Frank Energy
Assessed 16 July 2026 under NZ · High confidence
Evidence last captured 30 August 2026 · next re-check due 30 August 2027
We contacted this company 2 times between 6 August 2026 and 12 August 2026, by email and phone. No reply received.
A grade rules on whether a public claim is substantiated. It is not a finding about environmental performance, truthfulness, or the merit of the business. HowLegit is not a licensed adviser and nothing here is legal or investment advice.
Where this sits
All 21 energy companies, assessed against the same checklist in the same window.
Frank Energy ranks 11 of 21 in this sector by overall score, between 47.6% and 96.0%.
Findings
The Ecobulb campaign page states LEDs use "up to 90% less electricity than older model light bulbs". No comparator bulb is specified and "up to" sets a ceiling rather than a typical level, so the figure cannot be checked against anything.
Why this matters. A percentage saving with nothing named as the comparison cannot be checked by the customer it is offered to. The same page shows Frank can be specific when it chooses to be.
What closing this looks like
- State what the 90 per cent efficiency figure is measured against
“An energy-efficiency saving is stated as a percentage against an undefined comparator and with an unbounded qualifier.”
An efficiency claim in percentage form with nothing to measure it against. "Older model light bulbs" names no comparator, and "up to" sets a ceiling rather than a level, so the figure is true of the best case and says nothing about the typical one. The page elsewhere shows it can be specific: the monetary saving on the same page carries its full calculation. ISO 14021 asks that a comparative environmental claim state what it is compared with. Established across the full published estate: 63 addresses in the sitemap plus navigation enumeration to a stable total of 65, of which 84 surfaces and 9 documents were read, checked 17 August 2026.
Captured 30 August 2026 · source page ↗
"Trusted by 90,000 customers" appears unchanged since the 2021 launch while media sources reported 100,000-110,000 during operation. "94% satisfaction rating" from Consumer NZ People's Choice (2023-2024) lacks temporal qualification -- Consumer NZ withdrew all electricity sector awards in 2026.
Why this matters. Two figures that customers are most likely to check, the customer count and the satisfaction rating, are the two that carry no date. Both were accurate once.
What closing this looks like
- Date or remove the two figures customers are most likely to check
“Customer service is presented as locally staffed and located in Hamilton.”
The location is named and the team is described as local, which makes the claim checkable rather than atmospheric. Frank's own media release places the head office and service team in Hamilton, and no surface in the estate contradicts it. Established across the full published estate: 63 addresses in the sitemap plus navigation enumeration to a stable total of 65, of which 84 surfaces and 9 documents were read, checked 17 August 2026.
Captured 30 August 2026 · source page ↗
“Operating history is presented by reference to the predecessor brand's launch date.”
The claim is anchored to a dated event, the launch of the predecessor brand, rather than to an unqualified assertion of experience. Energy Online was acquired by Genesis in December 2002, which supports the stated period.
Captured 30 August 2026 · source page ↗
“Consumer NZ People's Choice Award recognition is claimed for two named years.”
Both award years are named on the surface where the claim is made, so a reader can date the recognition without leaving the page. The awards were independently conferred by Consumer NZ and are verifiable against its published results.
Captured 30 August 2026 · source page ↗
“A customer-count figure unchanged since the 2021 launch is presented in the present tense on live pages.”
The figure has not changed since the 2021 launch release and is presented in the present tense on pages that are still live. Media reporting through the operating period put the customer base higher, so the number is most likely conservative rather than inflated, but a figure carried unchanged for four years and stated as current does not tell a reader what it is measuring or when it was measured.
Captured 30 August 2026 · source page ↗
“A satisfaction figure from a superseded survey is presented without the date of the survey it came from.”
The percentage is real and was accurate when the award was made. What is missing is the date: the surface says "Consumer's latest survey" without naming the year, and Consumer NZ has since withdrawn the electricity award entirely on the basis that no retailer met its threshold. A reader meeting the figure today cannot tell which survey it came from.
Captured 30 August 2026 · source page ↗
Privacy Policy discloses AI use for service delivery and routine process automation but does not specify which processes are AI-driven, what data feeds the AI, or what consumer rights exist regarding AI-assisted decisions.
