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NCOSS's response to the final round of consultation addresses remaining concerns with the Australian Energy Regulator's draft Hardship Policy Guideline. NCOSS notes that the Australian Energy Regulator should define the concept of 'hardship' as the Essential Services Commission has done in Victoria in order to capture all people in 'payment difficulty'. This submission further suggests that the Australian Energy Regulator has both the power and responsibility to provide guidance and direction to electricity retailers when assessing hardship policies. NCOSS suggests specific alterations that will strengthen the draft Guidelines and standardised statements for electricity retailers and their customers.