What AER compliance actually demands of your billing system

Read through the AER's retail compliance and enforcement activity and a pattern repeats. The retailer had a policy. Staff were trained. The breach happened anyway, across thousands of accounts, because the system did not stop it — a flag that did not propagate, a notice that was not sent, a de-energisation request that went out against a protected account.

Which makes retail compliance a systems question. Below is what that means concretely, obligation by obligation.

Life support

The highest-consequence obligation in energy retail. A registered life support customer must not be de-energised, must be given required notice of planned interruptions, and their registration must be maintained and shared correctly with the distributor.

The systems failure mode is almost always the same: registration is recorded in one place, and de-energisation is triggered from another.

Hardship and payment difficulty

Retailers must have an approved hardship policy, identify customers in payment difficulty, offer payment plans on prescribed terms, and protect participating customers from disconnection while they meet their arrangement.

• Identification triggers — missed payments, plan breakage, repeated late payment — need to fire from billing data automatically, not wait for a customer to ask.
• Payment plan terms must be calculated from actual consumption and arrears, and the plan has to be a live object the collections path respects.
• Entering hardship must suppress collections and disconnection immediately and demonstrably, with the suppression visible on the account.
• Exiting hardship needs the same rigour, including whether the exit was compliant.

Disconnection safeguards

De-energisation for non-payment is hedged with conditions: minimum amounts, required notices with prescribed timing, prohibited days and times, and protections for customers on plans, in hardship, or under dispute.

Billing accuracy and estimation

Bills must be based on actual meter data where available, estimates must be identified and justified, and undercharging and overcharging both carry prescribed remedies with limits on how far back a retailer can recover.

With five-minute settlement and widespread interval metering, the practical problem is less about reading the meter and more about what the system does when data is missing, substituted or revised after the fact. A revision to MSATS data weeks after a bill has issued is normal; a billing system that cannot re-rate cleanly and produce an adjustment that explains itself is not.

Best offer and plan information

Retailers must tell customers, on their bills at prescribed intervals, whether a better plan is available to them. It sounds like a messaging requirement. It is really a rating requirement: to know whether a better plan exists, the system has to re-rate the customer's actual consumption against the retailer's current offers — every time.

The AER is actively reviewing its guidelines

The AER has a program of retail guideline reviews running through 2025 and 2026, alongside the Retailer of Last Resort guidelines review. Requirements will move. That argues for building compliance as configuration the system enforces — thresholds, notice sequences, protected states — rather than as logic hard-coded by a vendor on a release cycle you do not control.

The underlying question

For any obligation, ask three things. Can the system do the prohibited thing at all? If a protection applies, does every path respect it, including bulk and automated ones? And can you produce the evidence for a period, as a set, without a data project?

Where the answers are no, yes and yes, compliance is a property of the platform. Where they are not, it is a property of how careful everyone was that month.