Submission to Consumer Care Obligations Consultation 2024

Summary

• The Salvation Army Te Ope Whakaora welcomes this consultation on proposed Consumer Care Obligations and the decision to make current guidelines binding obligations on retailers.
• It is those on the lowest incomes who are most impacted by the service from electricity retailers. People struggling to get by on low incomes are in greatest need of this essential service and are often facing energy hardship. We believe the new obligations will support the Electricity Authority (EA) to enforce the requirements on retailers to meet their social license as set out in the EA legislation to “protect the interests of domestic consumer… in relation to supply of electricity to those consumers” (Electricity Industry Act, Section 15(2).  
• Enforcement of the obligations is crucial, and this must include meaningful financial penalties and proactive enforcement activity by the EA as well as responsive and easy to use complaints processes.
• The proposed Consumer Care Obligations we believe do not go far enough to genuinely protect consumers on low incomes and those in energy hardship. Other areas where action is needed include banning disconnection fees, requiring retailers to advise customers whether they are on the cheapest plan for their energy needs and ensuring prepay fees are fair and align with other retail pricing plans.