Following the National Insurance Brokers Association’s request in late February for further stakeholder input, Financial Counselling Victoria and the Financial Counsellors’ Association of Western Australia have provided a joint submission responding to the consultation on the Insurance Brokers Code of Practice review. In our letter dated Wednesday, 1 April 2026, we observed that the National Insurance Brokers Association’s initial response to the Independent Review did not address several recommendations aimed at strengthening transparency, accountability, and consumer protection, and we encouraged adoption of the full set of recommendations. The submission outlines priority areas for improvement, including clearer expectations for broker advice, more consistent disclosure of remuneration and conflicts of interest, and stronger support for clients experiencing vulnerability, including engagement with third-party authorities.

FCVic’s submission on the Regulatory Impact Statement for the proposed Gambling Regulations 2026 welcomes the consultation but argues the RIS prioritises regulatory continuity, administrative efficiency, and cost recovery over meaningful harm reduction, despite Victorian research estimating $14.1 billion in annual social and economic costs across financial, emotional and psychological, family, productivity, government, crime, non‑profit, and federal impacts. FCVic calls for significantly higher industry fees to fund prevention, early intervention, and support services, as well as a penalty framework that acts as a genuine deterrent rather than a cost of doing business; it withholds clause‑by‑clause commentary to avoid validating a status‑quo framework, and urges bold, evidence‑based reforms now rather than deferring change until 2036.

FCVic have submitted a detailed response to the Federal Parliamentary Inquiry into Small Business Insurance, outlining how current insurance market conditions are contributing to financial hardship among small businesses and sole traders. Drawing on the experiences of financial counsellors across Victoria, the submission highlights escalating premium volatility, increasing excess levels, declining availability of suitable products, and the growing number of businesses becoming effectively uninsurable. FCVic notes that these pressures are especially pronounced in regional communities and high‑risk industries, where limited competition and rising costs create inequitable and unsustainable outcomes.

The submission also raises concerns about opaque policy exclusions, the widespread risks of underinsurance, and the failure of many products, particularly business interruption and cyber insurance, to reflect contemporary business models. FCVic emphasises that delays and disputes in claims handling can cause severe financial stress, with some businesses unable to resume trading for extended periods. The role of insurance brokers is identified as an additional risk factor, with inconsistent advice contributing to both underinsurance and overinsurance, leading to significant financial consequences.

FCVic calls for stronger regulatory settings to ensure that insurance products are affordable, transparent, and fit for purpose. Key recommendations include making the General Insurance Code of Practice mandatory and enforceable, improving the clarity of policy terms, lifting product design standards, and strengthening accountability across the insurance and broking sectors. The submission underscores the urgent need for reform so that insurance once again serves as a reliable safety net that supports small business viability and community resilience.

This submission urges ACMA to prioritise stronger oversight of telco financial hardship practices, responsible selling, and rejection of the weakened Telecommunications Consumer Protections Code in favour of direct regulation. It also highlights the need to monitor compliance with the new Domestic, Family and Sexual Violence Standard and to strengthen action on gambling harms, including emerging “scambling” scams that mimic online gambling platforms.

Financial Counselling Victoria’s submission to the Parliamentary Inquiry into renewable and affordable energy for apartments highlights the urgent need for equitable access to renewable energy for renters, social and community housing residents, and low‑income households. Drawing on insights from financial counsellors working with people experiencing energy hardship, the submission outlines how high upfront costs, embedded network restrictions, and inconsistent planning requirements are leaving vulnerable households behind in Victoria’s energy transition. FCVic recommends reforms to enable retail choice, ensure new developments include fair access to shared renewable infrastructure, strengthen regulation around emerging products like plug‑in balcony solar, and explore models such as community batteries to improve affordability and access.

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.