Why this matters. Customers are told AI is used but not where. Without knowing which decisions it touches, a customer cannot tell when to ask for a human to look again.
What closing this looks like
- State in the Privacy Policy which processes are AI-driven, what customer data feeds them, and how a customer can ask for a human review of an AI-assisted decision, so a disclosure that currently names the technology also tells a customer what it does to them.
“A complaint resolution timeframe is stated with a named escalation route.”
A specific number of working days is committed to, the escalation route to Utilities Disputes is named and free, and the page states what happens if the timeframe cannot be met. That is a checkable undertaking rather than an assurance.
Captured 30 August 2026 · source page ↗
“The Privacy Policy carries a stated revision date.”
The policy carries a revision date on its face, which lets a reader establish which version they are reading. Note the version assessed during grading was superseded before capture; the date shown is the current one.
Captured 30 August 2026 · source page ↗
“AI use is disclosed by category of purpose without identifying which processes are AI-driven or what rights attach to an AI-assisted decision.”
The disclosure is present and its presence is to Frank's credit. What it does not do is let a reader work out where AI touches their own account. The purposes are given as categories, no process is identified as AI-driven, the data feeding the systems is not described, and no route is offered to question a decision an AI system contributed to. The Privacy Act 2020 transparency principles set the expectation that a person can tell how their information is used.
Captured 30 August 2026 · source page ↗
The wording "a fiercely independent bunch with our own customer service teams, simple plans, pricing, our own ambition and attitude" remains in the present tense on the brand identity page while the brand is being absorbed into Genesis. Consumer NZ People's Choice recognition for 2023 and 2024 remains on live pages after Consumer NZ announced on 3 June 2026 that it would make no energy award this year because no retailer met its threshold.
Why this matters. A brand built on directness is being wound down, and the wording that described it as independent is still in the present tense on the page customers visit to find out who they are dealing with.
What closing this looks like
- Publish a closure notice on every channel with an active audience
- Note beside the award years that Consumer NZ made no energy award in 2026
- Publish a dated statement of Frank's current structure at the top of the brand identity page
“An independence claim remains on the brand identity page while the brand is being absorbed into its parent.”
The ownership position is disclosed in the same sentence, and the independence asserted is expressly operational: service teams, plans, pricing, ambition and attitude. Read as written, in 2021, it was accurate. The difficulty is temporal rather than structural. The brand is being absorbed into the parent, the operational separation the sentence describes is being dismantled, and the sentence is still live in the present tense on the page a reader visits to find out what Frank is.
Captured 30 August 2026 · source page ↗
“Award recognition earned in two named years remains on live pages after the award programme was withdrawn for the sector.”
The awards were earned and the years are named. Consumer NZ announced on 3 June 2026 that, for the first time in over a decade, it had decided not to award an annual People's Choice accolade to any energy retailer, and its campaigns manager Jessica Walker stated that no retailer met the threshold of having both highly satisfied customers and Consumer NZ's backing. Consumer NZ's own award page still lists Frank Energy as a licensed business, so the display itself is licensed. What it no longer signals is current standing, because the programme that confers it made no award to any retailer in the sector this year. Consumer NZ also records Frank as holding the award in 2023, 2024 and 2025, one year more than the page claims.
Captured 30 August 2026 · source page ↗
The migration FAQ answers "How much will I pay with Genesis?" by directing customers to the Genesis address lookup and to Powerswitch, without stating the price effect. PowerCompare's published comparison of one Auckland household puts it at 11 per cent, or $145.56 a year. A price-positioning claim remains live on pages customers read during the migration.
Why this matters. Customers are being moved without choosing to move. Frank gives them two routes to find out what it costs and does not tell them the answer.
What closing this looks like
- Give migrating customers the figure, not only the route
“The migration FAQ answers a direct question about cost by routing the reader to two external tools rather than stating the price effect.”
