Municipal mysteries: When “actuals” aren’t “actuals”

municipality readings
07 Sep 2018


This article canvases what consumers can do to protect themselves when a municipality is charging them according to “actual” readings for electricity or water consumption, but where the readings used by the municipality are clearly not ‘actuals’ and thus cannot be true and proper readings.

Actuals versus Estimates

There are two types of readings that a municipality can use to bill a consumer for metered consumption for electricity and water. The first is an “estimated” reading, which is where the municipality does not actually go to your property and take a reading from the meter at your property but rather uses an algorithm to guess how much electricity or water you have consumed. This is contrasted with an “actual” reading, which is used to bill a consumer when a meter reader has been to the property and has physically taken a reading from the meters at the property, or when there are “smart” meters at the property transmitting the readings to the municipality periodically.

Inaccurate Estimated Readings

If you have received an invoice with estimated readings that are wildly out of kilter with the reading as it appears on your meter, then you need to raise a billing query with the municipality concerned and ask that it verify your actual readings, and bill you accordingly.

Inaccurate “Actual” Readings

The focus of this article, however, is not to deal with scenarios where consumers are billed on estimates, but where they are billed on “actuals” that are not correct. This might have happened because the smart meter is not working properly and incorrect readings have been transmitted to the municipality, or because the meter readers have applied the incorrect readings to the meters (i.e. they have “mixed up” meters and meter readings), or because the meter reader has incorrectly recorded the actual readings from the meter.

These types of errors are difficult to fix because certain municipalities (such as Johannesburg) will often tell consumers that they are not allowed to raise a query disputing “actual” readings, because to their minds there is no query to raise – on their systems the meter reading reflects as an actual reading and is thus correct.

This is unlawful – a municipality cannot lawfully refuse to allow a consumer to log a billing query or dispute simply on the basis that what appears on the municipality’s system is correct and the consumer therefore must be wrong, because (logically) the possibility always exists that the municipality’s system is wrong and that the consumer is right.

If this happens to you, and you are not permitted to log a query with Johannesburg municipality, keep proof that you have attempted to log the query and then proceed on to the next ‘step’ in the municipality’s prescribed dispute resolution procedure, which is to deliver a written complaint to the municipality. We would advise outlining in the written complaint that you had attempted to log a query but were unable to do so due to the refusal of the municipality’s consultants to allow this to happen. It is also advisable for a person trying to log such a query, to obtain an interaction number from the municipality which will serve as proof of the attempt to log a query. The municipality will not issue you with a reference number for the query if it is not of the view that it is a valid query and so the interaction number is the next best thing that a consumer can keep as proof of the attempt in logging the query.

Deemed Readings

A deemed reading occurs where the municipality is adjusting a consumer’s account to bill the consumer for a guestimate of consumption in the situation where the meter was not working at all, or was faulty, or where there was no meter. In these kinds of situations, there is no actual and/or reliable recording of the consumption at the property, and so the municipality does an extrapolation to guess what the consumer’s consumption was. The municipality will normally install a new (functioning) meter, take three month’s readings, and then calculate the average and apply it to the period where there were no accurate/reliable readings. Deemed readings appear on invoices in Johannesburg as ‘actual’ readings and this makes it very confusing for consumers who can clearly see that the reading indicated on their invoice cannot possibly be correct – for example in the situation where the meter has been removed from the property but the municipal invoice indicates that it is billing the consumer on an actual reading for a period after the meter was removed.

If the problem is that the reading on your invoice is a “deemed” reading, then the first thing you need to do is ascertain from the municipality, the basis of the calculation for that deemed reading and determine whether that calculation is arithmetically correct and whether it is fair. If it turns out that there is either a calculation error or that the municipality has loaded the account with unfair charges, then the consumer can follow the standard dispute resolution process provided for by that particular municipality in taking it up with them. This would include first logging a query (but if you are not permitted to log a query because the municipality’s system says that the reading is an ‘actual’, then skip this step as advised above).


In the event that you discover that the actual (or deemed) readings on the account are not correct, and you have difficulties in resolving any billing dispute resulting from this problem with the municipality, you may need to contact an attorney for assistance because it can be difficult to navigate the many laws and procedures prescribed in order for resolving these kinds of disputes.

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(This article is provided for informational purposes only and not for the purpose of providing legal advice. For more information on the topic, please contact the author/s or the relevant provider.)

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