AGL provides feedback on the ESC's 'Getting to Fair: Advancing Equity' Consultation

AGL broadly supports the Commission's next iteration of its Consumer Vulnerability Strategy which aims to improve equitable access to essential services but emphasises the need to balance social policy objectives with evidence-based, economically grounded regulation.

AGL's submission highlights key considerations including the importance of maintaining clear and practical definitions of consumer vulnerability, ensuring regulatory responses are proportionate and data-driven, and avoiding overly broad or subjective interpretations of “just outcomes” that may shift costs inequitably across customers.

AGL advocates for principles- and outcomes-based regulation to support innovation in the evolving energy market, particularly amid the energy transition, and calls for greater transparency, robust data analysis, and collaborative engagement across regulators, industry and stakeholders.

The submission also identifies gaps in guidance for engaging vulnerable and disengaged customers, including First Nations communities, and underscores the need for improved measurement, reporting, and capability uplift to ensure the strategy delivers measurable, sustainable improvements for Victorian energy consumers.

Read the full submission (PDF).