Energy Retail Customer Hardship, Payment Plan or Concession Record

Energy retailer customer records about hardship, payment plans, concessions and vulnerability. The National Energy Retail Law requires each retailer to have a customer hardship policy (s 43) meeting minimum requirements (s 44), and National Energy Retail Rules Part 3 (rr 70A-75B) sets out hardship customer obligations: informing the customer of the policy (r 71), payment plans set by capacity to pay, arrears and expected consumption (r 72), waiver of late payment fees (r 73), Centrepay (r 74) and the AER Customer Hardship Policy Guideline (r 75A). Queensland Government energy concessions (Electricity Rebate, Reticulated Natural Gas Rebate, Home Energy Emergency Assistance Scheme, Medical Cooling and Heating Electricity Concession Scheme) are applied through the retailer on proof of a Pensioner Concession Card, Health Care Card, Veteran (DVA) Gold Card, Queensland Seniors Card or ImmiCard. Records tie an account holder, customer or account number, NMI/MIRN or supply address to hardship program status, arrears, concession card details, payment plan amounts and "personal circumstances" notes. The incident class is a retailer's outsourced call-centre compromise exposing customer circumstances notes and government concession numbers. Published hardship policies, the AER guideline, blank applications and news are decoys.

Type: regex
Engine: boost_regex
Confidence: medium
Confidence justification: Medium: NERL/NERR hardship terms and the Queensland concession scheme names are distinctive, but every retailer must publish a hardship policy containing the AER guideline's standardised statements and concession pages list the same cards, so enforce tiers need a populated account field plus a populated hardship, concession or detail field, and policy, guideline and news wording is excluded. The CRN shape (nine digits and a letter) and DVA file number shape are reused from au-centrelink-crn and global-dva-file-number and have no checksum; retailer account numbers are organisation-defined, so account values are loose and placeholder-guarded. Water and council hardship records with the same fields can reach 75 here; the 85 tier needs energy-account evidence. 85/75 are heuristic evidence tiers, not measured accuracy; test values are synthetic.
Jurisdictions: au
Regulations: National Energy Retail Law, National Energy Retail Rules, AER Customer Hardship Policy Guideline, Privacy Act 1988 (Cth), Information Privacy Act 2009 (Qld)
Frameworks: QGISCF
Data categories: financial, pii, government-id
Scope: narrow
Risk rating: 7
Platform compatibility: Purview: Compatible, GCP DLP: Compatible, Macie: Unsupported, Zscaler: Compatible, Palo Alto: Degraded, Netskope: Unsupported

Pattern

(?i)\b(?:hardship\s+(?:customers?|program(?:me)?s?|plans?|flags?|status|team|assessments?|applications?|arrangements?|cases?|payment\s+plans?)|(?:energy|electricity|gas)\s+(?:hardship|concessions?|rebates?)|(?:customer|financial|energy)\s+hardship\s+(?:record|note|referral)s?|Reticulated\s+Natural\s+Gas\s+Rebate|Home\s+Energy\s+Emergency\s+Assistance(?:\s+Scheme)?|HEEAS|Medical\s+Cooling\s+and\s+Heating\s+Electricity\s+Concession(?:\s+Scheme)?|MCHECS|concession\s+(?:card\s+(?:holder|details|number|type)|eligibility|status)|personal\s+circumstances\s+(?:note|notes|flag)|vulnerab(?:le|ility)\s+(?:customer|flag|indicator|marker|note)s?)\b

Corroborative evidence keywords

hardship program, payment plan, Pensioner Concession Card, Health Care Card, Electricity Rebate, personal circumstances, Centrepay, NMI

Proximity: 300 characters

Should match

Hardship program review - residential electricity Customer number: 5502918844 NMI: 3120456789 Hardship status: active Concession card type: Pensioner Concession Card Concession card number: 301 456 789K Payment plan amount: $35 per fortnight Personal circumstances: recently widowed, caring for grandchild, reduced hours at work — Hardship review with customer number, NMI, status, concession card number, payment plan and circumstances note (85 tier)
Account note - vulnerable customer Account holder: Morgan Teston Supply address: 27 Banksia Street, Rockhampton QLD 4700 Rebate applied: Electricity Rebate DVA file number: QX123456 Arrears: $1,106.40. Gas and electricity accounts both placed on disconnection hold. — Vulnerable customer note with account holder, supply address, rebate, DVA file number and arrears (85 tier)
Customer hardship team referral Account number: EA-7730-1182 Hardship program: enrolled 03/09/2026 — Hardship referral with an account number and program status, no detail field (75 tier)
Electricity Rebate eligibility check - customer number: 8841120937, card type: Health Care Card. Rebate will show on the next bill. — Rebate eligibility check with a customer number and card type (75 tier)

Should not match

AER Customer Hardship Policy Guideline. Retailers must include the standardised statements, such as: We will offer you a payment plan that takes into account your capacity to pay. A retailer must inform a hardship customer of its hardship program. Hardship status: active customers are reported under the hardship program indicators. — AER guideline text (excluded)
Our hardship policy is published on our website. If you hold a Pensioner Concession Card or Health Care Card you may be eligible for the Electricity Rebate. Our hardship program can offer a payment plan, Centrepay and waiver of late payment fees. — Retailer hardship policy page (65 only / excluded)
Electricity Rebate application Account holder: ______________ NMI: __________ Concession card number: __________ Card type: [ ] Pensioner Concession Card [ ] Health Care Card Payment plan amount: $______ — Blank rebate application (65 only)
An energy retailer confirmed that concession card numbers and notes about customers' personal circumstances were accessed through an outsourced call centre, the company said in a statement. — Breach news report (65 at most)

Known false positives

Published retailer hardship policies (NERL s 43) and the AER Customer Hardship Policy Guideline's standardised statements. Mitigation: Policies describe the program without populated account fields; policy, guideline and Law/Rules wording is excluded.
Queensland Government concession pages and blank rebate application forms. Mitigation: Placeholder-guarded fields; the shared template-exclusion dictionary and you may be eligible wording.
Water, council rates and telco hardship records with account and arrears fields. Mitigation: These can reach 75 (same harm class); 85 needs an energy-account term. Water and council records are covered by au-qld-water-customer-hardship-restriction-record and au-qld-council-rates-concession-hardship-application.
News reports about utility breaches or hardship statistics. Mitigation: Excluded on said in a statement and told reporters; news seldom carries populated account fields.