NSW Fair Trading Response to CHOICE Super Complaint on Electricity Switching Websites

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1 NSW Fair Trading Response to CHOICE Super Complaint on Electricity Switching Websites Monday, July 02, 2012 NSW Fair Trading NSW Department of Finance & Services

2 State of New South Wales, through NSW Fair Trading 2012 You may copy, distribute, download and otherwise freely deal with this information provided you attribute NSW Fair Trading as the owner. However, you must obtain permission from NSW Fair Trading if you wish to 1) modify, 2) charge others for access, 3) include in advertising or a product for sale, or 4) profit, from the information. Important: for full details, see NSW Fair Trading s copyright policy at or

3 CHOICE Super Complaint Electricity Switch websites Table of Contents 1 KEY FINDINGS INTRODUCTION BACKGROUND WHAT IS THE SUPER COMPLAINT? METHODOLOGY INDUSTRY REVIEW REGULATORS STAKEHOLDERS AND RESOURCES THE AUSTRALIAN COMPETITION AND CONSUMER COMMISSION (ACCC) AUSTRALIAN ENERGY REGULATOR (AER) INDEPENDENT PRICE AND REGULATORY TRIBUNAL (IPART) ENERGY AND WATER OMBUDSMAN NSW (EWON) AUSTRALIAN CONSUMER LAW PROVISIONS CONSUMER UTILITIES ADVOCACY CENTRE (CUAC) REPORT RESPONSE TO RECOMMENDATION INTRODUCTION WHAT IS THE PROBLEM THAT A MANDATORY OR VOLUNTARY CODE OR ACCREDITATION SYSTEM WOULD ADDRESS? IS A MANDATORY OR VOLUNTARY CODE OR ACCREDITATION SYSTEM NECESSARY? THE BENEFITS OF A VOLUNTARY CODE OVER A MANDATORY CODE INCLUDE: EVALUATION OF DATA A SUMMARY OF ADVICE FROM OTHER REGULATORS THE AUSTRALIAN ENERGY REGULATOR INDEPENDENT PRICING AND REGULATORY TRIBUNAL (IPART) ACCC FEDERAL COURT ACTION AGAINST ENERGY WATCH INTERNATIONAL EXPERIENCE THE REGULATORY FRAMEWORK FOR ENERGY SUPPLIERS AND RETAILERS IN AUSTRALIA CHOICE Super Complaint Report i

4 CHOICE Super Complaint Electricity Switch websites 4.11 EVIDENCE TO SUPPORT A MANDATORY CODE THE CREATION OF THE AUSTRALIAN ENERGY REGULATOR AND THE NATIONAL ENERGY CUSTOMER FRAMEWORK A VOLUNTARY CODE RESPONSE TO RECOMMENDATION INTRODUCTION CLAIMED SAVINGS VARIATIONS IN CLAIMED SAVINGS THE BEST DEAL SITE SPECIFIC REPRESENTATIONS EXAMPLE 1: WHAT IS A BEST PRICED RETAILER? EXAMPLE 2: ARE PROMISED SAVINGS AVAILABLE TO THE CONSUMER? EXAMPLE 3: IS SWITCHING AS EASY AND PROFITABLE AS THIS? EXAMPLE 4: WILL A DECISION MADE IN 5 MINUTES CREATE SAVINGS? EXAMPLE 5: SUGGESTING THAT PREDICTED SAVINGS HAVE BEEN ACHIEVED BY OTHER CONSUMERS OFFERS MAY NOT BE THE BEST OFFER THE BENEFITS TO CONSUMERS IN REGIONAL AREAS TERMS AND CONDITIONS DISPLAYED BY SWITCHING WEBSITES TRANSMISSION OF BILLS/INVOICES TO CONSUMERS PAYMENT BY INSTALMENT FAIR TRADING COMPLAINTS ANALYSIS EWON COMPLAINTS DATA ACCC V ENERGY WATCH FUTURE COMPLIANCE AND ENFORCEMENT ACTION RESPONSE TO RECOMMENDATION THE MIDATA PROJECT CHOICE Super Complaint Report ii

5 1 Key Findings The key findings in relation to the three recommendations contained in the CHOICE Super Complaint to NSW Fair Trading are summarised below: Voluntary or Compulsory Code or Accreditation System I. The need for a compulsory code or accreditation system has not been established. There is no available empirical evidence of significant consumer detriment arising from the use of electricity switching sites by consumers. II. The existing regulatory framework provided by the Australian Consumer Law has proved effective in addressing identified instances of misleading and/or deceptive conduct by energy switching and comparison sites. III. The commencement of the National Energy Customer Framework will introduce a range of consumer protection measures that address key issues identified in this Super Complaint. The Australian Energy Regulator, through the National Energy Retail Law and Rules, will prescribe the content, manner and form for information that energy retailers provide to consumers. The AER is developing an energy price comparator website for consumers Energy Made Easy. IV. A voluntary code, developed by industry may improve the quality and consistency of product information provided by electricity switching sites. Investigation into existing Energy Switching Sites V. Consumers are likely to achieve greater savings if transacting directly with the energy retailers than by using energy switching sites. VI. The predicted cost savings identified by energy switching sites vary widely for customers currently utilising standard energy contracts. VII. The comparison tools used by energy switching sites are not identical in methodology. A common metric should be developed. VIII. The variance and complexity of information related to energy offers in the marketplace is very likely to make it difficult for consumers to understand and compare plans. CHOICE Super Complaint Report 3

