Sociologist from Malta

Tuesday, November 20, 2018

ARMS Utility Bills: Letter to Maltese and EU Authorities



The CEO EneMalta

The CEO Water Services Corporation

The Malta Competition and Consumer Affairs Authority

The Competitions Officer,
The Consumers’ Office,
The Regulator for Energy and Water Services,
The European Commission Representation in Malta 

The European Commissioner for Competition

The European Commissioner for Energy

Dear Sirs, Madams,

In the past years and especially months, the situation with water and electricity billing in Malta has raised concerns about unfair billing practices, abuse of dominance, state-aid, discrimination among consumers and business, and more recently links with offshore business. Individual queries seem to be sending customers and journalists in circles. I am therefore writing to you all together and publicly in the hope of understanding the status and the regulation of the sector.  I will be sharing this letter publicly, as I will be sharing any answers you would care to provide, when and if you would care to provide them.


Is it legal for ARMS ltd to reduce the annual quotas foreseen in the legal notice by bulking prior period consumption into shorter billing periods or by rationing the annual quota into discreet short-period quantities?

Is the ARMS billing procedure clear and understandable to Maltese households?

How many billing queries have ARMS ltd received annually since operation?

Threats of cut off:

Do customers have the right to contest a bill without paying interest or risk of cut-off?

How are they to do this?

Loans, interest rates and ad hoc fees:

At what rate is ARMS entitled to charge interest on loan facilities?

Is Arms entitled to create and impose ad hoc fees that are not foreseen in the law (e.g. 13% to revise a bulking error)


Is ARMS entitled to discriminate between residents on the basis of the type of accommodation they live in (Domestic vs Resident)?

Why do non-residents pay less per unit at higher consumption while residents pay more per unit?

Can ARMS cross-subsidise one group of users by another? 

Is it acceptable that residents are put on different billing periods (2 month vs 6 month) when these result in material differences to the rate applicable?

Ownership and regulation:

Who do Enemalta, the Water Services Corporation belong to?

Who does Arms ltd belong to?

Which entity regulates EneMalta, WSC and ARMS?

Looking forward to your reply,

Dr Michael Briguglio

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