The following list summarises family violence obligations for retailers as of February 2025.

1. Family Violence Policy Development and Implementation

• Develop and maintain a family violence policy outlining how affected customers will be identified and assisted, including the application of protections. (ESC Clause 157-159, AER Rule 76A(a))
• Publish the family violence policy on the retailer’s website, ensuring it is easily accessible. (ESC Clause 157-159, AER Rule 76A(b))
• Implement, maintain, and comply with the family violence policy. (AER Rule 76A(c))
• Regularly review and update the family violence policy at least once every two years or to align with best practices. (ESC Clause 157-159, AER Rule 76A(d))
  
  

2. Staff Training and Capability

• Ensure training is provided to all relevant staff, including employees, agents, contractors, managers, and individuals responsible for customer interactions and processes. (ESC Clause 149, AER Rule 76B)
• Training must cover: 
  • The nature and consequences of family violence.
  • Application of the retailer’s family violence policy.
  • Identification of affected customers.
  • Appropriate and effective engagement with affected customers.
    
    

3. Customer Identification and Engagement

• Implement a secure process to assess if a customer is affected by family violence, identify their account, and avoid repeated disclosures. (ESC Clause 151, AER Rule 76C)
• Ensure effective, ongoing engagement with affected customers. (ESC Clause 151)
• Prioritise the safety of affected customers and consider their specific circumstances in all interactions. (AER Rule 76D)

4. Account Security and Privacy

• Do not disclose or provide access to confidential information about an affected customer without their consent, except as required by law. (ESC Clause 150, AER Rule 76G)
• Take reasonable steps to determine and use the affected customer’s preferred method of communication. (ESC Clause 150, AER Rule 76H)
• Offer alternative communication methods if the preferred method is not practicable and keep a record of communication arrangements. (ESC Clause 150)

5. Recognition of Family Violence as a Cause of Hardship

• Recognise family violence as a likely cause of a customer experiencing payment difficulties or being a hardship customer. (ESC Clause 153, AER Rule 76E)

6. Debt Management and Payment Assistance

• Before taking action to recover arrears, consider: 
  • The potential impact of debt recovery on the affected customer.
  • Whether other persons are responsible for the debt. (ESC Clause 152, AER Rule 76F(1))
• Waive any late payment fees for affected customers. (AER Rule 76F(3))
• Allow affected customers to use Centrepay as a payment option. (AER Rule 76F(4))

7. Documentary Evidence

• Only seek documentary evidence of family violence when considering debt management, recovery, or restrictions on disconnection. (ESC Clause 155)
• Do not require documentary evidence of family violence from affected customers or third parties acting on their behalf. (AER Rule 76I)

8. Support Services Information

• Provide affected customers with information about external family violence support services in a safe, respectful, and appropriate manner. (ESC Clause 154, AER Rule 76J)
• Publish and keep updated a list of external family violence support services on the retailer’s website. (ESC Clause 154)

9. Contractual Compliance

• Ensure compliance with family violence obligations does not breach customer retail contracts. (AER Rule 76K)
• Ensure market retail contracts are consistent with the family violence policy. (AER Rule 76L)

10. Record Keeping and Compliance

• Maintain records sufficient to evidence compliance with family violence obligations. (ESC Clause 160)
• Retain records for at least two years, or as long as the affected customer continues to receive assistance, or until any related complaint or dispute is resolved. (ESC Clause 160)