6 IX. Although onerous and in need of streamlining, the terms and conditions offered in documents presented through energy switching websites appear to comply with the unfair contract terms provisions of the Australian Consumer Law. X. Consumers in regional areas may not have the same range of choices or level of savings from energy switching website deals, relative to those choices and savings predicted for consumers in metropolitan areas. XI. Further consumer information and education programs are appropriate in order to improve consumer understanding of the market and their ability to make effective choices between plans. Industry has a responsibility to deliver this information and education. XII. A number of claims made by electricity switching websites require assessment to determine whether those specific representations breach the provisions of the Australian Consumer Law. Those representations include: o o o o advertising claims about cost savings, cheapest and/or best plans; claims about the impartiality of the website; the pool of energy retailers used; and undisclosed commissions received by operators of websites. Fair Trading will work with other ACL regulators throughout 2012/13 in relation to these concerns and will publish details of any compliance and enforcement outcomes on its website when completed. XIII. Assessment is also needed to determine whether compliance and enforcement operations are necessary in the direct marketing and door-to-door sales activities of energy retailers. Fair Trading will report on its assessment of this aspect of the industry by 31 December 2012 and publish its assessment on its website; Consideration of the Midata Project XIV. Fair Trading notes the intention of the Australian Government to initiate a scoping study for the establishment of an energy information hub. The information hub will be designed to assist consumers to better understand and manage their energy costs and consumption. CHOICE Super Complaint Report 4

7 2 Introduction 2.1 Background In June 2011, the New South Wales Minister for Fair Trading announced an 18 month pilot Super Complaints project between Fair Trading and consumer group CHOICE The Super Complaints system allows CHOICE to present evidence of issues that are, or appear to be significantly harming the interests of consumers in NSW to the attention of Fair Trading The role of Fair Trading was to test the supporting evidence in order to form a reasoned view on whether the Super Complaint justifies further action. Fair Trading was required to publish a response to a Super Complaint within 90 calendar days of receipt A memorandum of understanding between Fair Trading and CHOICE established the Super Complaints pilot program and set out the roles of the parties, the scope of and process for handling super complaints as well as possible responses to the issues raised On 8 March 2012, CHOICE submitted its first Super Complaint: Between a door-knock and cyber-space: the problems with electricity switching sites. 2.2 What is the Super Complaint? In their submission, CHOICE identified five key areas of concern: NSW consumers that visit only one commercial switching site may not find, contrary to their expectations, the best electricity deal available; Some of the switching sites are arguably making representations (directly or by omission) that lead consumers to incorrectly believe a user would find the best deal on their site (as opposed to a better deal ); In some instances, different switching sites recommend the same electricity plan but with different estimated levels of savings, which raises questions over the accuracy of the calculations used by some CHOICE Super Complaint Report 5

8 switching sites and/or the need to indicate that costs and savings are no more than predictions; Some of the commercial switching sites do not provide the user with all the relevant terms and conditions associated with electricity plans so that a user can make an informed decision before switching; and The characteristics of retail plans, including tariffs and relevant fees and charges, make it difficult for a user to compare plans effectively CHOICE also outlined three recommendations: The introduction of a voluntary or compulsory code of conduct or accreditation system; That Fair Trading investigate whether any of the commercial switching sites are engaged in misleading or deceptive conduct with regards to representations over best plans ; That a project similar to UK Midata project be pursued in Australia The full Super Complaint can be downloaded from Fair Trading s website; For the purposes of responding to this Super Complaint, switching sites refers only to those relating to electricity retailers In its submission, CHOICE has disclosed the following: That it currently operates the Compare, Ditch and Switch site located at choice.com. This site offers consumers facilities with which to compare financial services products such as credit cards and home loans. CHOICE does not receive any payments for this service; and That during the period August 2008 and March 2010, it operated the CHOICE Switch website which allowed consumers to compare gas and electricity providers by postcode. CHOICE compared all available providers and plans. Users of the site were able to switch providers with whom CHOICE had a commercial arrangement; This paper provides the Fair Trading response to the Super Complaint, specifically addressing the three recommendations made by CHOICE which relate to the areas of concern outlined above. CHOICE Super Complaint Report 6