The answer does route the reader onward, twice: to the address lookup that returns a table of plan options and rates, and to the independent comparison service. That is more than a bare statement and it should be credited. What it does not do is tell a customer being moved without choosing to move what the move costs them. PowerCompare publishes a worked comparison, retrieved on 30 August 2026 at powercompare.co.nz, for an Auckland two-bedroom home using 299 kWh over 30 days: 25.50 cents per kWh with Frank against 29.55 cents on the Genesis Flexi plan at the same daily charge, which PowerCompare states is an 11 per cent increase in the monthly bill and $145.56 a year. That is one worked example rather than a population estimate, and it is the kind of figure the party conducting the migration is better placed to produce than the customer being migrated.
Captured 30 August 2026 · source page ↗
“A price-positioning claim remains on live pages through a migration to a different provider's rates.”
A price-positioning claim stated in the present tense continues to appear on pages a customer reads while being migrated to a different provider's rates. The claim was about Frank's pricing and Frank's pricing is ending.
Captured 30 August 2026 · source page ↗
"Two simple plans, no fixed term contracts or exit fees" is substantiated by the Standard Terms and Conditions and the published fee schedule, and the plan thresholds are stated with their regional variation. The 2021 launch release promises "no contracts and best rates first time", a superiority claim with no comparison published behind it. Sign-up calls to action remain live across the site, two of them stating a maximum sign-up time, and every one of them routes to a page that says new customers are not being accepted.
Why this matters. The contract terms are clear and hold up. The rate claim beside them does not, and a customer following the sign-up button is invited into a process that has been closed for over a year.
What closing this looks like
- Remove or relabel the sign-up calls to action, rather than explaining them at the destination
“Contract terms are stated as having no fixed term and no exit fee.”
Both terms are absolute and both are substantiated. The Standard Terms and Conditions confirm no fixed term, and the published fee schedule contains no exit or termination charge. Established across the full published estate: 63 addresses in the sitemap plus navigation enumeration to a stable total of 65, of which 84 surfaces and 9 documents were read, checked 17 August 2026.
Captured 30 August 2026 · source page ↗
“The plan range is stated as two named plans.”
The number of plans is stated, both are named, and the usage threshold that separates them is given as a figure with a regional variation. A reader can work out which plan applies to them from the page itself.
Captured 30 August 2026 · source page ↗
“A rate superiority claim is made without a stated comparison basis.”
This is a superiority claim in absolute form. No comparison is offered on the surface or anywhere in the estate: no ranking, no competitor set, no methodology and no date. Established across the full published estate: 63 addresses in the sitemap plus navigation enumeration to a stable total of 65, of which 84 surfaces and 9 documents were read, checked 17 August 2026. Under the Fair Trading Act a comparative pricing claim needs a basis capable of supporting it at the time it is made.
Captured 30 August 2026 · source page ↗
“A live sign-up call to action stating a maximum duration leads to a closed sign-up.”
The duration is stated as a specific maximum, which is the substantiable form of this claim. What a customer meets is not the sentence on its own. A Join us call to action sits in the navigation of every page walked on 30 August 2026, sign-up buttons sit in the body of the electricity page, the brand identity page and the Warriors campaign page, and the calculation page states the same duration on the button itself. Every one of them routes to the sign-up address, which redirects to the migration notice, a page that carries no form and no input fields. The duration is no longer testable because the route it describes is closed, and the invitation to take it is still live.
Captured 30 August 2026 · source page ↗
"Fair, competitive pricing" and "keeping prices low all day every day" appear across several pages with no comparison behind either. The solar buy-back rate of 11.00c per kWh excluding GST and the itemised fee schedule, including a zero card processing fee, are specific and checkable.
Why this matters. Frank's pricing claims are the ones customers act on and the ones with the least behind them. The specific figures elsewhere on the same pages show the contrast.
What closing this looks like
- Publish the basis for the pricing claims, or reword them
“The solar buy-back rate is stated as a specific figure with its GST treatment.”
The rate is a specific figure, the GST treatment is stated, and the eligibility conditions including the system size limit are on the same surface.
Captured 30 August 2026 · source page ↗
“The fee schedule states individual amounts including a zero card-processing fee.”
