FCVic has made a submission to the Insurance Council of Australia’s consultation on the draft General Insurance Code of Practice. The submission draws directly on the experience of Victorian financial counsellors supporting people through insurance claims after major disaster events, including the January 2026 Victorian fires and the October 2022 floods, as well as those supporting victim-survivors of family violence and households in severe financial hardship. We warmly thank the members who shared their casework insights and feedback through the FCVic Disaster Recovery Network — their generosity has allowed us to coordinate a truly member-led submission, and the twenty recommendations put forward are grounded in their frontline expertise.

While FCVic supports the objective of modernising industry standards, the submission raises serious concerns that the draft Code weakens existing consumer protections in several places and does not adequately address the recommendations of the Independent Review or the Parliamentary Inquiry into insurers’ responses to the 2022 major floods claims. Key recommendations include replacing discretionary language with mandatory obligations, requiring insurers to use a customer’s nominated method of communication, mandating acceptance of a standard authority form, extending protections to eligible small businesses, inserting a dedicated section on temporary accommodation entitlements, and ensuring expert reports are provided to consumers without delay or unnecessary redaction. FCVic supports the recommendations made in the joint consumer submission led by Financial Rights Legal Centre, and the submission by Financial Counselling Australia on vulnerability.

This submission should be read in conjunction with our earlier work on insurance and natural disasters:

• Unsettled: Climate Risk and Cash Settlements in Home Insurance
• Submission to the Independent Review of the 2020 General Insurance Code of Practice
• Submission to the House Standing Committee on Economics Inquiry into Insurers’ Responses to 2022 Major Floods Claims
• Submission to AFCA’s Joint Consultation on General Insurance Approaches
• Submission to AFCA’s Consultation on Approach to General Insurance Claims Handling
• Submission to the Insurance Brokers Code of Practice Review
• Submission to Treasury’s Consultation on Standard Definitions and Standard Cover for Insurance

FCVic has made a submission to the Victorian Government’s consultation on the next State Disability Plan and Victorian Autism Plan 2027-2031. Grounded in the experiences of Victorian financial counsellors and financial capability workers, the submission argues that economic independence cannot be achieved through education and employment initiatives alone, and that financial wellbeing should be recognised as a core pillar of economic inclusion for people with disability. FCVic acknowledges the contributions of State Trustees Victoria and Carers Victoria to this submission.

The current Plan’s Midway Outcomes Report showed no significant improvement in economic security for people with disability, with fewer people able to access emergency funds and more going without meals because of a lack of money. FCVic calls for dedicated investment in accessible financial capability programs, specialist financial counselling, a qualified workforce, and greater support for independent financial decision-making. Drawing on research showing a return of between $4.20 and $5.90 for every $1 invested in financial counselling for people with disability, the submission also makes the case for prioritising capability building ahead of substitute decision-making, recognising carers as critical partners, and protecting access to physical cash as an essential money management tool.

FCVic’s submission to the Victorian Government’s Embedded Networks Review addresses reforms to pricing and consumer protections for customers in embedded electricity and gas networks. Grounded in the direct experience of Victorian financial counsellors, the submission highlights the systemic barriers faced by embedded network customers, including higher energy costs, reduced consumer protections, and an inability to access the competitive retail energy market.

The submission makes six recommendations, including benchmarking embedded network prices to the lowest available market offer, extending full Energy Retail Code of Practice (ERCOP) protections to all embedded network operators, mandating clearer disclosure for prospective residents, banning new residential embedded networks, developing a transition strategy for existing networks, and reviewing the Utility Relief Grant Scheme (URGS) and Non-Mains Utility Relief Grant Scheme (NURGS). The submission is endorsed by Community Information & Support Victoria (CISVic).

Financial Counselling Victoria, alongside national, state, and territory peak bodies, has made a joint submission to the Fair Work Commission in response to its 1 June 2026 decision on gender‑based undervaluation in the SCHADS Award.

The submission raises serious concerns about how the decision may affect the classification, pay, and recognition of financial counsellors. While the new framework includes mechanisms that could support translation of current Level 5 roles to higher classifications, it also creates uncertainty and a real risk that financial counselling work may be undervalued as entry‑level. The submission sets out the complex, specialist nature of financial counselling, including its legal, regulatory, advocacy, and counselling dimensions, and argues that this work warrants classification above minimum levels.

It also highlights the broader consequences for the sector, including workforce attraction and retention, funding pressures, and the long-term sustainability of services at a time of rising financial hardship. The peaks call for clear, evidence-based implementation of the classification framework, alignment with existing sector practice, and funding models that properly reflect the value of financial counselling work.

This joint submission responds to the Interim Report of the Independent Review of the Customer Owned Banking Code of Practice and reflects the experience of organisations working directly with people navigating hardship, vulnerability, and barriers to fair banking. It supports the overall direction of reform, including stronger drafting, improved hardship protections, better recognition of vulnerability, dedicated protections for people affected by domestic and family violence, stronger First Nations banking measures, and greater transparency around digital banking and AI.

At the same time, the submission argues that the final report should be more ambitious. It calls for the revised Code to seek ASIC approval, retain enforceable protections within the Code itself, strengthen oversight and consequences for non-compliance, require internal customer advocates across all lenders, improve access to in-person and non-digital banking, expand low-fee and no-fee banking protections, and ensure the compliance committee has the transparency and resourcing needed to do its job effectively.

This is a strong joint effort, backed by a wide range of consumer and community organisations:

• CARE.
• CHOICE.
• Consumer Action Law Centre.
• Consumer Credit Legal Service Western Australia.
• Consumers Federation of Australia.
• COTA Australia.
• Each.
• Financial Counselling Association WA.
• Financial Counselling Australia.
• Financial Counselling Victoria.
• Financial Rights Legal Centre.
• ICAN.
• Mob Strong Debt Help.
• Mortgage Stress Victoria.
• SAFCA.
• Thriving Communities Australia.
  

Financial Counselling Victoria’s submission to the Essential Services Commission’s Water Price Review 2026 draft decisions broadly supports the proposed approaches for Melbourne Water and North East Water, particularly efforts to balance infrastructure investment with cost containment for customers. The submission emphasises the importance of maintaining and strengthening hardship supports, including contributions to the Financial Counselling Industry Fund, and calls for consistent commitments across all Victorian water corporations to ensure equitable access to financial counselling services.