We are reviewing our urban and rural water customer service codes to ensure they continue to meet the needs of Victorian water consumers.
Water codes review
Launch of review21 December 2021
Stakeholder engagementFebruary - March 2022
Draft decisionJune 2022
Submissions close26 July 2022
Final decisionSeptember 2022
In recent years, significant events including the coronavirus pandemic have created new challenges and exacerbated existing issues for consumers.
In response to these challenges, water businesses have substantially increased their support for customers, often going beyond the minimum requirements set out in our customer service codes. We have also seen for the first time a set of National Cabinet approved policies and principles for coronavirus support that aim to ensure consistent support during the pandemic.
To ensure the water customer service codes continue to meet the contemporary needs of Victorian water consumers, we have undertaken a review of the codes. This review has led to a series of proposed updates to reflect community expectations and best practice that has evolved over the last two years.
We consulted on proposed updates to the codes between 14 June 2022 and 26 July 2022
In June 2022 we published a draft decision that set out proposed amendments to the codes including an updated set of standards water businesses would need to comply with. We proposed the amendments to take effect from 1 January 2023.
We held a public forum on 11 July 2022
We held a public forum during the consultation period to inform stakeholders about the updates, including the new standards water businesses will need to comply with. We had about 50 key stakeholders in attendance and the forum provided an opportunity to discuss the specific initiatives proposed in the draft standards.
We received submissions from stakeholders
We also published our draft decision on proposed changes to the codes on Engage Victoria’s website where stakeholders could respond to a series of questions and upload a submission.
We received 12 submissions of which 11 were from water businesses and one from the Consumer Action Law Centre.
The mains themes covered in the submissions we received were:
- the definition of small business
- the undercharging limitation period
- the periods of reminder and final notice periods
- the proposed reasonable endeavours requirements before restriction
- the commencement date of the service standards
- the requirement for e-bills
- restriction as a measure of last resort.
Stakeholder submission also provided their views on individual clauses in the service standards.
View all submissions in the 'resources' tab of this page.
This draft builds on past engagement with stakeholders
From February to April 2022, we undertook a public engagement process to ensure that the views of interested stakeholders were considered in the proposed amendments to the customer service codes. This built on initial engagement undertaken in 2019.
Our activities included a range of different methods, including stakeholder forums, a community panel and targeted discussions.
We held three online public forums in February and March 2022. Over the course of the three forums, we covered a variety of different topics under the following themes:
- reflection of the National Principles
- communication assistance
- actions for non-payment
We convened a community panel of 27 Victorian consumers, from a range of demographics to seek their views on issues related the customer service codes.
The topics the community panel discussed included:
- supporting customer experiencing financial stress
- communication assistance
- reminder and warning notices
- actions before restricting water supply or legal action
- which types of small businesses should be covered by the codes.
You can read the report summarising our customer panel process and outcomes in the 'Resources' tab.
Small business organisations
To explore key considerations when including support for small businesses in the draft water industry standards, we spoke directly to organisations that represent or work with small businesses.
Rural water businesses
To ensure we captured rural specific issues, we consulted with representatives from each of the water businesses providing rural services in Victoria. We wanted to further understand the payment support that rural water businesses provide to their customers.
Consultation on the draft proposals closed on 26 July 2022.
The commission is in the process of reviewing submissions. We will consider all stakeholders feedback and release a final decision in late September 2022.
If you have any questions about this work you can email the commission at firstname.lastname@example.org.
Summary of the proposed amendments
The draft decision proposed amendments to customer protections, with a focus on:
- strengthening code requirements relating to customer communication, to help ensure water businesses communicate appropriately and sensitively with their customers
- refining the minimum standards regarding support for customers experiencing payment difficulty, and mandating certain support for small businesses
- reflecting changes in technology and communication channels since we last review our codes
- clarifying the application of interest and debt management activities by water businesses.
We also plan some administrative amendments proposed throughout the paper and in the accompanying annexures.
Draft water industry standards
Community panel report on the engagement process
Draft decision submissions
Documents we reviewed
Overview of our third workshop: Actions for non-payment
We held our third workshop for our review of the water customer service codes on 17 March 2022. In this workshop, 46 participants from the water and community sectors focused on actions for non-payment.
Restriction limitations and interest on unrecovered amounts
Participants discussed how the National Principles could be best reflected in the codes in relation to limits on restrictions and charging interest on unrecovered amounts.
