Assessed 16 July 2026 under NZ · Medium confidence
Evidence last captured 28 August 2026 · next re-check due 28 August 2027
We contacted this company 2 times between 6 August 2026 and 31 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.
All 21 energy companies, assessed against the same checklist in the same window.
Toast Electric ranks 4 of 21 in this sector by overall score, between 47.6% and 96.0%.
The renewable figure is stated but not sourced. No reference is given to the Electricity Authority or other published generation data that would let a reader check it. The parent organisation is described as a Climate Positive organisation without naming the certifying scheme, the assessment date or a supporting document, and that claim is made for the parent rather than for the retail brand.
Why this matters. A certification named without a scheme or a date cannot be verified by the reader it is meant to reassure.
“"Sustainability Trust is also a Climate Positive organisation"”
The certification is named but no certifying body, scheme, assessment date or supporting document is given alongside it, and no link is provided. The claim is also made for the parent organisation rather than for the retail brand a customer is buying from. A reader cannot verify what the term covers or who awarded it.
Captured 28 August 2026 · source page ↗
The renewable supply disclosure sits on the questions page. It does not appear on the pricing page, the about page or the wellbeing programme page. A customer comparing retailers on environmental grounds would not meet it at the point of decision. This was established by walking the site navigation across all 21 captured pages.
Why this matters. Information that only appears once a customer goes looking for it does not inform the decision it is relevant to.
“Renewable supply disclosure appears on the questions page only”
The renewable supply disclosure sits on the questions page. It does not appear on the pricing page, the about page or the wellbeing programme page. A customer comparing retailers on environmental grounds would not meet it at the point of decision. Established by walking the site navigation across all 21 captured pages on 17 August 2026.
Captured 28 August 2026 · source page ↗
The stated intent to increase the renewable percentage carries no target, no baseline year and no pathway. The intent is credible and modestly framed, but nothing is published against which progress could later be measured.
Why this matters. A commitment without a target or a baseline cannot be held to account later, including by the entity itself.
“"Always looking for ways to increase that percentage"”
A forward-looking statement with no target percentage, no baseline year and no stated pathway. The intent is credible and modestly framed, but there is nothing published against which progress could later be measured.
Captured 28 August 2026 · source page ↗
All profit from general-income customers funding low-income households is an absolute claim, and it is structurally plausible given charity governance and the absence of shareholders. It cannot be checked at the level it is made: the parent trust's consolidated statements are on the public charities register, but they cover every activity the trust runs rather than the retail brand, and neither the brand's result nor the transfer described is separated out. The figure of more than 500,000 kWh donated describes a discount rather than a gift, because Energy Wellbeing customers receive subsidised tariffs rather than electricity at no cost. The count of over 400 home performance visits is published on the entity's own news page, but no outcome from those visits is published.
Why this matters. Impact figures shape whether people trust where their money goes, and these ones cannot currently be checked against anything published.
“"100% of profits from general-income customers go right back to supporting those living with low income"”
Absolute claim, and structurally plausible: the retail brand sits inside a registered charitable trust with no shareholders and no profit distribution. The parent trust files annual returns with Charities Services under Tier 2, so its consolidated financial statements are on the public record. Those statements cover every activity the trust runs and do not separate the retail brand's result or show the transfer this claim describes, and the basis on which profit is calculated before or after shared administration is not stated. The claim cannot be checked at the level at which it is made.
Captured 28 August 2026 · source page ↗
“"500,000+ kWh donated"”
"Donated" is imprecise language. The mechanism is cross-subsidy through discounted tariffs for Energy Wellbeing customers, not gifting of electricity at no cost. "Donated" implies a transfer of goods; the model is a price reduction funded by general-income customer profits. Language precision concern per audit voice rules.
Captured 28 August 2026 · source page ↗
“"400+ home assessments completed"”
Quantitative claim from LinkedIn only. Not independently verified. 400 assessments / 3,000 customers = 13.3% of customer base. Suggests Energy Wellbeing Programme serves a minority of customers. No published impact assessment or outcomes data for these assessments.
Captured 28 August 2026 · source page ↗
The guarantee of a lower everyday electricity cost appears on the wellbeing programme page and on the government comparison listing, in both cases without qualification. The Energy Wellbeing terms do set out a substantive mechanism, in which the previous supplier's tariffs are applied to twelve months of the customer's usage and Toast's rates are then set so the overall cost is lower. The same terms, at Section 5.i.f, also allow an alternative rate to be offered instead where the previous bill is not genuine or reflects an offer significantly below the current market. Neither public surface discloses those conditions, so a customer reading the word guaranteed would have to open the programme terms to find them.
Why this matters. A guarantee that carries undisclosed exceptions is the gap most likely to surface as a dispute.
