Key Reporting Obligations for Australian Electricity Retailers under the ERA’s 2025 Performance Indicators Handbook

The Economic Regulation Authority (ERA) of Western Australia has recently published its updated “Performance Indicators and Definitions Handbook – For Electricity Retailers” (April 2025). This significant regulatory document establishes comprehensive reporting requirements for electricity retail licence holders operating within Western Australia. As legal practitioners specialising in energy regulation, we believe it is crucial for electricity retailers to understand these obligations thoroughly to ensure compliance with their licence conditions.

The handbook, which has undergone several modifications since its previous iteration, outlines the performance data that must be reported annually to the ERA. This article examines the key aspects of these reporting requirements, potential compliance challenges, and important deadlines that electricity retailers must observe.

Regulatory Context and Purpose

The ERA administers the licensing scheme under Part 2 of the Electricity Industry Act 2004. As part of this regulatory framework, electricity retail licences impose specific obligations regarding the type and format of information that must be provided to the ERA. These reporting requirements serve multiple purposes:

1. Monitoring trends in electricity retailer performance;
2. Identifying challenges facing energy consumers; and
3. Tracking broader changes in Western Australia’s electricity markets.

The data collected through this reporting process is subsequently published in the ERA’s annual performance report, which is accessed by various stakeholders including consumers, industry participants, and regulatory bodies.

Scope of Application

It is important to note that these reporting obligations apply to all electricity retail licence holders who must report annual performance data for both contestable and non-contestable customers. However, the handbook explicitly excludes those who self-supply electricity or on-sell it to someone who is not the end user from these reporting requirements.

Key Performance Indicators

The 2025 handbook requires licensees to report on 97 indicators across ten categories:

1. Customer numbers – Including contestable and non-contestable residential and business customers, and pre-payment meter customers
2. Billing and payment – Covering aspects such as billing timeframes, payment plans, and direct debit terminations
3. Disconnections for non-payment – Tracking disconnection events across various customer segments
4. Reconnections – Monitoring reconnection events, particularly within prescribed timeframes
5. Complaints – Recording complaints from residential and business customers across various categories
6. Compensation payments – Tracking payments made under clauses 94, 95, and 96 of the Code of Conduct
7. Call centre performance – Measuring responsiveness and service quality
8. Energy bill debt – Monitoring customer debt levels and payment plan performance
9. Hardship customers – Tracking participation in and outcomes from hardship programs
10. Vulnerable customers – Assessing support for customers experiencing family violence

It is worth noting that the ERA derives a further 44 indicators using the information provided by licensees, bringing the total number of performance metrics to 141.

Significant Changes in the 2025 Handbook

The 2025 handbook incorporates several changes designed to simplify the annual performance reporting process:

1. Removal of derived indicators from the datasheet to simplify the form
2. Clearer guidance on reporting conventions
3. Updated submission deadline to 31 August 2025

These modifications require particular attention from licensees who may have previously used automated processes or scripts to complete the datasheet, as these will need to be updated to reflect the new format.

Reporting Process and Deadlines

The reporting process involves three key steps:

Step 1: Enter Preliminary Information

Licensees must provide basic information including the reporting year, licence holder details, and contact information for the person responsible for the submission.

Step 2: Enter Information for the Reporting Year

Data must be entered into the ‘Data input’ column for each of the indicators, with careful attention paid to:

• Reporting units – Ensuring data is provided in the correct format (e.g., number of customers, number of incidents, dollars)
• Reporting basis – Understanding whether indicators are based on a point in time (e.g., 30 June) or cover the whole reporting year
• Customer vs incident basis – Recognising whether reporting should be on a number-of-customers basis or a number-of-incidents basis

Step 3: Submit Datasheet to the ERA

The completed datasheet must be submitted no later than 31 August 2025 to licensing@erawa.com.au. After the ERA has reviewed and approved the submission, licensees will be instructed to publish the datasheet on their website by a specific date.

Important Reporting Conventions

The handbook provides specific guidance on reporting conventions for different categories of indicators:

Disconnections for Non-payment

A disconnection event may count towards multiple disconnection indicators. For example, disconnecting a residential customer who was previously disconnected and receiving a concession will be recorded against multiple indicators.

Reconnections

Only reconnections that occurred at the same supply address and in the same account name as the disconnection should be included. Each reconnection event should be recorded separately, even if the same customer is reconnected multiple times during the reporting year.

Complaints

Each complaint should be recorded separately, and multiple complaints can be made per customer contact. This means that if a customer raises issues about both billing and transfer matters in the same communication, two separate complaints should be recorded.

Call Centre Performance

The handbook provides specific formulas for calculating metrics such as average duration before a call is answered. It also clarifies which calls should be excluded from the indicators, such as interactive voice response calls where the customer does not select an option to speak with an operator.

Hardship Customers and Vulnerable Customers

These indicators are measured on a per-customer basis rather than per incident. If a customer satisfies an indicator criterion multiple times during a reporting year, they should only be counted once.

Compliance Implications and Legal Considerations

Failure to comply with these reporting obligations could potentially constitute a breach of licence conditions, which may result in regulatory action by the ERA. From a legal perspective, electricity retailers should consider the following:

1. Data Collection Systems – Ensure that internal systems can accurately capture and report on all required indicators
2. Verification Processes – Implement robust verification processes to ensure the accuracy of reported data
3. Recordkeeping – Maintain comprehensive records to substantiate reported figures in case of regulatory inquiry
4. Significant Variations – Provide explanations for any data showing a variance of more than 10% from the previous year
5. Publication Requirements – Be prepared to publish the approved datasheet on the company website as directed by the ERA

Conclusion

The ERA’s 2025 Performance Indicators Handbook represents a significant regulatory obligation for electricity retailers operating in Western Australia. By understanding and effectively implementing these reporting requirements, retailers can not only ensure compliance with their licence conditions but also contribute to greater transparency and accountability in the electricity market.

For electricity retailers seeking to ensure full compliance with these reporting obligations, we recommend:

1. Thoroughly reviewing the updated handbook and identifying any changes from previous reporting requirements
2. Updating internal data collection and reporting systems to align with the new format
3. Ensuring that staff responsible for compliance reporting are fully trained on the requirements
4. Implementing a calendar reminder for the 31 August 2025 submission deadline
5. Seeking legal advice if clarification is needed on specific reporting obligations

The complete handbook can be accessed through the ERA website, and specific queries regarding reporting obligations can be directed to the ERA’s licensing team.

By maintaining diligent compliance with these reporting requirements, electricity retailers can avoid potential regulatory issues while contributing to the effective monitoring and development of Western Australia’s electricity market.