Financial Counselling Victoria has made a short submission to the Essential Services Commission’s Getting to Fair: Advancing Equity consultation, strongly supporting the Commission’s continued focus on fairness in essential services regulation. Our feedback highlights the importance of maintaining a barriers‑based definition of consumer vulnerability, strengthening systemic equity responses, and improving transparency in how annual priorities are set and resourced. We emphasise the critical role of financial counsellors as frontline system‑intelligence and call for clearer commitments to co‑design, lived experience engagement, and measures that genuinely reflect consumer outcomes.