Reports and Submissions
Read the latest reports and submissions from FCVic on a range of topics significant to financial counsellors, consumer advocates and the wider community.
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Submission to Treasury on financial abuse perpetrated through coerced directorships
- Published: 23 December 2025
Financial Counselling Victoria has lodged a submission to the Australian Government Treasury consultation on combatting financial abuse through coerced directorships, endorsing the Economic Abuse Reference Group’s reform directions. The submission is supported by Financial Counselling Queensland and the Financial Counsellors’ Association of Western Australia.
Drawing on the experience of Victorian financial counsellors, the submission highlights how coerced appointments saddle victim‑survivors with complex corporate and tax liabilities and calls for survivor‑centred, practical reforms. These include a trauma‑informed administrative pathway at ASIC to remove non‑consenting or coerced directors, the option to resign directly to the regulator where coercion is established, a broader scope across business structures, and national funding for small‑business financial counselling casework to make reforms effective in practice and strengthen the integrity of corporate and tax systems.
Joint Submission to the Remaking of the Fines Regulations
- Published: 17 December 2025
The Infringements Working Group (IWG), a joint working group of the Federation of Community Legal Centres (Victoria), Victoria Legal Aid, and Financial Counselling Victoria, has urged the Department of Justice and Community Safety to prioritise fairness and hardship-informed practice in remaking the Fines Regulations 2025. The submission opposes increases to administrative fees and recommends a concessional fee‑waiver scheme for people on low incomes, alongside plain‑language fines correspondence that clearly explains all resolution pathways and includes visible referrals to legal and financial counselling services. It also urges additional funding for community legal centres, Victoria Legal Aid, and financial counsellors to manage the increased demand that will follow better referrals, noting the cost‑of‑living context and the risk that higher fees will entrench poverty rather than promote early engagement. Financial Counselling Victoria contributed statistics, and authored sections on hardship and vulnerability.
Beyond the core proposals, the submission recommends expanding the definition of homelessness to include people living in rooming houses or in severely crowded accommodation, increasing minimum debt thresholds for enforcement actions and protected income levels for social security recipients, and extending vehicle detainment and sale timeframes to 28 days to allow people time to seek advice. This submission was made via the Infringements Working Group, which includes 38 organisations named in the report.
Submission to the VGCCC’s EGM Application Improvement Project Consultation
- Published: 16 December 2025
FCVic has lodged a submission to the Victorian Gambling and Casino Control Commission (VGCCC) on its Electronic Gaming Machine (EGM) application improvement project, dated Tuesday, 16 December 2025. Drawing on the frontline expertise of financial counsellors who specialise in gambling harm, FCVic stresses that gambling harm is complex and intersects with financial stress, addiction, health outcomes, and community wellbeing. The submission underscores research indicating that harm increases with losses and that there is no safe level of EGM consumption, urging the VGCCC to reject applications that would increase community exposure to EGMs. FCVic recommends mandatory, early, and transparent consultation with local therapeutic and financial counsellors, with their full feedback captured in the economic and social impact report rather than summarised.
FCVic supports the use of truly independent experts and asks the VGCCC to scrutinise potential conflicts of interest, including incentives or rewards that may compromise independence. The submission calls for the application form to include clear questions on applicant suitability, disclosure of any disciplinary history, and evidence of remediation, while Practice Note 1 should allow refusal even where net community impact is neutral. Practice Note 2 should promote accessible public hearings and submissions, advertised through trusted local channels. FCVic recommends strengthening community surveys with local gambling harm statistics, reply‑paid mail options, promotion via community hubs, and a ban on incentives that could skew results. It further urges inclusion of local health and addiction data in impact reports and cautions against assuming the mandated 8.33% ‘Community Benefit Scheme’ contribution delivers genuine community benefit, noting evidence that much of it is internally retained by clubs.
Joint Submission Responding to Request for Comment Paper 2026-27 Victorian Default Offer
- Published: 15 December 2025
A VCOSS‑led coalition has responded to the Essential Services Commission’s Request for Comment on the Victorian Default Offer (VDO) 2026–27, reaffirming the VDO’s role as a crucial consumer safeguard, especially for people on standing offers and those in embedded networks. The submission supports exploring a regulated “free power period” tariff within the VDO to provide a benchmark for consumers, while emphasising that many households cannot practically shift usage to benefit from such products. Recommended protections include opt‑in only application, a better‑off price guarantee, an easy switch‑back option, ongoing access to a simple flat tariff, and bill comparisons based on actual consumption rather than assumed behaviour change.
Consumer advocates urge a holistic, cost‑of‑living lens in price‑setting, favouring lower estimates where ranges are presented, and call for removing Customer Acquisition and Retention Costs from the VDO price stack. This submission seeks clarity on any pass‑through of AEMO’s cybersecurity charge, and argues that the VDO alone cannot deliver true affordability, recommending complementary measures such as a targeted social tariff for low‑income households. Financial Counselling Victoria contributed to this VCOSS‑led submission, drawing on frontline insights into energy hardship. Signatories: Victorian Council of Social Service (VCOSS), Brotherhood of St. Laurence (BSL), Community Information and Support Victoria (CISVic), Consumer Action Law Centre (CALC), Council on the Ageing Victoria (COTA), Energy Consumers Australia (ECA), Financial Counselling Victoria (FCVic), Uniting Vic.Tas, and Westjustice.
Submission to ESC’s Water Price Review 2026
- Published: 12 December 2025
FCVic submitted feedback to the Essential Services Commission’s Water Price Review 2026, informed by the Essential Services Network of financial counsellors, welcoming water corporations’ engagement with vulnerability while urging fairness, accessibility and proportionality in pricing and hardship responses. FCVic notes utility bills are a top issue for National Debt Helpline callers and warns water pricing could compound household pressures. The submission calls for nuanced local hardship approaches in North East Water’s region given pockets of disadvantage, welcomes Melbourne Water’s average increase of less than 1 per cent with customer support measures, and supports contributions to the Financial Counselling Industry Fund, encouraging statewide commitments.
Joint Submission on Ministerial Guidelines for Councils relating to payment of Rates and Charges
- Published: 5 December 2025
A coalition of consumer advocates has provided a joint submission on the Draft Ministerial Guidelines for Councils relating to payment of rates and charges. The submission welcomes the draft’s intent to improve consistency and fairness across Victorian councils but calls for stronger, mandatory standards to ensure ratepayers experiencing hardship are treated with dignity and safety. Recommendations include clearer binding language, trauma-informed approaches to family violence and economic abuse, compulsory staff training, defined timeframes for policy updates and hardship assessments, and transparent public reporting of hardship-related metrics.
FCVic contributed expertise on several critical areas: privacy and personal security for victim-survivors of family violence, recommendations for clear and consistent timeframes for hardship processes, transparent public reporting requirements, and improvements to definitions and assessment processes for hardship applications. These contributions aim to ensure councils adopt practices that prioritise safety, fairness, and accessibility for vulnerable ratepayers.
The submission was authored by Westjustice, Mortgage Stress Victoria, Financial Counselling Victoria, Consumer Action Law Centre, and Thriving Communities Australia, with additional sign-on support from other organisations committed to improving hardship responses across Victoria.