“Guaranteed lower everyday electricity costs compared to previous suppliers”
Assessed in detail under C4. Claim IS on the website: "Energy Wellbeing customers are also guaranteed a lower everyday electricity cost than they were paying with their previous supplier" (wellbeing-programme.html). Original cross-channel inconsistency finding was incorrect -- claim is consistent across Billy.govt.nz and website. FLAG rationale unchanged: qualification gap between unqualified "guaranteed" language and T&Cs Section 5.i.f escape clauses. Primary area: C4 (outcome promise).
Captured 28 August 2026 · source page ↗
One cross-channel inconsistency remains. The complaint address differs between the web version of the customer care policy, which gives hello@toastelectric.nz, and the downloadable PDF of the same policy, which gives hello@sustaintrust.org.nz in the same sentence; the questions page adds a third form on a domain the entity does not use. The overall tone is conservative, with no superlative claims and no urgency marketing. The address inconsistency sustains the FLAG.
Why this matters. Consistent tone and contact detail across documents is what makes a compliance process usable in practice.
“"Friendly customer service"”
Puffery. Subjective, non-assessable. Below FTA threshold.
Captured 28 August 2026 · source page ↗
“Time-of-use tariffs and EV charging tariffs”
Time-of-use and EV charging products are published on the entity's own surfaces. The pricing page carries a Day/Night tariff and a Night Boost rate for three named network areas, for both low and standard users, under the heading Toast Electric Power Tariffs, and states that the day/night tariff suits EV owners. The questions page answers the EV question directly and gives the off-peak window as 9pm to 7am. A customer can find and price both products without leaving the site.
Captured 28 August 2026 · source page ↗
“Contact email inconsistencies across documents”
Different email addresses for complaints vs general contact. While both presumably reach the right team, a consumer following the complaint process in the Consumer Care Policy would email a different address than the one in the T&Cs. Consistency gap across compliance documents.
Captured 28 August 2026 · source page ↗
Toast Electric states that at least 80% of the power it sells is renewable, gives the range as around 80% and as high as 95% depending on conditions, and names the national grid as the source. The figure is consistent with the published national generation mix. The wording is hedged rather than absolute and the basis for it is set out on the same page.
Why this matters. A quantified and hedged supply claim gives customers something they can check, and it is the claim a regulator would test first.
“"At least 80% of the power we sell to you is renewable"”
The questions page states a quantified renewable share for the power supplied to customers, gives the range as around 80% and as high as 95% depending on conditions, and names the national grid as the source. The figure is consistent with the published national generation mix. The wording is hedged rather than absolute, and the page sets out the basis for it.
Captured 28 August 2026 · source page ↗
“"Toast is plugged into New Zealand's renewable energy system (typically between 80-100% renewable energy generation)"”
A stated range rather than a single headline figure. The range matches the variability of national hydro generation and is presented alongside the explanation of how retail supply draws from the grid.
Captured 28 August 2026 · source page ↗
The questions page discloses its own baseline, the grid mix, and then explains how a competing 100% renewable claim is constructed through power purchase agreements, stating that the long term benefit of that accounting is not certain. The comparison names the mechanism rather than trading on it.
Why this matters. Explaining how a rival's stronger sounding claim is built is unusual, and it lowers the risk of the market being compared on an uneven basis.
“"A company that claims its power is 100% renewable is slightly different"”
The page discloses its own baseline, the grid mix, and then explains how a competing 100% renewable claim is constructed through power purchase agreements. It states plainly that the long term benefit of that accounting is not certain. The comparison names the mechanism rather than trading on it, which is the disclosure this area looks for.
Captured 28 August 2026 · source page ↗
New Zealand's only not-for-profit electricity retailer is an absolute uniqueness claim, repeated on the website, the government comparison listing, Powerswitch and social channels. Claims using only attract the highest scrutiny, and no other New Zealand not-for-profit electricity retailer was identified across this 22-retailer scan or in adversarial research. The structure supports it, in that Toast Electric Limited operates under Sustainability Trust, a registered charity, with no shareholders and no profit distribution. The figure of 3,000 customers is dated March 2026, is published on the entity's own news page, and is proportionate to the regional footprint.
Why this matters. Uniqueness claims carry the highest burden, and this one is load bearing for the whole brand position.
“"New Zealand's only not-for-profit electricity retailer" / "Aotearoa's not-for-profit power company"”
Uniqueness claim ("only") . Structurally supported: operates under registered charity (Sustainability Trust), NZBN 9429050939756. No other NZ NPO electricity retailer identified in adversarial research or sector scan of 22 retailers. Consistent across all surfaces.
Captured 28 August 2026 · source page ↗
“"3,000 customers" (March 2026)”
Specific, dated metric. Proportionate to regional service area (Wellington, Canterbury). No contradicting evidence.
