Energy policy in Queensland and Victoria has been in our sights, with two new submissions responding to government inquiries posted this week.

The first, our 'Submission in response to Queensland Treasury’s review of the National Energy Retail Law (Queensland) Regulation 2014 - Discussion paper’ looks at reporting requirements around card-operated meters.

Used exclusively in over 5,000 households in 32 remote and isolated First Nations communities across Far North Queensland and the Torres Strait, with Ergon Energy as the licensed retailer, card-operated meters are a type of prepayment meter where households pay for electricity before using it. When credit runs out, a household self-disconnects—which can be during extreme heat. Without household power, food spoils, medicines can't be stored safely, and air conditioning stops—posing serious health risks.

Card-operated meters are defined separately from prepayment meters under Queensland law and have been excluded from public reporting requirements. This regulatory exception limits transparency regarding energy hardship experienced by First Nations households in card-operated metered communities.

The need for public retail performance reporting for card-operated meters was previously identified by the Australian Energy Regulator (AER) in 2023. Yet current regulatory arrangements prevent the AER from requiring card-operated meter data reporting by Ergon Energy, and limits the Queensland Competition Authority’s (QCA’s) public reporting powers in relation to card-operated meters, reducing data transparency specifically for First Nations households.

The absence of public reporting on card-operated meter retail performance data represents a departure from retail performance reporting standards which apply for the benefit of other Queensland households. It is also inconsistent with frameworks established under National Agreement Targets on Closing the Gap and the First Nations Clean Energy Strategy.

To address this regulatory gap, we suggest the Queensland Government considers amending the National Energy Retail Law (Queensland) Regulation 2014 to nominate the Australian Energy Regulator (AER) as the prescribed regulator with powers over retail performance reporting monitoring, investigating and enforcing for licensed entities providing card-operated meter services under Division 10A of the National Energy Retail Law (Queensland).

Our 'Submission to the Essential Services Commission on Energy Retail Code of Practice review’ addressed proposed changes to the Victoria' Energy Retail Code of Practice.

We find the proposed reforms represent a valuable opportunity to address energy inequality in Victoria—but that opportunity will be missed unless the specific needs of First Nations peoples are embedded at every stage. 

The Essential Services Commission (ESC) is proposing new rules requiring retailers to: 

• Review and adjust legacy plan prices annually. 
• Switch customers on legacy plans to cheaper options—without needing explicit consent—but with opt-out rights. 
• Ensure any conditional fees or discounts are fair and cost-reflective, even on older contracts. 

The proposed changes present important opportunities to improve energy outcomes for First Nations customers—particularly those experiencing financial hardship, digital exclusion, or energy insecurity. This includes culturally safe training for retailers, data collection to monitor outcomes for First Nations customers, and co-designed outreach and support services. In addition, these reforms present a unique opportunity to address the unique barriers faced by First Nations consumers—including language, literacy, trust in institutions, and access. 

While the review presents a vital opportunity to embed equity in the regulation of essential energy services, we urge the Commission to centre the voices and needs of First Nations people in this process. Doing so is not only consistent with the objectives of the Getting to fair strategy, but essential to a just energy transition for all Victorians. 

See all submissions

Thank you for use of the photo Markus Winkler on Unsplash