Individual amounts are listed rather than described, GST treatment is stated, and the card processing fee is disclosed as zero rather than omitted. A customer can price a transaction before making it.
Captured 30 August 2026 · source page ↗
“A pricing claim is made on multiple pages without a stated comparison basis.”
An absolute pricing claim repeated across several pages with no comparison behind it. Established across the full published estate: 63 addresses in the sitemap plus navigation enumeration to a stable total of 65, of which 84 surfaces and 9 documents were read, checked 17 August 2026. No ranking, market analysis or independent comparison is published anywhere in the estate to support it.
Captured 30 August 2026 · source page ↗
“A fairness-and-competitiveness pricing claim is listed as a product benefit without a stated comparison basis.”
Listed as a product benefit alongside checkable items such as the contract terms and the payment options, which invites a reader to treat it as equally checkable. It is not. Fairness and competitiveness are both comparative and neither has a stated basis. Established across the full published estate: 63 addresses in the sitemap plus navigation enumeration to a stable total of 65, of which 84 surfaces and 9 documents were read, checked 17 August 2026.
Captured 30 August 2026 · source page ↗
"Energy without the gimmicks, giveaways and guff of our competitors" and "We don't do fluff, guff, freebies and gimmicks" position Frank against unnamed competitors. No competitor is named, no promotional practice is described, and no evidence is offered that going without promotions produces a lower overall cost.
Why this matters. Defining the brand by what competitors are said to do puts the comparison at the centre of the pitch. No competitor is named and no comparison is shown.
What closing this looks like
- Name the comparison or drop it
“The brand is positioned by contrast with unnamed competitors' promotional practices.”
The positioning defines Frank by what competitors are said to do. No competitor is named, no promotional practice is described, and no evidence is offered that the absence of promotions produces a lower overall cost. Established across the full published estate: 63 addresses in the sitemap plus navigation enumeration to a stable total of 65, of which 84 surfaces and 9 documents were read, checked 17 August 2026. The claim asks the reader to accept a comparison that is never made.
Captured 30 August 2026 · source page ↗
“The same contrast is restated as a first-person practice claim on the product page.”
The same contrast restated in the first person on the product page, where a purchase decision is made. The rhetorical force comes from the comparison, and the comparison has no stated basis. Established across the full published estate: 63 addresses in the sitemap plus navigation enumeration to a stable total of 65, of which 84 surfaces and 9 documents were read, checked 17 August 2026.
Captured 30 August 2026 · source page ↗
Genesis ownership is disclosed in the footer of every page and the closure banner runs across the top of every page, which is strong placement for the most material current fact. On the brand identity page the "fiercely independent bunch" wording sits directly beneath that banner. The ownership qualifier is in the same sentence, so this is a question of what the page says overall rather than of concealment.
Why this matters. The page that exists to say what Frank is now says two things at once: independent, and being absorbed. Both are on screen together.
What closing this looks like
- Update the brand identity page to describe Frank in the past tense
“Parent ownership is disclosed in the footer of every page.”
Ownership is disclosed in the footer of every page rather than on a single about-us surface, so a reader meets it wherever they enter the site. This closes an earlier gap: ownership was not disclosed at launch and was added after media questioning.
Captured 30 August 2026 · source page ↗
“Closure and migration are disclosed in a banner on every page.”
The most material current fact about the brand, that it is closing and customers are being moved, is at the top of every page rather than on a notices page. That is strong placement and it is the right decision.
Captured 30 August 2026 · source page ↗
“An independence claim sits on the brand identity page alongside the closure banner announcing absorption into the parent.”
The same wording assessed under cross-channel consistency, considered here for where it sits rather than for what it says. It is on the brand identity page, directly beneath the banner announcing absorption into the parent. The ownership qualifier is present in the sentence, so this is not concealment. The difficulty is that the page a reader visits to find out what Frank is now carries two answers at once.
Captured 30 August 2026 · source page ↗
Frank "prides itself on selling it to you straight", which sets the standard its communication is measured against. The New Zealand Herald reported that Genesis ownership was not disclosed on the website at launch and was added after the publication put questions to the company. Ownership is now disclosed on every page.