Captured 28 August 2026 · source page ↗
“"4:1 giving model"”
Claim appears on 3 surfaces: Instagram bio, FAQ page ("We work on a 4:1 model, which means for every four general-income customers, we can provide wraparound support to one more low-income customer"), and meter reading news article. The 4:1 ratio IS defined and IS plausible: 3,000 total customers / 5 = 600 EW customer slots. With 400+ home assessments completed out of ~600 potential EW customers (~67% assessed), the numbers are consistent with a 4:1 cross-subsidy model. The ratio describes operational capacity, not assessment completion rate. Upgraded from FLAG to PASS -- claim is defined, explained, and mathematically plausible.
Captured 28 August 2026 · source page ↗
“"Eliminate energy hardship in Aotearoa"”
Aspirational mission statement, correctly framed as a goal ("our mission is to eliminate"). Not presented as current achievement. Pathway evidence exists (Energy Wellbeing Programme, home assessments, winter discounts). "Elimination" is aspirational but directionally consistent with actions.
Captured 28 August 2026 · source page ↗
The customer care policy is published in full at sixteen pages, the Energy Wellbeing programme is set out on the website with its eligibility criteria, and the terms and the privacy policy are current at July 2026 and April 2026. No adverse regulatory, compliance or dispute finding was identified in the public record searched for this assessment. Toast made submissions to Electricity Authority consultations on billing improvement and on the Consumer Care Guidelines. The published policy set is the record a customer or a regulator would turn to when something goes wrong.
Why this matters. Published policies are the record a customer or regulator turns to when something goes wrong.
“Consumer Care Policy published”
Comprehensive 16-page document covering billing, payments, hardship support, disconnection process, complaints, MDC protections. Five-step communication process before disconnection. Fee schedule published. External support services listed.
Captured 28 August 2026 · source page ↗
Utilities Disputes membership is confirmed and the complaint process is described in the customer care policy with a twenty working day resolution period. The medically dependent consumer register is available, and Toast states it does not disconnect medically dependent consumers for non-payment. Contact details are published, including an email address and a phone call-back option. External support services are listed: Powerswitch, MoneyTalks, Citizens Advice Bureau, Work and Income, Community Energy Network, Eco Design Advisor, EnergyMate and Utilities Disputes.
Why this matters. For a customer in hardship, knowing where to complain and who will hear it is the difference between a remedy and a dead end.
“Medically Dependent Consumer register available”
EA Consumer Care Guidelines requirement. All retailers must provide. Toast Electric provides MDC registration, no-disconnection protection, and 24/7 outage hotline (network provider). Meets regulatory requirement.
Captured 28 August 2026 · source page ↗
“Utilities Disputes membership”
Membership confirmed by logo display. Utilities Disputes contact details provided in Consumer Care Policy (0800 22 33 40, utilitiesdisputes.co.nz).
Captured 28 August 2026 · source page ↗
Imagery is built around community, warmth and families, consistent with the energy hardship mission. The Wellington-centred positioning matches the actual service area rather than implying national reach. No misuse of stock imagery and no cultural appropriation concern was identified. Use of te reo Māori is contextually appropriate for a New Zealand entity.
Why this matters. Imagery that matches the actual service area and mission avoids implying a reach the entity does not have.
Messaging holds together across the website, the government comparison listing and social channels. The lower everyday cost guarantee appears on both the website and the government listing in consistent terms, and the four to one giving model is defined the same way on the questions page and in the news coverage. Two remaining differences, the tariff products listed on the government site and the two contact addresses, are assessed under the commercial dimension where the wording sits.
Why this matters. A customer who meets one version of an offer on a government site and another on the website cannot tell which one binds.
The terms dated 1 July 2026 match the headline offer. A customer ends supply on 48 hours notice with no early termination fee, no lock-in and no credit clawback, and no interest is charged on late payments. Toast gives 30 days notice of a price change and notifies individually where an increase exceeds 5%, and Energy Wellbeing customers are not disconnected while they engage in good faith. Consumer Guarantees Act 1993 compliance is stated in the contract, liability is capped at $10,000 per event, and no fine print was found that contradicts a headline claim.
Why this matters. Contract terms that match the headline offer are what stop a switching decision becoming a complaint.
“No early termination fee”
T&Cs confirm: customer may terminate with 48 hours notice. No exit fee. No credit clawback. No lock-in period. Verifiable and consistent across surfaces.
Captured 28 August 2026
“30 days notice for price changes; individual notice if increase exceeds 5%”
Exceeds minimum regulatory requirement. Individual notification for increases above 5% is a consumer protection positive.
Captured 28 August 2026
“Consumer Guarantees Act 1993 compliance stated”
CGA compliance explicit in contract terms. Standard compliance but affirmatively stated.
Captured 28 August 2026
“"Switching is easy" / "Simple to switch"”
Subjective but consistent with NZ's EA-standardised switching process. Switching Registry ensures consistent process across all retailers. Low compliance risk.
