Financial Counselling Victoria has provided a submission to the Essential Services Commission as part of Stage 2 of the Energy Retail Code of Practice review. Grounded in the direct experiences of Victorian financial counsellors, it highlights how early, flexible, and compassionate retailer responses improve outcomes, and how rigid, fragmented systems can escalate harm.

The submission broadly supports the Commission’s proposed reforms and identifies priority areas where stronger protections are most needed. These include an overarching consumer duty requiring retailers to act fairly and in consumers’ interests, proactive hardship identification obligations, and strengthened family violence protections that reduce retraumatisation and address safety risks in contact, account security, and debt pathways.

It also calls for extending minimum protections to embedded network customers, ensuring any First Nations data collection is culturally safe and linked to real consumer benefits, clarifying that customers with closed accounts remain entitled to payment difficulty assistance, and improving outage communications while maintaining strict privacy safeguards. The submission acknowledges and is co-signed by Westjustice, the Economic Abuse Reference Group (EARG), and Community Information & Support Victoria (CISVic).