Why this matters. A brand named for plain speaking sets the standard it will be judged against. The ownership disclosure that is now prominent was added after it was questioned.
What closing this looks like
- Set a wind-down disclosure standard for future brand consolidations
“A transparency claim is made as the brand's core positioning statement.”
The brand's core positioning is a claim about how it communicates, which makes the way it communicates assessable. Ownership was not disclosed at launch and was added after media questioning, a matter of public record. The disclosure is now in place and prominent. The claim is graded on the gap between the standard the positioning sets and the record, not on the reporting itself.
Captured 30 August 2026 · source page ↗
“Brand voice is consistent between the product pages and the closure communication.”
The closure notice keeps the brand's register rather than switching to corporate language at the point where the news is unwelcome, which is the harder place to stay consistent.
Captured 30 August 2026 · source page ↗
The same campaign page states a saving of up to $970 over ten years and discloses the full basis on the page: the bulbs replaced, both wattages, hours of daily use, the unit price of electricity and the period.
Why this matters. Where Frank does put a number on a saving, it shows its working. That is the standard the rest of its numeric claims are measured against.
“A monetary saving is stated with its full calculation basis disclosed on the same page.”
The basis is disclosed in full on the same page as the claim: the bulbs being replaced, their wattage, the replacement wattage, the hours of daily use, the unit price of electricity and the period. A reader can recalculate the figure for their own household. This is the standard the rest of the estate's numeric claims do not meet, and it is worth saying that it was met here.
Captured 30 August 2026 · source page ↗
Complaint resolution is multi-channel with a 20 working day target and free escalation to Utilities Disputes. Medically dependent customers cannot be disconnected for non-payment, and hardship referrals to Work and Income, MoneyTalks and Citizens Advice Bureau are documented. The Consumer Care Policy behind those commitments is published and current at seven pages dated 6 May 2026, setting disconnection notice periods, a minimum number of contact attempts and the circumstances in which supply will not be cut. One of the three pages presenting it links to the address the document used before its May 2026 reissue.
Why this matters. The consumer protection framework here is strong and the document behind it is more specific than the pages that point to it. A customer following the route from the resolution process page or the customer care page reaches it.
“Medically dependent consumers are told disconnection for non-payment does not apply to them, with a documented registration route.”
Protection for medically dependent customers is stated plainly, with a registration route requiring a health practitioner signature and separate guidance for what to do during an outage. The provisions meet the Electricity Authority obligations and in places go past them.
Captured 30 August 2026 · source page ↗
“Hardship support is presented as referral to named external agencies.”
Support is routed to named external agencies with contact details rather than described in general terms, which gives a customer in difficulty somewhere to go rather than something to read.
Captured 30 August 2026 · source page ↗
“The Consumer Care Policy presented as Frank's commitment under a named regulatory obligation is published, current and specific.”
The sentence presents the policy as a document the reader can open and ties it to a named regulatory obligation. The document delivers that. It runs to seven pages, is dated 6 May 2026, opens by stating that it meets the purpose and outcomes specified in the Electricity Authority's Consumer Care Obligations, and carries forty working links. It sets disconnection notice periods of no earlier than 28 days and 44 days from the original invoice, at least five contact attempts, no disconnection at night, before or during a weekend or public holiday, during severe weather or a civil emergency, and no reconnection fee where a disconnection was made in error. It names MoneyTalks, Citizens Advice Bureau, Work and Income, ERANZ and the Community Energy Network with contact details, and routes complaints to Utilities Disputes as independent and free of charge. Retrieved on 30 August 2026 it returned 472,052 bytes. The resolution process page and the customer care page both link to an address that opens it. The legal page links to the address the document used before its May 2026 reissue.
Captured 30 August 2026 · source page ↗
Orange/black branding with humour-driven content and NZ cultural references (Warriors partnership, TikTok engagement via Motion Sickness). No cultural appropriation or diversity misrepresentation identified.
Why this matters. The brand sounds the same everywhere it appears, including in the closure notice. Consistency at the point where the news is unwelcome is the harder half.
“The brand positions its tone against category convention.”