9 2.3 Methodology In order to undertake the research and investigative tests required, Fair Trading used a methodology incorporating both quantitative and qualitative tools as outlined below: Undertaking an industry survey using calculation methodology adopted by CHOICE, but using a broader sample Reviewing of the Terms and Conditions published on the identified electricity switching websites; Coordinating with the Energy and Water Ombudsman NSW to exchange marketplace intelligence; Reviewing Fair Trading databases for complaints lodged against the identified switching websites; Researching relevant literature and activities published by other regulatory agencies in Australia and internationally. CHOICE Super Complaint Report 7

10 3 Industry Review 3.1 Regulators Stakeholders and Resources Roles and responsibilities of major industry regulators, stakeholders and recent publications on electricity switching websites and relevant sections of the Australian Consumer Law are discussed in detail below: 3.2 The Australian Competition and Consumer Commission (ACCC) The ACCC is an independent statutory authority that administers the Competition and Consumer Act 2010 and other legislation. The ACCC promotes competition and fair trade in the market place and also regulates national infrastructure industries. Its primary responsibility is to ensure that individuals and businesses comply with the Commonwealth's competition, fair trading and consumer protection laws The Australian Consumer Law (ACL) is a schedule to the Competition and Consumer Act and applies in all States and Territories, to all Australian businesses. The ACCC together with consumer protection agencies in the States and Territories such as Fair Trading, jointly enforce the ACL Central to the issues raised by CHOICE in this Super Complaint, are claims that some electricity switching sites are arguably misleading consumers through claims of offering the best deal on offer, inaccurate savings calculations and incomplete disclosure of relevant terms of conditions associated with electricity offers The ACL prohibits conduct by a business that is misleading or deceptive (sections 18 and 19). It is also unlawful for businesses to make false or misleading representations about goods or services in promotions or advertising (sections 29-38). 3.3 Australian Energy Regulator (AER) The AER is an independent statutory authority. The AER s staff, resources and facilities are provided by the ACCC. The key responsibilities of the AER include: CHOICE Super Complaint Report 8

11 regulation of the wholesale electricity market; economic regulation of the electricity transmission and distribution networks in the national electricity market; economic regulation of gas transmission and distribution networks; and enforcing the national gas law and national gas rules in all jurisdictions except Western Australia Under the National Energy Retail Law (Retail Law), the AER must develop an online price comparator website to become operational on 1 July 2012, when the Retail Law commences; The objective of the AER operated website will be to assist small energy customers to compare the electricity and gas offers available to them. 3.4 Independent Price and Regulatory Tribunal (IPART) IPART determines the maximum prices that can be charged for certain retail energy, water and transport services in New South Wales and the local government rates; IPART also monitors service delivery, audit suppliers and oversee licence compliance by certain water utilities and retail energy suppliers 1 : IPART also operates a My energy offers website designed for residential and small business energy consumers to compare offers from electricity and gas retailers. 3.5 Energy and Water Ombudsman NSW (EWON) The Energy & Water Ombudsman NSW (EWON) was founded in 1998 and is the government approved dispute resolution scheme for New South Wales electricity and gas customers, and some water customers 2 ; The type of complaints EWON can investigate includes: disputed accounts, high bills, debts, arrears; Energy & Water Ombudsman NSW, CHOICE Super Complaint Report 9

12 disconnection or restriction of supply; actions of a supplier that affect your property; quality and reliability of supply (including claims for compensation); connection or transfer issues; negotiated contracts; marketing practices; and poor customer service EWON was requested to share marketplace intelligence the organisation held on the industry given its broad mandate and contact with consumers and traders in the industry. The intelligence included complaints data which was analysed by Fair Trading. This analysis is presented in Section Australian Consumer Law Provisions CHOICE had asked Fair Trading to investigate whether any of the identified switching websites were engaged in misleading or deceptive conduct. Relevant provisions of the Australian Consumer Law (Schedule 2 of the Competition and Consumer Act 2010) dealing with misrepresentations, misleading or deceptive conduct are discussed below; Section 18 (1) of the Australian Consumer Law the deals with misleading or deceptive conduct and states: A person must not, in trade or commerce, engage in conduct that is misleading or deceptive or is likely to mislead or deceive Section 29 of the Australian Consumer Law deals with false or misleading representations about goods or services, stating: A person must not, in trade or commerce, in connection with the supply or possible supply of goods or services or in connection with the promotion by any means of the supply or use of goods or services make a false or misleading representation that goods or services have sponsorship, approval, performance characteristics, accessories, uses or benefits. CHOICE Super Complaint Report 10

