Proposed billing exception approval for Greater Western Water
Overview
In May 2024, Greater Western Water launched a new billing system by merging two previous systems. The new system led to various billing issues, including Greater Western Water’s failure to issue customers with quarterly bills.
Following an investigation by the Essential Services Commission, Greater Western Water offered the commission an enforceable undertaking and sought four time-limited exceptions to the requirement that bills be issued quarterly.
Between 1 October 2025 and 22 October 2025, the commission consulted publicly on the proposed exception approvals.
Consultation process
Between 1 October and 22 October 2025, the commission sought feedback on the proposed exception approvals through its website and the Engage Victoria website.
The purpose of the consultation was to gather feedback from the public and stakeholders to better understand the potential impact of the exception approvals sought by Greater Western Water.
The commission received 788 submissions throughout the consultation period – including 775 submissions via Engage Victoria.
The commission completed a review of all submissions. Several submissions included comments that touched on one or more themes. This stakeholder feedback helped to inform the commission’s decision regarding whether to accept the exception approvals.
Final decision
The commission has approved four time-limited exceptions to quarterly billing for Greater Western Water. This approval recognises that Greater Western Water must continue investing in critical water services and infrastructure while addressing the technical constraints of its billing system.
Greater Western Water can send delayed bills to residential and small business customers for January 2024 to June 2026 charges on the following conditions:
- 2024 charges were sent before 1 September 2025.
- January to March 2025 charges are sent within 12 months of that billing period, list the amount due and offer payment plans.
- April 2025 to June 2026 charges are sent within 12 months of that billing period, list the amount due and offer payment plans. If it is not sent within four months, customers must be given an estimate of their bill.
The commission adopted consumer feedback from the consultation and added several new conditions to the exemption.
The commission has also accepted a court enforceable undertaking from Greater Western Water. The undertaking contains a customer redress package valued at $130 million and requires Greater Western Water to carry out a compliance improvement activities plan.
The undertaking requires Greater Western Water to remediate residential and small business customers by:
- writing off any 2024 charges that were not billed before 1 September 2025, which will clear about $75 million in unbilled charges from customer accounts
- giving an $80 credit to customers who received a bill for 2024 charges that were delayed by more than seven months
- only sending bills or recovering charges within 12 months from the end of the quarter being billed
- giving credits of between $80 and $240 to customers who receive a delayed bill for usage charges from January 2025 to June 2026, based on the length of the delay
- giving an $80 credit to approximately 70,000 customers affected by the suspension of its ‘direct debit in full’ payment option.
Greater Western Water must also implement measures to improve compliance and follow rules about how it communicates with customers.
A summary of our final decision and consultation can be accessed below.
The commission approves variations to Greater Western Water’s customer charters
On 17 December 2025, the commission, pursuant to clause 22.4 of the Water Industry Standard (the WIS), made a decision to accept a variation requested to Greater Western Water’s (GWW) customer charters.
The commission made this decision after receiving a request from GWW on 10 December 2025. GWW had undertaken a consultation process as required under clause 22.3 of the WIS.
The underlined words indicate the new additions to the charter and the strike out words are deletions:
Residential Customer Charter 2024-2028
| Section/Title of Customer Charter (the words underlined indicate the additions and the |
s. 1.1 – About the Residential Customer Charter: This Residential Customer Charter outlines the rights and obligations between GWW (us) and the residential customers we serve (you). It provides information on the services we deliver between 1 July 2024 to 30 June 2028 and the standards that apply to those services. This Residential Customer Charter should be interpreted consistently with the Water Industry Standard, which we are required to comply with. |
s. 8.2 – Billing cycle, content, presentation and history: A typical residential customer will be billed for their water consumption based on actual (or estimated) meter reads a minimum of once every three months. If your property is part of a large owners corporation that collectively consumes in excess of 5,000 kL per quarter, you may get a monthly bill. Our regulator, the Essential Services Commission, may approve alternative billing cycles (i.e. other than quarterly) under cl 6.1 of the Water Industry Standard. On 31 October 2025, the Essential Services Commission approved alternate billing arrangements for our customers in relation to charges for the usage period 1 January 2024 to 30 June 2026. See Appendix C, which explains the billing arrangements for the usage period 1 January 2024 to 30 June 2026. |
s. 8.4 – Payment
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s. 12.1 – Undercharging or overcharging – adjusting bills: If you are undercharged:
For amounts that were undercharged as a result of billing delays for the usage period 1 January 2024 to 30 June 2026, see Appendix C, which explains the billing arrangements for that period. |
Appendix C – Enforceable Undertaking On 31 October 2025, the Essential Services Commission approved alternate billing arrangements for our customers in relation to charges for the usage period 1 January 2024 to 30 June 2026 (Approval). The Essential Services Commission also accepted an enforceable undertaking (Undertaking) from GWW which requires GWW to meet certain obligations in relation to consumer redress, notification of customers and improvements in relation to compliance with the Water Industry Standard. The decision is public and is available on the Essential Services Commission’s website. Below is a summary of the Approval and the Undertaking and should be read consistently with them and the requirements under the Water Industry Standard. The Undertaking requires Greater Western Water to remediate residential and small business customers by:
The Approval provides an exception to GWW to bill on a quarterly basis for a time limited period. After 30 June 2026 the usual requirements under the Water Industry Standard will apply. The exception granted in the Approval allows GWW to bill outside a quarterly cycle for:
The notification requirements in the Undertaking provide that for small businesses and residential customers:
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Business & Non-residential Customer Charter 2024-2028
| Section/Title of Customer Charter amendments (the words underlined indicate the additions and the |
s.1.1 – About the Business & Non-residential Customer Charter The business and non-residential customer charter should be interpreted consistently with the Water Industry Standard, which we are required to comply with. |
s. 7.2 Billing cycle, content, presentation and history Our regulator, the Essential Services Commission, may approve alternative billing cycles (i.e. other than quarterly) under cl 6.1 of the Water Industry Standard. On 31 October 2025, the Essential Services Commission approved alternate billing arrangements for our customers in relation to charges for the usage period 1 January 2024 to 30 June 2026. See Appendix C, which explains the billing arrangements for the usage period 1 January 2024 to 30 June 2026. |
s.7.4 Payment
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Appendix C – for the Non-residential and business customer charter On 31 October 2025, the Essential Services Commission approved alternate billing arrangements for our customers in relation to charges for the usage period 1 January 2024 to 30 June 2026 (Approval). The Essential Services Commission also accepted an enforceable undertaking (Undertaking) from GWW which requires GWW to meet certain obligations in relation to consumer redress, notification of customers and improvements in relation to compliance with the Water Industry Standard. The decision is public and is available on the Essential Services Commission’s website. Below is a summary of the Approval and the Undertaking and should be read consistently with them and the requirements under the Water Industry Standard. A “large business customer" for the purpose of the Approval and the Undertaking means a customer that is not a residential customer or a small business customer. A “small business customer” is defined under s. 4 of the charter. The Approval provides an exception to GWW to bill on a quarterly basis for a time limited period. After 30 June 2026 the usual requirements under the Water Industry Standard will apply. The exceptions granted in the Approval allows GWW to bill outside a quarterly cycle for:
A separate exception also applies for bills for large business customers only. This exception allows GWW to bill outside a quarterly cycle for 2024 charges (including amounts not yet billed), provided that these amounts are billed by GWW to those large business customers by no later than 28 February 2026, so long as:
The Undertaking also requires Greater Western Water to remediate small business customers by:
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