Participants from water businesses noted that due to the pandemic there is more debt across the water industry, however if customers remain engaged, restrictions should be avoided. There was broad agreement that customers experiencing payment difficulties should not have their services restricted and should not be charged interest or additional fees.
Reasonable endeavours before restriction or legal action
Participants then discussed what actions a water business should take before it restricts or takes legal action against a customer (Hardship related Guaranteed Service Level ‘reasonable endeavours’ checklist). Participants highlighted some issues with the use of registered post, particularly in rural areas. As a result of this, sending registered post notices may no longer be ideal. Some water businesses noted that they were transitioning to monthly billing cycles and that this should be considered in an updated checklist. Participants agreed that water businesses should be allowed to choose the best possible communication methods for customers to allow maximum chance of engagement.
Overview of our second workshop: Communications and proactive engagement
We held our second workshop, in a series of three, for our review of the water customer service codes. In this workshop, 42 participants from the water and community sectors focused on communications assistance and appropriate communication.
We invited participants to discuss how water businesses have changed their approach to communicating with their customers since the coronavirus pandemic and the introduction of the National Principles. We also asked how the current requirements in the codes can be improved to ensure water businesses communicate more effectively with their customers.
Participants highlighted that there was a need for balancing flexibility in communicating with customers and ensuring minimum standards are met. They were also supportive of broadening the current requirements and ensuring that water businesses, as much as possible, met the communication needs of their customers.
Participants discussed what communication channels water businesses use to provide information about payment difficulties and the communications options customers might prefer when speaking with water businesses. There was a diverse mix of communication channels that water businesses are already using to communicate with customers. Each channel has unique benefits and challenges for us all to consider.
Appropriate communication, summary bills (eBill) and notices
Participants were then split into four groups. Each group discussed a different topic related to the contents of eBills and notices whilst considering all communication relating to collection is appropriate and focused on the support available to customers.
eBills are usually sent by email, containing a summary of the water business’ bill and a link to the full bill. Participants discussed what information should be included in eBills but agreed that it should be brief and to the point. Some participants highlighted that issuing eBills may not be cost effective for all businesses, based on the sophistication of their current systems.
Notices to customers
Groups considered whether notices to customers such as reminder notices and notices warning of restriction could be personalised or whether water businesses would find it difficult to tailor notices to individual circumstances. Participants agreed that both reminder and warning notices should have options for customer support clearly set out.
Participants agreed that changes to warning notices may help improve customer engagement and reduce debt levels.
Overview of our first workshop: Reflection of National Principles in the codes
We held our first workshop, in a series of three, for our review of the water customer service codes. Thirty seven participants from the water and community sectors focused on how we could incorporate the National Principles in the codes and the types of support the codes could offer for small businesses.
Reflecting the National Principles in the codes
After some background information about the water customer service code review, participants were split into three groups to discuss one of three proposed draft clauses: proactive customer engagement, payment difficulty assistance and customer support policy.
Proactive customer engagement
Participants discussed what was meant by proactive customer engagement and agreed with the concept in principle but stated that it may be difficult to execute in practice. Several participants highlighted that the policies and procedures water businesses currently have in place to help customers experiencing payment difficulties are mainly reactive. It relies on customers to contact the business before being able to access assistance.
Participants were interested in hearing examples of what best practice proactive engagement can look like.
Payment difficulty assistance
The focus of this discussion was a draft clause about support for residential customers experiencing payment difficulty. Participants agreed the balance between what water business ‘must’ offer to customers and what they ‘may’ offer to customers was right.
There was a discussion about the importance of providing support early on for customers to reduce their usage.
Customer support policy
There was support for the change of wording from ‘hardship policy’ to ‘customer support policy’ and a move away from hardship as the focal point.
The group highlighted that support for customers is broader than financial support and access to information should also be a focus.
Support for small businesses
To discuss support for small businesses, the participants were split into three groups.
The groups first covered whether the codes need to define a small business. There was agreement that there should be a definition of a small business in the codes to ensure consistency amongst the approaches of water businesses.
Currently, many water businesses rely on self-identification by the business customer. Some identify based on consumption (e.g. consumption levels similar to residential customers) and others distinguish industrial business from other non-industrial businesses (small businesses).
Participants mostly agreed that the balance between what a water business ‘must’ offer small business customers and what they ‘may’ offer was right. However, it was noted that it is important to include non-financial assistance, particularly about water efficiency.