Balancing rights and markets: Towards a typology and critical review of residential electricity disconnection prohibitions in France, Spain, Ireland and Australia

This article explores the contested issue of electricity disconnection prohibitions through the economies of worth framework. Residential electricity disconnections for non-payment can negatively affect mental, social and physical wellbeing. Debates in the European Union and Australia reveal differing perceptions of what is fair and legitimate. Consumer advocates seek the right to electricity, while policymakers also value the electricity markets' economic sustainability. Recent mandates to review consumer protection mechanisms aim to better align these concerns, yet there is little information on how competing principles of legitimacy may be resolved. To address this gap, this narrative literature review examined electricity disconnection prohibitions for bill-paying household customers in France, Spain and Ireland, which are often seen as model examples, and Australia. The study explored how current (as of February 2025) disconnection bans were configured, to whom they applied and under what circumstances. Our findings indicate that disconnection bans can be grouped into mandatory, permanent or temporary, prohibitions as ‘compromises’ between civic and market principles, mitigating immediate health risks, and voluntary restraints as ‘arrangements’, contingent on the goodwill of retailers. Governments and industry increasingly acknowledge the role of affordable, uninterrupted electricity services for well-being and incorporate social obligations and hardship safeguards alongside their commercial operations. Recommendations address eligibility criteria, collaborations with intermediaries, consideration of local contexts and additional financial support mechanisms. Understanding the plurality of values that decision-makers need to balance regarding the right to energy enables advocates and scholars to advocate for fairer, context-sensitive pathways that reflect and legitimate diverse forms of worth. • Application of the ‘economies of worth’ framework to disconnection bans • Cross-national review of residential electricity disconnections prohibitions • Identifies characteristics and develops a typology of disconnection bans • Contributes to debate on strengthening and homogenising consumer protection • Recommendations to improve policy reach and equity