Published on 20 Aug 2025

Strengthening Consumer Protections: Review of Consumer Advocacy Council

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Nick Leffler Organisational Design + Change Lead Contact me

When the Electricity Authority conducted its review in 2023, it discovered what many consumer advocates had long suspected – retailers were inconsistently following voluntary guidelines meant to protect consumers. This reality stood in stark contrast to regulators' previous confidence that electricity companies would "do the right thing" without mandatory requirements.

The Consumer Advocacy Council, established to give small electricity consumers a voice following the Price Review, needed robust evidence to drive change. They engaged Allen + Clarke to identify specific gaps in New Zealand's consumer protections and provide practical recommendations for improvement.

Building a comprehensive picture of the current landscape

Our assessment used a multi-faceted methodology to build a comprehensive picture of the current landscape. 

This approach revealed that New Zealand's consumer protection framework significantly lagged behind international standards. Particularly concerning were gaps affecting medically dependent consumers and households experiencing energy hardship. 

Our approach included:

  • Website Generic Icons 1200x1200 GREEN 31 In-depth interviews with key stakeholders to understand frontline issues.
  • Website Generic Icons 1200x1200 GREEN 31 Detailed review of New Zealand's regulatory framework.
  • Website Generic Icons 1200x1200 GREEN 31 Comparative analysis of international approaches from Australia, UK, EU, Canada and others.
  • Website Generic Icons 1200x1200 GREEN 31 Development of an evaluation framework with clear criteria for assessing options.
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Key Takeaways from our analysis

  • Voluntary guidelines without compliance monitoring resulted in significant protection gaps for New Zealand's most vulnerable electricity consumers. 

  • International jurisdictions offered proven models for stronger consumer protections, particularly for medically dependent and households in energy hardship. 

  • Mandatory minimum standards would ensure consistent protection across all retailers and reduce risks of disconnection. 

  • Better data collection, particularly around prepayment services, is needed to understand the full extent of issues facing vulnerable consumers. 

  • Transparent, accessible information and independent price comparison tools are essential for consumers to make informed choices. 

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