November 2025
Proposal A: Standardise billing information to make bills easier to understand and give residential consumers the information they need to engage
We believe that minimum billing standards should be compulsory.
We support the proposed tiered layout of bills, with critical information (tier one) presented first, followed by important information (tier two). Proposed tier one information included the amount due, due date, key retailer, customer details, emergency information and switching prompts, while tier two information included more details of the plan, consumption and support information.
Proposal B: Introduce better plans to support residential consumers to understand if they are on their retailer’s cheapest plan for them, and switch risk-free if they are not
We strongly support the plan review proposal, with consumers regularly prompted to move to a more suitable plan or to trial a more suitable plan. We support the proposed timeframes with plans reviewed every 6 months and time-of-use trials of 3 months.
We believe this has the potential to provide substantial benefit to low-income households and particularly older people who are less engaged with the internet. However as noted in the consultation paper, usage can change dramatically in relation to a household’s current situation (household composition, whether people are working from home, etc.) and we highlight a need to ensure it is clear to the consumer which period has been used to make the assessment.
We suggest that this includes comment on any substantial changes in their power consumption compared to the previous year; for example if their power consumption has stayed the same for the first 8 months of the last year but halved for the final 4 months the proposed power plans may not be suitable, so making this clear will ensure that consumers do not sign up to an inappropriate plan.
In addition, when providing consumers with multiple plan options it is essential that this is provided clearly with consideration of how the plans would apply to them and why they might be beneficial in this instance to ensure that consumers are not disadvantaged.
We support the removal of termination fees when switching between plans with the same retailer. We encourage consideration of the removal of penalties for switching retailers. The consultation document highlights the main argument against doing so being disruption of contract-based incentives (Electrical Authority, 2025). However, as removing internal plan-switching penalties may give consumers the ability to switch to another plan to avoid penalty and then subsequently change to another retailer, it is likely that this will already disrupt contract-based incentives. As such we think this should be expanded to cover penalties for switching retailer as it would be in the best interest of consumers to do so.
Proposal C: Encourage consumers to compare plans across all retailers and switch where it will save them money
We feel that the proposed wording of the switching prompt did not sufficiently promote consideration of changing electricity provider. The proposed prompt read:
“Could you save money on another plan? Compare plans at the independent a government-funded site [TBC].org.nz.
The Electricity Authority requires us to include this information”
It is essential that this is presented plainly to ensure there is no confusion among consumers and encourage checking of alternative providers. Wording which specifies that the consumer may be better off changing to another provider such as “you could save money by changing your plan or provider”.
We support the suggestion that each electricity retailer should maintain a catalogue of their full range of plans and costs to allow consumers to compare these.
We support the requirement for annual check-ins to require retailers to tell customers how to check for better plans and that retailers should have to advise customers if there is a more suitable plan available whenever a customer contacts them.
Proposal D: Limit back-billing to protect residential and small business consumers from bill shock
We strongly support limiting back-billing, however we feel that this should be limited to 4 months rather than the proposed 6-month cap. The consultation document mentions that an alternative proposal was to have the cut-off period for back-billing set to 4 months like has been done in Victoria Australia. This idea was not pursued as there were concerns raised (both for retailers and consumers) including that short cut-offs could result in consumers being more quickly disconnected. We were unable to find any evidence to suggest this has occurred in Victoria despite this legislation being introduced in 2021. Although we accept the introduction of a 6-month cut-off is a vast improvement on the status quo, we would urge the Authority to consider shortening this further if the proposed benefit to low-income families is modelled to be significantly greater.
We support consumers being allowed to pay this back in instalments and think ensuring all households have smart meters would help to prevent back billing accruing while also allowing greater understanding of energy usage amongst consumers.
We support the proposal for these changes being rolled out over four stages over 2026 (option 1) with this starting in February 2026.
Other feedback on the proposed code amendments
NZCCSS strongly supports the use of plain language including the proposed change to remove jargon. We would however propose that where this is not achievable, specific electricity terms and abbreviations are explained as a footnote on the bill to ensure that consumers are able to easily identify the information, for example if an outside organisation is requesting details like Installation Control Point (ICP) number.
Additionally, we’re aware that although the average billing period is 30 days, some retailers billing periods vary drastically from month to month, with Genesis noting billing periods of up to 45 days. This makes it challenging for consumers to compare power bills from month to month or to assess how changing to a new plan has impacted their power bill. We would suggest considering a set billing period such as 4 weeks for all bills, with yearly comparisons using the same 4-week period. However, we understand that for consumers without smart meters this may be hard to implement so suggest the inclusion of a basic comparator like average daily electricity cost in each bill to help provide clarity for consumers.
Currently bills, retailers and power comparison websites are inconsistent in their presentation of pricing in terms of GST inclusion or exclusion making it difficult for consumers to compare prices. The Commerce Commission recently highlighted concerns regarding some retailers advertising GST exclusive power pricing resulting in consumers signing up to power plans that were not producing cost savings. How power pricing is advertised and presented in bills should be consistent to allow for greater understanding and comparison of costs and ensure that consumers are not taken advantage of.
Currently comparison of usage/cost with previous years is not a requirement to be presented in bills and many retailers require consumers to assess this themselves through manual comparison of previous bills or via the retailer’s app. This is a barrier for some cohorts, including older people and those who live rurally, who may not be using the app or have access to the internet. Consideration of these cohorts and how this information will be presented to them is needed to ensure that households are not disadvantaged.