13 3.6.5 Section 34 of the Australian Consumer Law deals with misleading conduct as to the nature etc. of services and states: A person must not, in trade or commerce, engage in conduct that is liable to mislead the public as to the nature, the characteristics, the suitability for their purpose or the quantity of any services Other relevant sections of the Australian Consumer Law include: Section 151(1)(a) - False or misleading representations about goods or services; and Section 156(1) Misleading conduct as to the nature etc of services. 3.7 Consumer Utilities Advocacy Centre (CUAC) Report Consumer Utilities Advocacy Centre is a Victoria based consumer organisation established in 2002 to represent Victorian energy and water consumers in policy and regulatory processes 3 ; The CUAC report was released in December The report is relevant to Fair Trading s current work on electricity switching websites. The report however, has much broader terms of reference and makes recommendation on issues outside of the scope of Fair Trading Super Complaint Report, including: Door to door sales by retailers; and Telephone marketing by retailers; Findings and recommendations of the CUAC report which are supported by Fair Trading s work in relation to the Super Complaint on electricity switching sites include: Consumers may find information related to energy offers in the market place difficult to understand and compare; There is a high potential for poorly informed consumer decision making and market participation. This leads to an increased probability of 3 Consumer Utilities Advocacy Centre, Improving Energy Market Competition through Consumer Participation, December 2011, p. 4 CHOICE Super Complaint Report 11

14 decisions being made with a limited understanding of what is being agreed to; There are significant problems with the quality of information available to consumers; Work should occur with retailers to achieve a more meaningful approach to expressing offers in language which can be easily understood; Work should occur in developing a common metric for offer comparison so that all offers can be easily compared against a benchmarked consumption level; and further consumer information and education campaigns are necessary and appropriate. CHOICE Super Complaint Report 12

15 4 Response to Recommendation Introduction In recent years there has been a steady increase in the number of businesses offering either an online comparison or an online switching service for consumers in sectors such as banking and retail energy. Sites offering a price comparison service to consumers generally package what they claim to be the best prices and provide this information directly to consumers. Switching sites will compare the different prices or rates offered by retailers and offer the consumer the option of moving or switching their business to another provider; The emergence of these sites has in part been a response to Governments opening up segments of the energy market to competition, such as electricity retailing. Businesses offering these services have tapped into a desire by consumers to get a better deal on what are for the most part, essential household purchases; Apart from the cost savings to consumers from switching to a more cost competitive provider, these sites offer consumers fast access to synthesised market information that may otherwise prove difficult and time consuming to collect; It can be argued that the existence and growth of these sites have contributed in some way to enhancing competition in the marketplace through the provision of information to consumers on price and other factors that influence consumer choice; NSW Fair Trading s examination of the issues raised in this Super Complaint, has confirmed the importance of consumers having access to the critical information that influences the decision to switch electricity retailers choice. Further, there is a need to ensure that switching sites appropriately disclose the methods of and any limits to the comparisons of retailer contracts they conduct, including key conditions which must be met by the consumer to receive any discount that is part of a contract; CHOICE Super Complaint Report 13

16 4.1.6 As part of this Super Complaint, CHOICE has recommended that a voluntary or compulsory code or accreditation system for commercial switching sites be introduced. 4.2 What is the problem that a mandatory or voluntary code or accreditation system would address? In its Super Complaint, CHOICE makes the point that to make an informed decision on whether to switch electricity retailers, consumers must be in a position where all relevant factors, terms and conditions are available to be reasonably considered, and that the estimated savings and costs as calculated by the site, are accurate and verifiable. The specific areas of concern are that: NSW consumers that visit only one commercial switching site may not find, contrary to their reasonable expectations, the best electricity deal available; Some of the switching sites are arguably making representations (directly or by omission) that lead consumers to incorrectly believe a user would find the best deal on their site; In some instances, different switching sites recommend the same electricity plan but with different estimated levels of savings, which raises questions over the accuracy of the calculations used by some sites; Some of the commercial switching sites do not provide the user with all the relevant terms and conditions associated with electricity plans so that a user can make an informed decision before switching; and The characteristics of retail plans, including tariffs and relevant fees and charges, make it difficult for a user to compare plans effectively At the heart of the claims made by CHOICE are: Do these sites disclose all relevant terms, conditions and offers that are relevant to the contract and the decision to switch providers; Do these sites make claims that could mislead or deceive consumers when considering what the best deal may be for them? In addressing these questions, Fair Trading acknowledges that while price is a central factor in influencing consumer choice, there are other factors or CHOICE Super Complaint Report 14

17 elements of arrangements/contracts with different electricity retailers which may very well be important to consumers and therefore influence choice. 4.3 Is a mandatory or voluntary code or accreditation system necessary? In responding to recommendation 1, a range of factors have been considered including the following: Complaint data and other relevant information from regulators; The role of the Australian Energy Regulator; Recent inter-jurisdictional work on comparison websites carried out by the Council of Australian Governments Legislative and Governance Forum on Consumer Affairs Policy and Research Advisory Committee (PRAC); The application of the Australian Consumer Law; and The results of work conducted by Fair Trading that considered whether switching sites were engaging in misleading or deceptive conduct The above information is relevant in identifying the nature and extent of any consumer detriment; The decision to regulate an industry or some aspect of trader activity within an industry is influenced by a range of factors. In the first instance, existing law and regulation that apply to that market and the behaviour that has been identified as the cause of the problem, must be evaluated both in terms of how the regulation addresses the issue (or not) and compliance by industry with the regulation. Does existing legislation address the key concerns raised by CHOICE? In addressing this issue, the response considers the application of the Australian Consumer Law on electricity switching sites and whether this national law is sufficient to regulate the identified behaviour; This analysis goes directly to the need for additional regulation of the industry If it is considered that regulation is required in order to adequately address matters that are leading to consumer detriment or have the potential for consumer detriment, the size and scope of the issues will play a key role in the type of regulation that is best suited to address the issue; CHOICE Super Complaint Report 15