The self-deprecating rating device is used consistently across the estate and reads as brand voice rather than as a rating claim a customer could mistake for third-party recognition.
Captured 30 August 2026 · source page ↗
ReliaBill (payment smoothing) is well-documented with clear terms. Account credit refund before migration is stated. Standard T&Cs confirm no exit fees and full energy charge liability regardless of ReliaBill levels.
Why this matters. What Frank promises about payments and refunds is documented well enough that a customer can hold it to them.
“Payment smoothing is presented with its review cycle and change-notice period.”
The review cycle is committed to as a stated period, and the terms set out how payment amounts change and what notice is given. The arrangement is described well enough that a customer can tell what they are agreeing to.
Captured 30 August 2026 · source page ↗
Comprehensive pricing disclosure: regional rate schedules for 33+ regions, low/standard user thresholds clearly stated, government-mandated $1.20 max daily charge disclosed. Notable 0% credit card fee and no interest on late payments.
Why this matters. Pricing is published in enough detail that a customer can work out their own bill before signing up. That is unusual in this sector and it is worth saying.
“Regional rate schedules are published with daily charges and usage-band thresholds.”
The usage threshold is given as a figure with its regional variation, which is the detail that determines which plan a household should be on.
Captured 30 August 2026 · source page ↗
“The basis of the bill calculation is published as a standalone explanation.”
The bill is broken into its components and the page states plainly which costs are passed through. It also notes that some competitors itemise these separately, which is a comparative remark, but it is a remark about presentation rather than about price and it does not carry a superiority claim.
Captured 30 August 2026 · source page ↗
Frank publishes no environmental reporting, sustainability data, certification or third-party verification of its own, and does not point customers to the parent's. Established across the full published estate of 65 addresses, checked 17 August 2026.
Why this matters. Frank publishes no environmental reporting of its own. Customers who want to know the environmental profile of their electricity have to find it at the parent, and nothing on Frank's pages tells them to look.
No green or nature imagery is used in an environmental context. The visual identity is orange and black with humour-led creative and New Zealand cultural references.
Why this matters. Frank's visual identity makes no environmental suggestion, so there is no gap between what the imagery implies and what the business does.
Beyond the Ecobulb campaign page, no environmental messaging appears at any point in the purchase journey. Established across the full published estate of 65 addresses, checked 17 August 2026.
Why this matters. There is no environmental message running through the purchase journey to be inconsistent with, which is a finding about the journey rather than a fault in it.
Frank makes no forward environmental commitment. The Genesis consolidation release hosted on Frank's media page refers to the transition to renewable generation and to net zero 2050, and attributes both to the parent.
Why this matters. Frank makes no forward environmental commitment of its own. The transition language on its media page belongs to the parent and is described as the parent's.
What has changed since first assessment
This audit was assessed in August 2026 and reviewed twice since. Both reviews were carried out by HowLegit on its own initiative.
- 13 August 2026Original assessmentFirst assessmentC+
Assessed against 84 captured surfaces. The Environmental dimension was returned as insufficient to grade.
- 17 August 2026Evidence reviewOur correctionC+
Thirty-six claims were authored and anchored to the entity's own wording. The Environmental dimension entered the assessment on the energy efficiency campaign. Remedy visibility moved down on a policy document recorded as unreachable.
- 30 August 2026Correction on new evidenceOur correctionB-
The Consumer Care Policy was retrieved and read. It is published and current at seven pages dated 6 May 2026, and two of the three pages presenting it link to an address that opens it. The August finding rested on an address the document used before it was reissued, and remedy visibility returns to met.
Cite this
One company, with every graded claim, its own published wording and the dated capture each grade rests on.
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HowLegit, Frank Energy — messaging integrity assessment. Energy sector register, assessed 16 July 2026. Overall B- (62.4%). https://howlegit.com/register/Energy/frank-energy A grade rules on whether a public claim is substantiated, not on its truth or on the merit of the business. Not legal or investment advice. Produced by HowLegit, which also sells audits commercially. The data on this page is public.
This entry is part of a complete sector scan. Companies not listed on the Energy register were not assessed — which is not the same as being cleared.