The Network has responded to the Australian Energy Regulator's Retail Guidelines Review which directly affects every aspect of First Nations energy experience—from billing and concessions, to hardship pathways, to protections for prepayment customers, to conditions for meaningful participation in the energy transition.

The Network recommends that the combined Retail Guidelines include:

1. A dedicated “First Nations and Equity” section - Setting out obligations regarding accessible communication, cultural safety, translator services, community engagement, and support pathways.
2. Inclusion of prepayment customers across all guideline elements - The current exclusion of prepayment customers is inequitable, inconsistent with the NEEF, and produces harmful outcomes.
3. Automatic concessions and rebates - Manual application processes are a structural barrier. The NEEF explicitly endorses auto-enrolment where friction exists.
4. Proactive hardship identification - Using hardship indicators such as payment patterns, missed bills, inactivity, or involuntary self-disconnection 
5. A Priority Services Register - To ensure identification and protection of customers with medical, cultural, technological or geographic vulnerabilities.
6. Mandatory data collection and reporting - Including First Nations status (self-identified), postcode-level analysis, and prepayment disconnection events.
7. Clearer, simpler, more culturally appropriate communication standards - Drawing on behavioural insights, First Nations languages, visual design and trusted communication channels such as ACCOs and community radio.

The Australian Energy Regulator cannot meet the national commitments from the First Nations Clean Energy Strategy unless its Retail Guidelines explicitly address First Nations inequity, prepayment customer protections, and culturally responsive communication.

Read our submission