18 4.3.6 The willingness of industry participants together with their influence and reach within that industry will also play a role in determining what the most appropriate regulatory response may be; Fundamental questions to be addressed in considering whether to enact any regulatory code include: Will consumers be better off for its introduction? Are the costs of regulation outweighed by the benefits to consumers? The Competition and Consumer Act 2010 (section 51AE) allows for the making of prescribed voluntary and mandatory industry codes of conduct. An industry code is defined as a code regulating the conduct of participants in an industry towards other participants or consumers in the industry and is enforceable by the ACCC. The decision to prescribe an industry code rests with the Australian Government. In most circumstances, a prescribed code will only be enacted where there is no underpinning legislation that deals with that industry. The codes that are currently administered by the ACCC meet this general requirement; Voluntary codes are generally used where there is insufficient evidence to support additional formal regulation such as a mandatory code or specific legislation. A voluntary code sets out specific standards of conduct for industry and assists business to meet their regulatory obligations. Signatories to the code voluntarily agree to meet these standards. A well designed voluntary code can enhance existing legislation by clearly setting out the obligations of business and minimising the costs of compliance; While government generally may provide some guidance in the development of a voluntary code, industry participants and their peak associations are responsible for the development of the framework; 4.4 The benefits of a voluntary code: A more flexible framework than legislation that can be easily amended to address emerging issues, provides a more efficient complaints resolution mechanism for consumers, is less costly to implement and administer and has a greater sense of ownership by industry; A voluntary code that covers electricity switching sites may have potential to provide consumers with better and more consistent information that is relevant to making an informed decision on whether to switch retailers; CHOICE Super Complaint Report 16

19 4.4.3 An accreditation system typically involves an endorsement of an organisation s competence, credibility, independence and integrity in carrying out certain activities. In the electricity switching industry, such a system could involve businesses applying to the regulator for accreditation of their comparison calculator. The accreditation process may include a requirement for the organisation s calculator and related systems to be independently audited; A mandatory accreditation process imposes direct costs on business and can act as a barrier to entry in that industry. For these reasons, together with the role of IPART and in particular the Australian Energy Regulator in establishing price comparison sites for consumers to determine best value offers, an accreditation system is not considered appropriate. 4.5 Evaluation of data a summary of advice from other regulators As part of the consideration and assessment of the claims and recommendations made by CHOICE in its Super Complaint, Fair Trading wrote to the NSW Independent Pricing and Regulatory Tribunal (IPART), the Energy and Water Ombudsman (EWON), the Australian Energy Regulator (AER) and the Australian Competition and Consumer Commission (ACCC). 4.6 The Australian Energy Regulator The implementation of the National Energy Customer Framework (NECF) is the next major stage in the national energy reform process, as agreed by the Council of Australian Governments. The NECF involves the harmonisation of State-based regulatory frameworks (excluding retail price regulation and community service obligations) to a national regime for the sale and supply of electricity and gas by retailers and distributors to retail customers; The focus of the NECF is on providing a regulatory framework for the relationship between energy customers and the energy retailers and distributors that supply them, and includes a range of energy-specific consumer protections; The AER regulates the wholesale electricity market and is responsible for the economic regulation of the electricity transmission and distribution networks in the national electricity market; CHOICE Super Complaint Report 17

20 4.6.4 In its response to Fair Trading on the issue of this Super Complaint, the AER confirmed that from 1 July 2012, its responsibilities under the National Energy Retail Law and Rules (Retail Law) include assisting consumers to become more informed about available energy products. As part of this work, the AER is developing a Retail Pricing Information Guideline (the Guideline) through which it will prescribe the manner and form in which retailers provide information on their energy products and the development of an energy price comparator website. This website will be available to consumers from 1 July The site will enable consumers as well as small business customers to compare energy offers as well as provide advice on energy efficiency initiatives; The Guideline specifies the use of a template (Energy Price Fact Sheet) to present prices and other product information when retailers present or otherwise market or advertise pricing information to consumers. It also sets out the information on contract offers to be provided by retailers to the AER for the price comparator site and how that information is to be managed. The information that is required to be included on an Energy Price Fact Sheet includes: Unit price; Any fixed or standing charge and key applicable fees; Discounts and rebates which apply to an offer including one-off, direct debit and pay on time discounts; Length of the contract; How a retailer may vary the prices that apply to a contact offer; Contact information; Where customers can access information on the full terms and conditions; and The availability of the AER s price comparator website. CHOICE Super Complaint Report 18

