What’s more important, the electricity or food? But to us, they are both important.

This is the decision that we make every day – everybody.

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

For many First Nations households who experience disproportionately high energy hardship, limited access to consumer energy resources (CER), and structural barriers to switching or reducing consumption, Rate of Return Instrument (RORI) decisions can have immediate and severe affordability consequences. 

The Australian Energy Regulator (AER) has an opportunity in this 2026 Rate of Return Instrument (RORI) review to acknowledge and respond to the lived experiences of First Nations consumers, to adopt a cautious and consumer-protective approach to rate-of-return settings, and to help ensure that the energy transition delivers fair and affordable outcomes for all. 

In 2024, all Australian Energy Ministers endorsed the First Nations Clean Energy Strategy as a priority action under the National Energy Transformation Partnership. The Strategy commits governments to ensure First Nations people are not left behind in the energy transition, to improve affordability and essential service access, and to reduce structural energy disadvantage. Given the Strategy’s ministerial endorsement and its explicit relevance to consumer outcomes, it should inform the AER’s interpretation of the long-term interests of consumers in this RORI review. 

The evidence is clear: First Nations households are more vulnerable to energy price increases, more exposed to network charges, and less able to mitigate costs through CER. For these reasons, the AER must adopt a cautious, equity-focused approach to rate of return settings. Past examples of network over-recovery — including the substantial uplift received by Ausgrid under the introduction of the trailing average cost of debt, and widespread over-recovery under earlier inflation methodologies — demonstrate how technical regulatory choices can have unintended but very real consequences for affordability. The AER should avoid repeating this pattern. 

The Network’s view is that the AER should apply a distributional lens to the RORI review, carefully assess affordability impacts on First Nations consumers, and recognise that strong First Nations engagement reduces risk and improves investment certainty. In which, we recognise that network businesses are highly responsive to financial incentives and that the RORI could be a lever for embedding better and more equitable outcomes for First Nations customers if reviewed and audited. However, the long-term interests of consumers, particularly those experiencing structural energy hardship, must be central to the AER’s decisions. 

Read our submission

Australian First Nations households and communities accessing electricity through prepayment arrangements experience extremely high levels of energy insecurity. In many cases, there is an absence of consumer protections, financial hardship assistance, or debt and disconnection relief. Until recently, these arrangements have largely avoided scrutiny.

While awareness of prepayment for electricity has improved, our research is the first national project to shine a spotlight on the previously hidden experiences of First Nations households using prepayment. The research incorporates household surveys and household-level energy use data to show that frequent disconnections are impacting food security, health, wellbeing and economic participation for First Nations prepayment customers.

Australia is entering a new era of energy-driven economic development, powered by the potential of lower cost renewables. The consent for access to First Nations’ extensive land and sea estates will be needed. It is incumbent on leaders and policymakers to recognise those same communities remain at risk of being left behind; underserved by policy and regulation to pursue opportunities that would secure their own energy futures.

To overcome these structural disadvantages Australian governments must be guided by existing frameworks, including the First Nations Clean Energy Strategy and Closing the Gap targets, and take action to ensure regulators and energy retailers work together to improve the experiences of First Nations people across all key reform areas.

There is considerable scope and opportunity for existing processes to include prepayment customers, and to bring regulation, reporting requirements and policy responses for prepayment customers in line with National Energy Market rules and regulatory standards.

Energy is an essential service that must be accessible by all, regardless of billing arrangements, location or income level. This can be achieved through the application of a nationally consistent consumer protection framework and guaranteed service levels for all customer groups.

The overarching goal of this research and associated proposals for prepayment reform is to keep First Nations people connected to power. This is consistent with wider recognition of energy as an essential service and that no- one should be disconnected due to inability to afford the energy they need.

Cite: Original Power and the prepay research team (2025) The Right to Power - Keeping First Nations communities on prepayment connected. Melbourne, Australia.

Read the report

Today, a series of recommendations on reforming prepayment metering is being presented to government, based on findings from a report led by Original Power and the First Nations Clean Energy Network.

Sixty-five thousand First Nations’ households across Australia access electricity through prepayment supply arrangements that mean they can experience disconnection rates as high as an average of 59 disconnections per year, a landmark new report shows.

The issue of prepayment for power is a really hidden part of the energy landscape in Australia. People are doing it really tough trying to stay connected to power.