below.
Effective Date of the Better Bills Guideline
The AEMC changed the implementation date for new billing provisions from 31 March 2023 to 30 September 2023. The Better Bills Guideline has been amended to reference the date specified in the Retail Rules for consistency. Stakeholders supported this clarification in line with the rule change, with Momentum expressing appreciation for the AER’s letter of support submitted to the AEMC.
Recommendations in the Better Bills Guideline – Version 2
During the consultation process, stakeholders proposed changes to the Better Bills Guideline, and the AER responded with amendments to the guideline. The proposed changes and the AER’s responses are as follows:
1. Recommendations regarding Tier 1 requirements
Better offer messages
Energy Locals raised concerns that customers on a virtual power plant plan may get an incorrect better offer calculation when comparing usage to non-VPP plans due to differences in usage profiles. The AER intends to work with Energy Locals to find a solution to this issue.
Including or excluding GST – Better offer ‘dollar amount’
The Guideline has been amended to state whether the dollar amount of the better offer check result is inclusive or exclusive of GST in a negative deemed better offer message. The AER considers this as an important clarification, as it will help customers understand the conditions of their negative deemed better offer message, ensuring they can better comprehend their potential savings by switching to a different plan with their retailer.
MIRN/DPI gas customer
Tango Energy requested clarification on the requirement to present a gas customer’s Meter Installation Registration Number (MIRN) and Delivery Point Identifier (DPI). An amendment has been made to the Better Bills Guideline (Version 2) to require the inclusion of the exact words “Meter Installation Registration Number (MIRN)” and “Delivery Point Identifier (DPI)” within Tier 1 information requirements.
Retailer identifying information
Tango Energy requested that the definition of “retailer identifying information” be expanded to include email or web addresses with chat functions. However, the AER clarified that the definition of “retailer identifying information” includes only a retailer’s trading name, logo, and website. The AER stated that a website can be used to direct customers to other digital communication channels but does not permit the inclusion of an email address in Tier 1 or Tier 2 information.
Tango Energy suggested including specific invoice numbers on bills for accounting purposes, which was accepted by the AER. A new amendment was made to the Guideline allowing for the inclusion of invoice numbers in Tier 1 information if applicable, subject to compliance with design principles. This amendment aims to assist small customers in paying and querying their bills.
The AER received feedback from several retailers, including Red and Lumo, AEC, AGL, Energy Australia, and Momentum, who suggested that displaying the final bill message in a non-prominent location on the bill could cause confusion and result in increased retailer inquiries. To address this, the AER has included a final bill message in Tier 1 information, using the exact words “final bill.”
It was also suggested that a ‘better offer message’should not be required when a customer finalises their account, so Section 58 has been amended to exclude final bills from the requirement to include a better offer message. This amendment aligns with the bill objective and ensures that small customers can easily understand their bill.
2. Recommendations regarding Tier 2 requirements
AGL requested an exemption for multisite collective billing customers from the plan summary requirement under the Better Bills Guideline, as the plan summary would not translate to such arrangements and increase costs associated with IT systems. AGL argued that the collective billing customer will often never see the bill, and retailers may manage these arrangements through dedicated teams. The AER maintained that the plan summary is an important tool for small customers but acknowledged that the exemption would avoid unnecessary expenditure for retailers and potential resulting costs for small customers. The Guideline has been amended to omit the requirement for a plan summary on a small customer’s bill where the customer receives a single bill in respect of the sale and supply of energy at two or more premises.
Plan change during billing period
Tango Energy requested clarification on whether a customer’s bill needs multiple plan summaries if they change plans during the billing period. The AER clarified that only the current plan at the time of the bill needs to be included to help customers understand and compare their plans. This is in line with the bill objective to help customers understand how their bills correspond to their retail contracts.
Billing period moved to Tier1 information
AGL suggested that customers may find it difficult to identify the billing period of a bill if it is not displayed on the first page. They suggested that the billing period and the number of days can be included in either Tier 1 or Tier 2 information.
However, the AER decided to maintain the billing period within Tier 2 information to support better consumer comprehension through logical grouping while retaining the simplicity of Tier 1 information.
3. Information permitted to be included in ‘Additional information’
Red and Lumo expressed concerns that the “Understand your bill” table may not accommodate multiple meter scenarios and suggested including meter numbers in Tier 2. Despite this, tests conducted by the Behavioural Economics Team of Australian Government (BETA) and the Behavioural Insights Team (BIT) revealed high comprehension levels without meter numbers on bills.
Consequently, the AER advises retailers to provide detailed meter information in separate sections following Tier 1 and Tier 2 information.
Next scheduled meter read date
Red and Lumo suggested including the estimated date of the next scheduled meter read as Tier 2 information in the Better Bills Guideline. The AER responded that the Tier 2 information should be intended to assist customers in understanding their energy usage, energy plan, and how their bill was calculated, and to help them compare their plan. As smart meters become more popular, informing customers of their scheduled meter reads will become less relevant, and therefore the estimated date of the next scheduled meter read remains additional information.
Jurisdictional scheme costs
Ausgrid suggested that jurisdictional scheme costs should be included in the ‘Understand your bill’ section within Tier 2. However, it is not a requirement of the Guideline to separately itemise jurisdictional Roadmap costs and other environmental schemes within the bill. Retailers may choose to provide a breakdown of how the amount due was calculated, including such costs.
Ausgrid network tariff codes
Ausgrid proposed that the best network tariff for a customer’s consumption profile should be included on their bills. However, the AER stated that while this information is potentially useful, it does not fulfill the purpose of the AEMC’s bill objective. Therefore, tariff information of this type can be included as additional information.
Smart meter information
Ausgrid suggested that bills should include details of the potential customer benefits of requesting a smart meter from a customer’s retailer. The AER agrees that providing information on the benefits of smart meters is important to consumers, but it does not assist a customer in understanding or paying their bills. The AER considers that information in respect of the benefits of smart
meters does not meet the bill objective as contemplated by the AEMC. Therefore, it is additional information that can be included in bills.
4. Further clarification
The AER provided clarification for the following points:
Customer self-read information: Retailers can include a statement on how to access self-read guidance and information rather than comprehensive guidance when making a bill.
Including export in the calculation of Better Offer: Expanded the definition of annual usage history to include a customer’s exports to ensure an accurate calculation of the better offer check.
Frequency of Better Offer: Requirement regarding the frequency of the better offer and exception for a better offer for final bill customers.
In summary, the Better Bills Guideline (Version 2) represents an important step toward improving transparency and fairness in the energy market. By providing customers with clearer and more detailed billing information, energy retailers can help their customers manage their energy costs more effectively. While there may be some initial costs and administrative burdens associated with implementing the new requirements, the benefits to customers far outweigh any costs to retailers.
Should you require assistance in reviewing your energy bills to ensure adherence to the Better Bills Guideline, our team of experts is available for consultation. Don’t hesitate to reach out to us for a comprehensive discussion on how we can help you achieve compliance and enhance your customer experience.