21 4.6.6 While the retailer has some discretion over the layout of the Energy Price Fact Sheet, there are requirements relating to plain English, font size and other matters relating to the ease with which a consumer can understand the information presented; Retailers must publish an Energy Price Fact Sheet for all contract offers for consumers on its website and this must be easily accessible; The Guideline also set requirements for making Energy Price Fact Sheets available during the course of door to door sales, telemarketing and telephone enquiries and mass media marketing; Further information on the role of the AER and the requirements of energy retailers under the National Energy Retail Law is available at Independent Pricing and Regulatory Tribunal (IPART) In its response to Fair Trading on this matter, IPART note the importance of ensuring that consumers are able to accurately compare energy offers and make informed decisions on energy contracts that suit their circumstances. In that response, IPART also note the operation of its myenergyoffers website and the AER website (operational by 1 July 2012) as playing an important role in increasing consumer awareness On the issue of CHOICE s assertion that not all switching sites are providing the consumer with all relevant terms and conditions of a contract, IPART highlight the requirements of marketers of energy products under the NSW Marketing Code of Conduct. The Code requires information to be provided to a customer before or at the time the customer enters into the contract. This information is important to enable the customer to make an informed decision about a particular offer; IPART has advised that they have recently written to all energy marketers about energy switching sites to advise of their obligations under the marketing code (which will not operate on commencement of the National Energy Customer Framework) and request all energy retailers to review their websites to ensure compliance; IPART has also advised that it has conducted a high level review on energy switching websites, the results of which suggest that there may be a need for CHOICE Super Complaint Report 19

22 an industry voluntary code. In making this suggestion, IPART note that given the commencement of the National Energy Customer Framework on 1 July 2012, this should be considered in a national context. 4.8 ACCC Federal Court action against Energy Watch In 2012, the ACCC took an action under the Australian Consumer Law in the Federal Court against Energy Watch Pty Ltd alleging misleading and deceptive conduct relating to advertising and making false, misleading or deceptive representations; Energy Watch is a company that provides brokering services for the retail purchase of electricity and/or gas for residential and business customers. The company receives fees or commissions from energy retailers, when it refers customers to those retailers; The ACCC alleged that during an advertising campaign in 2011, Energy Watch made a number of representations that breached sections 18, 29 and 34 of the ACL (More information on these provisions was provided in section 2 of this Report); On 30 April 2012, the Federal Court found that Energy Watch had misled consumers in relation to its energy price comparison service and the savings that could be achieved using the service; The ACCC has indicated that it will continue to work towards ensuring providers of these services do not mislead consumers; 4.9 International experience Consumer Focus, the UK statutory consumer champion, administers the Confidence Code a voluntary code of practice for online domestic price comparison services; The Code was launched in 2002 and sets minimum requirements that an energy price comparison service must meet to be accredited by Consumer Focus. To gain accreditation the site has to pass an audit of their services and be subject to regular scrutiny to ensure the consumer information they provide is accurate; CHOICE Super Complaint Report 20

23 4.9.3 A 2008 Office of the Gas and Electricity Markets report found that approximately a third of consumers who switched energy retailers, were not better off after the switch; The Code was reviewed in 2009/10 with a number of changes made including: the way tariffs are displayed; auditing by Consumer Focus; and complaint processes The regulatory framework for energy suppliers and retailers in Australia The Australian energy market from production to supply, transmission and retailing of energy products, operates within a comprehensive and complex national regulatory framework. This framework has been established through the Council of Australian Governments (COAG) to ensure the safe supply and transmission of affordable and reliable energy products; The Australian Energy Market Operator (AEMO) was established in 2009, to operate the energy markets and systems. It is an independent organisation whose main role is the development of markets that offer affordable, safe and reliable energy supplies, in the long term interests of consumers; The AEMO operates alongside: The Australian Energy Regulator (AER), which oversees economic regulation and compliance with the national laws and rules, reports on generator bidding behaviour in the National Electricity Market (NEM) and regulates electricity transmission and distribution networks in the NEM; and The Australian Energy Market Commission (AEMC), which makes the rules governing the regulation of the energy markets. CHOICE Super Complaint Report 21

24 These institutions have assumed many of the electricity regulatory arrangements that were previously the responsibility of state government authorities; The Standing Council for Energy and Resources (SCER) is responsible for developing policies related to the gas and electricity markets; The commercial energy switching sites identified by CHOICE, are not electricity retailers and as such the energy market regulatory framework does not apply. Further advice from the AER has been sought in relation to the application of the Retail Law and Pricing Guidelines. As a legal entity engaged in trade or commerce, these sites are covered by the Australian Consumer Law Evidence to support a mandatory code Fair Trading s response to recommendation 1 is that the need for a mandatory code or an accreditation system for the electricity switching industry has not been established. The reasoning behind this response is predicated on three main issues: Lack of consumer complaints or other evidence that demonstrates consumer detriment: regulators receive relatively few consumer complaints related to electricity switching sites. Without substantial first hand evidence that there is a particular problem leading to consumer detriment, it is difficult to support additional regulation at this stage; No evidence of widespread or systemic non-compliance with consumer protection laws: Fair Trading tested the switching sites on the issues identified by CHOICE such as claims of estimated level of savings and disclosure of relevant terms and conditions. The results of these investigations are included in the next section of this response. While this work did not reveal widespread or systemic non-compliance with consumer protection laws, the investigations did however highlight a number of areas where further compliance work is warranted The Australian Consumer Law provides adequate and effective protection to consumers: The recent Federal Court decision (highlighted at section 4.7) illustrates that the Australian Consumer Law provisions for misleading and deceptive conduct, false and misleading representations and misleading CHOICE Super Complaint Report 22

