Customer trust is built into every bill

Why stronger customer protections require billing controls that retailers can explain and prove. 

Mark Humphreys – Chief Revenue Officer, APAC

Billing systems have always had to accommodate regulatory requirements. Tariff rules, tax treatment and payment terms have been built into them for decades. What has changed is the kind of obligation they are now expected to manage. 

Regulators in New Zealand and Australia increasingly ask retailers to work out what each customer is entitled to under the rules, act on it, and show how they reached the outcome. Which plan would be cheaper for this household? How far back can this charge be recovered? Was the customer told? These are personalised calculations, run on every account, with a record behind each one. 

That moves much of the work of customer protection into the systems that calculate, control and evidence each bill, alongside metering, customer communications and case management. Policy still matters, but it is no longer enough on its own. For retailers, the design of billing controls has become a matter for executive attention, not only for IT. 

New Zealand and Australia 

New Zealand’s billing reforms begin to be introduced from 30 October 2026. Once fully in force, retailers must check at least annually that residential customers are on the best plan they offer, prompt customers towards the independent comparison service Billy, and limit most back bills to six months (Electricity Authority). Until now, New Zealand has had no regulated cap on back-billing. 

Retailers have until 1 April 2027 to implement the full package, and individual obligations follow their own commencement dates. The Authority extended the deadline by five months, acknowledging the complexity of changing core billing systems, often involving multiple systems (Electricity Authority). That is a clear acknowledgement from the regulator that these protections depend on system change. 

For customers, these protections address a familiar problem.  Many households rarely look at their energy plans even when an introduction discount has ended or their circumstances have changed. They can remain on tariffs that are no longer competitive, often without realising a cheaper option is available.  
 
At a time when household budgets are under pressure, the ability to identify and communicate a better plan can make a meaningful difference. It shifts some of the responsibility from customers having to find a better deal themselves to retailers proactively helping them understand their options.  

Australia has been on this path for longer. In the jurisdictions covered by the National Energy Retail Rules, the AER’s Better Bills Guideline requires retailers to run a better offer check against each small customer’s usage and show the result prominently on their bills. Victoria applies its own retail rules. 

Both markets are moving in the same direction. Protections are calculated from each customer’s own data and applied across the whole customer base. Retailers are expected to be able to show how each outcome was reached. 

Where procedures fall short 

A better plan check or a back-billing limit is a calculation. It runs against each customer’s usage, tariff and history, at scale and to a deadline. Across a large customer base, a written procedure and a trained team cannot apply it reliably on their own. 

Australia has already seen what happens when the calculation goes wrong. After the Better Bills Guideline came into force, the AER found many retailers non-compliant. Some had self-reported miscalculating the better offer by leaving required factors out. The AER recommended regular audits of the code behind the calculation and stress-testing it across a wide range of scenarios. 

If a regulator is recommending code audits, oversight cannot stop at the procedure manual. The obligation is set out in a Code or a Guideline, but much of the evidence that it was met sits in the systems that produce the bill. 

The scale of the risk is different too. An individual handling error may affect one account. A faulty system rule can repeat across every account it touches until someone detects it. 

Controls at the point of billing 

In practice, this means checking the rule when the bill is produced, holding exceptions for review and recording how each one was resolved. Two capabilities in Gentrack’s g2 illustrate the approach. 

Plan comparison. Utility Operations compares every plan a customer is eligible for, either on demand or in the background. It shows the best option to service agents and on regulated communications. This supports the obligation to tell customers about cheaper plans without relying on manual checks. 

These controls support compliance, but they don’t remove the need for appropriate oversight. They identify cases that need attention and give staff the information to resolve them before the customer is affected. 

An example. A meter fault is corrected, and the new data shows a customer has been undercharged for eleven months. Without a control, the correction flows straight onto the next bill, including charges the retailer is no longer allowed to recover. This could lead to a customer complaint, further corrections and potential regulatory remediation. 

With a control, the platform identifies the charges outside the permitted period and holds the bill. An operator reviews it, removes what cannot be recovered, and the decision is recorded before the bill reaches the customer. The benefit is fewer avoidable complaints, less rework and lower exposure to remediation. 

Five questions boards and executives should ask about billing systems and regulatory compliance: 

1. Which customer protection and regulatory compliance obligations are enforced by our energy retail billing system, and which still depend on people following a procedure? 

2. If a regulatory requirement changes, how long does it take to reconfigure our billing platform, and who signs off the change? 

3. Can we demonstrate to a regulator why an individual customer bill was issued, held or adjusted, with a clear audit trail? 

4. How do we test the calculations behind regulated customer communications, such as the New Zealand better plan check, before and after each release? 

5. If our billing system makes an error, how quickly would we know, and how many customers would be affected? 

What comes next 

Back-billing limits and better plan checks are unlikely to be the last protections of this kind. Further rules will raise the same questions: whether the platform can apply them consistently, and whether the retailer can show that it did. 

As AI tools take on more account analysis and customer contact, the need for reliable billing controls and accountability will only increase. These tools must work from accurate billing data, operate within defined permissions and maintain a record of their actions. 

Ultimately, these protections are about more than meeting regulatory obligations.  They are about giving customers confidence that their retailer is looking out for their interests, not simply calculating what they owe. 
As customer protections become increasingly embedded in technology, boards need confidence not just in their policies, but in the systems enforcing them. 

Sources 

Electricity Authority: Billing reforms introduced from 30 October

Electricity Authority: Better billing toolkit

Electricity Authority: Code amendment omnibus #7

AER: Better Bills Guideline (Version 2)

AER: Better Bills Guideline compliance review, 1 October 2024