Captured 28 August 2026 · source page ↗
The solar buy-back rate of 12.5 cents per kWh is published on the pricing page and matches the third-party comparison listing. Full tariff tables are published for every network area, tariff type and user category. The customer care policy publishes a fee schedule in specific amounts, including remote reconnection at $25, manual reconnection at $110 or $235 after hours, and a direct debit dishonour fee of $14.95. Competitive pricing is recognised puffery and sits below the threshold at which a reader would take it as a specific factual comparison.
Why this matters. A published rate a customer can verify is worth more than a favourable one they cannot.
“Solar buy-back rate: 12.5c/kWh”
Specific, verifiable rate. Stated across surfaces. No contradicting information.
Captured 28 August 2026 · source page ↗
“SmoothPay and Direct Debit payment options”
Payment options verified across surfaces. WINZ redirects available for EW customers. Consistent across all channels.
Captured 28 August 2026 · source page ↗
"Competitive pricing" (Billy.govt.nz) is puffery -- no named comparator, but this is standard industry language below the FTA s.12A threshold. The "guaranteed lower everyday electricity costs compared to previous suppliers" claim has a comparative element (vs previous supplier), but the comparison mechanism in T&Cs Section 5.i is substantiated: Toast calculates 12-month usage on the customer's previous retailer's tariffs and sets Toast tariffs to ensure overall cost is lower. The comparative mechanism is real, documented, and operational. The issue is with the guarantee qualification (assessed in C4), not the comparison methodology.
Why this matters. Comparative language attracts regulator attention faster than almost any other claim type.
“"Competitive pricing"”
Recognised puffery. Subjective, unverifiable, but below FTA s.12A threshold. Standard industry language. No reasonable consumer would interpret "competitive" as a specific factual comparison.
Captured 28 August 2026 · source page ↗
Full tariff tables are published on the pricing page for both islands, for low and standard users, and for every tariff type including uncontrolled, controlled, composite, day/night, night boost and solar buy-back, each with its daily charge. The customer care policy publishes a fee schedule in GST-inclusive amounts. No hidden charges were identified, and there is no scarcity marketing, no urgency framing and no early termination fee. Publishing full rates rather than an indicative range is stronger practice than most retailers assessed in this scan.
Why this matters. Full published tariffs let customers compare on their own terms rather than on the seller's.
“Fee schedule published: reconnection $25 (remote), $110/$235 (manual), DD dishonour $14.95”
Specific, GST-inclusive amounts. Transparent and accessible. No hidden fees identified.
Captured 28 August 2026 · source page ↗
The relationship with Sustainability Trust is disclosed across the site, and the terms identify Toast Electric Limited by New Zealand Business Number 9429050939756. The privacy policy names every third party that receives customer data: Intellihub Ltd and Bluecurrent Ltd as metering providers, Centrix Group Ltd as credit agency, Credit Consultants for debt recovery, and the Electricity Authority and Utilities Disputes. Listings on the government comparison site and on Powerswitch were confirmed. A customer can establish which entity holds the contract and who receives their data.
Why this matters. Knowing which entity holds the contract and who receives customer data is basic to informed consent.
“Privacy Act 2020 compliance with named third parties”
Third parties disclosed: Intellihub Ltd, Bluecurrent Ltd (MEPs), Centrix Group Ltd (credit), Credit Consultants (debt recovery). Standard Privacy Act compliance.
Captured 28 August 2026
“Sustainability Trust relationship disclosed”
Entity relationship transparently disclosed across all surfaces. T&Cs identify NZBN. "Toast Electric is a retail brand of Sustainability Trust" stated in Energy Wellbeing T&Cs.
Captured 28 August 2026 · source page ↗
No environmental badges, green imagery or environmental visual framing were identified. Site imagery is built around community, warmth and families, consistent with the social equity positioning. Nothing in the visual treatment asserts an environmental credential, so there is nothing to assess here.
Why this matters. Where no environmental credential is asserted visually, there is no impression for the imagery to overstate.
Assessed from the public record, then reviewed once before publication, by HowLegit on its own initiative. Toast Electric was not involved. What moved, and why.
Assessed from the public record, unsolicited, as part of the New Zealand energy sector scan. Toast Electric did not commission it.
Quality review. The environmental finding asserted that no generation mix or renewable percentage was disclosed on any surface. The entity's own questions page states that at least 80% of the power it sells is renewable, names the national grid as the source and gives a range. The finding was withdrawn and the dimension graded on the disclosures that exist. A separate cross-channel finding that carried no assessed wording was also withdrawn.
One company, with every graded claim, its own published wording and the dated capture each grade rests on.
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HowLegit, Toast Electric — messaging integrity assessment. Energy sector register, assessed 16 July 2026. Overall B+ (79.0%). https://howlegit.com/register/Energy/toast-electric 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.