25 conduct as to the nature of services are effective in dealing with the central issues of this Super Complaint; 4.12 The creation of the Australian Energy Regulator and the National Energy Customer Framework The commencement of the NECF will mark an important development in consumer protection in the energy market. As highlighted earlier in this response, under the AER s Retail Pricing Information Guidelines, energy retailers will be obligated to present price offers to consumers through an Energy Price Fact Sheet in a prescribed manner and content. The AER will prescribe the use of particular terms and disclosure of additional fees and charges to consumers; The work undertaken by the AER in this area together with the operation of its energy comparison website energy made easy will considerably enhance the information and advice available to consumers A voluntary code In industries where legislation is considered sufficient, yet there is an identified need to provide clear markers for business in terms of expected behaviour, a voluntary code may provide benefits to consumers; A voluntary code has potential to be a low cost form of regulation that would provide consumers with better and more consistent information that is relevant to making a decision on whether to switch sites. An effective voluntary code will have the widespread support of the industry. Its development, implementation and administration while a shared responsibility within the industry, needs to be driven by a representative and authoritative industry body; However in a national energy market, any code needs to be considered in a national context; Fair Trading supports the industry developing a voluntary code that binds its signatories to a set of specific standards. These standards could include: commitment to adhering to the requirements of the Australian Consumer Law; CHOICE Super Complaint Report 23

26 disclosing all commercial and other significant relationships with energy retailers; an independent audit of the calculator used to estimate savings; full disclosure of key terms, conditions, fees and charges; and commitment to the standards required of retailers under the Energy Price Fact Sheet The voluntary code must have an effective Code Administration Committee and a transparent and efficient consumer complaints facility. Fair Trading notes that the ACCC has published guidelines for developing effective voluntary industry codes of conduct. Fair Trading is committed to assisting the industry in its development of any code. CHOICE Super Complaint Report 24

27 5 Response to Recommendation Introduction The second recommendation asked Fair Trading to investigate whether any of the identified switching websites were engaged in misleading or deceptive conduct; A major concern noted by CHOICE was the differences in claimed savings for residents of a given postcode when comparing the deals offered by the various websites; This lack of consistency in the projected monetary savings was identified as an area deserving of further investigation with a view to assessing whether the variations are indicative of systematic shortcomings regarding accuracy and disclosure of relevant information; Fair Trading undertook the following actions to implement recommendation 2: Applying the calculation methodology adopted by CHOICE, but by using a broad range of postcodes, to get a broader idea of choices and costs faced by consumers in a larger range of metropolitan and regional areas across NSW; Use of IPART switching service as a baseline comparator for testing purposes; Review of the displayed Terms and Conditions presented on switching websites; Calculations of savings if consumers switch retailers directly through supplier websites and comparison with switching websites; and Analysis of representations made on the websites to identify claims which may be potentially misleading or constitute misrepresentations; The following table identifies the six electricity switch websites reviewed and the ownership details: CHOICE Super Complaint Report 25

28 Website Registrant Registered Office goswitch.com.au switchwise.com.au compareelectricityprices.com.au youcompare.com.au ratedetective.com.au shoparound.com.au Goswitch Pty Ltd (previously known as Switching Services Pty Ltd) ACN Switchwise Pty Ltd ACN Switchselect Pty Ltd ACN Connectus Pty Ltd ACN DR Globalex Pty Ltd ACN Look Corporation Pty Ltd Park St, South Melbourne, Victoria St Kilda Rd, Melbourne Victoria 5 O Sullivan St, Hendra, Queensland MPR Group Pty Ltd Hwt Tower, Level 19, 40 City Rd, Southbank, Victoria WHK Thomsons, Langtree Avenue, Mildura, Victoria Toyne Business Consultants, Suite 6, 125 Bull Street, Newcastle West, New South Wales Table 1: Electricity Switching website details 5.2 Claimed Savings The table below is an analysis of the results of the survey undertaken by Fair Trading of the six switching websites using consumption data for ten separate NSW postcodes 4 : 4 Survey conducted 27 April 2012 CHOICE Super Complaint Report 26

