Submission to The Treasury on Regulatory Impact Assessment of Fees for Paper Bills

COTA Australia appreciates the opportunity to provide brief comments to Treasury regarding its Consultation Regulatory Impact Statement (RIS) on fees for paper bills, further to meeting with Treasury officers in December 2017 to discuss the paper and issues.

This consultation is significant for older Australians, who are disproportionately not online and who have lower levels of digital literacy than younger age cohorts. COTA hears regularly from members and older consumers who are alarmed and indignant at having to pay a fee to receive a commercial bill in paper form – either the only format they can access and/or the format with which they are confident and literate and which they trust. The monetary cost is also significant for many older Australians, who generally manage on very low incomes and extremely tight budgets. A couple of $3 fees on paper bills may be an annoyance to someone on the average wage, but to an age pensioner it can cost an outing with a friend forgone or a small treat for a grandchild.

COTA is repeatedly on the record as calling on the Australian Government to:

  • recognise that there will be a group of older people who will not ever access the internet (as well as in other age cohorts);
  • ensure that they are not penalised with social exclusion or second-class service delivery;
  • use regulatory and policy levers to ensure appropriate, sustainable and adequately resourced non-digital systems, including face-to-face, phone and paper based communications (at no extra cost to the consumer) are in place for people who are unable to access digital services.

Therefore, at the outset of this brief submission we wish to state that COTA Australia strongly supports Option 2: Ban fees on paper bills in the RIS Consultation Paper. We expand briefly below on our reasons for taking this position, but a key consideration for COTA is that billing is part of the business process and should be included in pricing. The fact that new technology used by many, but not all, customers becomes available and is cheaper for the provider does not mean that customers without that technology should be penalised.

The fact that a business or service provider is able to make a charge or place a condition of service on a customer that it is impossible or difficult for the customer to avoid is not a justification for that practice. COTA contends that it is not fair and reasonable for a provider to bill a consumer for using one method of payment over another when that method is indeed universally available and alternate means are not, and indeed require the consumer to incur costs to make payment.

Regarding the additional options provided in the Treasury paper, COTA strongly holds the view that:

  • Option 1 – status quo with industry education – is not acceptable for the range of equity reasons outlined below in this submission;
  • Option 3 – a ban on fees for paper bills in essential services – is a significant compromise on Option 2, but if Option 2 is not pursued, then Option 3 will require careful consideration and consultation about what constitutes an essential service, and we draw your attention to our response to the consultation question on this issue, below on P6; and
  • Option 4 – limiting fees to cost recovery – is inferior to both Options 2 and 3 and should only be considered in conjunction with an extension and promotion of exemptions as per Option 5. That said, we regard it as unconscionable that fees should be charged at above cost recovery; that is clearly a punitive action directed at people without access to online capacity.