Persistent inequities that prevent First Nations households—especially in remote and regional areas—from accessing safe, affordable and reliable energy must be corrected.

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 — is directly impacted by the Australian Energy Regulator’s (AER) Retail Guidelines Review and the consolidation of the Benefit Change Notice Guidelines, Better Bills Guideline, Customer Hardship Policy Guideline and Retail Pricing Information Guidelines. 

The Network strongly supports this review as a critical opportunity to align retail regulation with recent significant national reform, including the First Nations Clean Energy Strategy as a whole-of-government blueprint for achieving equitable First Nations participation and outcomes across the energy system; the National Energy Equity Framework (NEEF) which establishes a nationally consistent equity standard for all energy policies and programs; major reforms to customer protections under the Better Energy Customer Experiences (BECE) program; and growing evidence of energy inequities affecting First Nations peoples (as evidenced in the recent Original Power The Right to Power report). 

Overarching recommendations 

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. (see NEEF, “Accessibility barriers and friction”, p.12). 
4. Proactive hardship identification — Using hardship indicators such as payment patterns, missed bills, inactivity, or involuntary self-disconnection (recognised in NEEF as a valid hardship indicator; p.15). 
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 Aboriginal Community Controlled Organisations (ACCOs) and community radio. 

Read our submission

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