29 Website Reviewed Number of % of Highest Lowest postcodes postcodes claimed claimed with with claimed savings savings as Results savings as a % a % Goswitch.com.au 9 90% switchwise.com.au 10 90% 42 (5) 5 compareelectricityprices.com.au % youcompare.com.au 10 70% 25 (24) ratedetective.com.au % shoparound.com.au % IPART % Table 2: Analysis of switching website results Three of the six commercial switching websites reviewed claimed to deliver a savings in all ten postcodes evaluated; The level of savings each website claimed to achieve varied for the postcodes evaluated. For example, the Switchwise website claimed a savings of 42% for residents of Hurstville but did not offer any savings for residents in Liverpool; Additionally, all six websites offered varying results for particular postcodes. For example, GoSwitch offered a savings of 10% for Ku-Ring-Gai residents whereas Comparelectricityprices.com.au claimed a savings level of 58% a variation of 48%. Some of the causes and implications of the wide variations in savings noted are discussed in section 5.3 below. 5.3 Variations in claimed savings Fair Trading identified that using the same consumption data for the same postcode on different switching websites does not lead to the same result. In other words, variations in the level of estimated savings were confirmed; 5 Estimate was higher than current expenditure level CHOICE Super Complaint Report 27

30 5.3.2 The question to consider is whether the lack of consistency in the estimated level of savings across the websites points to systematic shortcomings within the industry; As noted earlier in this Report, the COAG Legislative and Governance Forum on Consumer Affairs has recently considered this question. One of the issues discussed was the motive of commercial enterprises for a point of difference to distinguish them from their competitors. A key area of establishing this distinction is to compete on the basis of price, or in this case, estimated savings; Nonetheless, the results obtained indicate that in some cases the variations in the level of claimed savings for the same postcode are inexplicably large. For example, GoSwitch had a claimed saving of 11% for Hurstville residents, Switchwise claimed to provide a saving of 42% and Comparelectricityprices 51% (It should be noted, however, that the input data used to calculate the estimated savings may vary from one website to another); The large variances are a concern and considering the growth of the commercial switching website industry and the entry of new operators in recent years, there is a concern that heightened competition may lead to operators adopting high risk marketing techniques such as exaggerating claims on savings available; The tests point to a greater likelihood that the industry has witnessed the entry of a number of high risk operators as opposed to widespread systematic shortcoming. In the absence of any complaints data, it is very difficult to identify how many or who these high risk operators may be; Experience in other industries especially emerging industries which have experienced rapid growth has shown that there could be an influx of operators who are more likely to engage in practices which fall below the standards expected by the community. CHOICE Super Complaint Report 28

31 5.4 The Best Deal The CHOICE Super Complaint identified the use of terminology such as best deal as a particular area of concern; Unqualified representations using the term Best Deal or similar statements are of concern to Fair Trading. Claims by advertisers which represent their products have certain characteristics or features which make them desirable to members of the public are indicative of the problems that may arise with claims contrary to consumer protection legislation applicable in this country 6 ; The investigation located representations which raise concerns (discussed in sections ). Some of the examples discussed in this paper are designed around the price factor. The use of small print or the practice of placing information under asterisks is also an area Fair Trading has identified as a particular concern. Whether information which can materially restrict or distort the dominant message or claim is placed in a position where it can be located is an important consideration in designing any future compliance action; It is also noted that the assessment of representations around best deal type claims in the context of misleading or deceptive conduct requires an examination of factors not limited to claimed savings. 5.5 Site specific representations The following claims are a selected example identified during Fair Trading s investigation and included in this Report to demonstrate the potential issues around the claims on selected electricity switching websites Fair Trading is considering further action in relation to these representations and claims. Any planned action will be taken in concert with other ACL regulators. 5.6 Example 1: What is a best priced retailer? 6 Federal Court of Australia, ACCC V Energv Watch, 30 April 2012 CHOICE Super Complaint Report 29

32 Based on the information you have provided, your current household expenditure is $XXX per annum for your electricity. The best priced retailer for you is This representation raises the following issues: Is there sufficient information on the number of retailers evaluated? Can the relevant information be easily located by a reasonable person? Is it best priced from the selected providers the website has a commercial arrangement with or all providers? 5.7 Example 2: Are promised savings available to the consumer? Save up to $400 on your power & gas bills**it's FREE, quick & easy to switch energy suppliers online The representation made on this website appears to be based upon a survey involving Victorian consumers, yet it is advertised as being applicable to NSW consumers. This raises the following issues:: Are the consumption rates quoted comparable for a NSW consumer? Is switching electricity retailers a quick and easy decision to make? Can a reasonable person locate and factor into their assessment the information placed under the asterisk? 5.8 Example 3: Is switching as easy and profitable as this? Switching to a cheaper energy provider you could save hundreds of dollars a year. Just answer a few easy questions about your current power usage and we will find the best deal for you from our participating suppliers Issues arising in relation to this representation include: Can a consumer save a few hundred dollars by answering a few easy questions? Is the best deal selected from providers that the website has a commercial arrangement with, or all providers? Can the pertinent information be located in a reasonable amount of time? CHOICE Super Complaint Report 30

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