Compliance Quarter’s Submission to the AER’s Review of the Compliance Procedures and Guidelines

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On 11 April 2024, Compliance Quarter put forward its submission on proposed changes to the AER Compliance Procedures and Guidelines.

The AER is reviewing its Compliance procedures and guidelines, which set out the manner and form in which energy businesses in jurisdictions that have adopted the National Energy Retail Law must submit compliance information and data to the AER.

We argue that there should be consideration of measures to incentivise early reporting of potential breaches. These may, for example, take the form of firm discounts to the maximum civil penalty that can result from non-compliance. Clearly, it is the obligation of entitles to comply and to report however as in other spheres, incentives make a difference and can influence behaviour. While changes would be required at the legislative level, we argue that if early reporting is the objective ‘firm discounts’ should be considered.

Read our submission below:

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