Recent Regulatory Changes for Embedded Networks: New Legislation and Compliance Insights

Recent Regulatory Changes for Embedded Networks: New Legislation and Compliance Insights

Updated Overview for 2026

The regulatory landscape for embedded networks in Australia is no longer just “emerging”; by early 2026, many elements of the AER’s review have moved from policy to practical day‑to‑day obligations for embedded network operators and strata committees. Following the Australian Energy Regulator’s (AER) 2025 review and Final Decision, a series of recent regulatory changes have introduced tighter compliance obligations for every embedded network operator. These reforms seek to align embedded network customers more closely with the protections available to those in the competitive retail market.

What Are Embedded Networks?

Embedded networks are private utility systems, common in apartment buildings, retirement villages, and shopping centres, where electricity is supplied to multiple customers through a parent meter. Operators, often body corporates or strata schemes, have previously relied on regulatory exemptions to sell energy internally. New embedded network legislation means these exemptions now come with heightened accountability and administrative responsibilities. In 2026, these arrangements are expected to deliver customer protections and pricing transparency much closer to what customers receive in the competitive market.

Highlights of the Recent Regulatory Changes

Key Reform Dates

Staggered implementation from August 2025 through mid-2026 brings several milestones:

• January 2026: Deemed exemption classes (D1/D2) closed; all new networks must register under R1/R2.

• From 1 January 2026: New family violence protections commence for applicable exempt sellers, requiring policies and procedures consistent with AER guidance.

• From 1 January 2026: New or varied exemptions must comply with updated Network and Retail Guideline conditions from day one, including stronger reporting and record‑keeping requirements.

• July 2026: Mandatory publication of tariffs comparing local retail offers.

• July 2026: Inclusion of Energy Ombudsman contact details on all bills.

• Annual from 2026: Operators must report customer numbers to the AER.

• From 1 July 2026 in NSW: Maximum energy prices and strengthened consumer protections begin under the Energy Legislation Amendment Act 2025, overseen by IPART, for many embedded network customers in the state.

For operators in New South Wales, these national AER requirements now sit alongside the NSW Embedded Network Action Plan and new legislation, meaning pricing, disclosure and dispute‑resolution obligations are tightening at both state and federal levels.

Strengthened Consumer Protections

New consumer protection measures introduced by the AER now include:

• Family violence protections require staff training and formal response processes.

• Hardship and life support policies modelled on authorised retailer standards.

• Transparency obligations require operators to proactively communicate tariff adjustments.

With the AER publishing dedicated guidance on family violence for exempt sellers in late 2025, operators can no longer rely on generic retail policies; they must be able to demonstrate that embedded network‑specific training, scripts and escalation pathways are in place.

Compliance Obligations for Operators

For every embedded network operator, these compliance obligations add new layers of governance, system documentation, and risk management:

• Creation of standalone family violence and hardship policies for exempt networks.

• Membership in energy ombudsman schemes with future fee structures anticipated.​​

• Clear record-keeping around disconnections, life-support customers, and annual data returns to the regulator.​

To reduce risk, exemption holders are encouraged to consider transferring compliance duties to authorised retailers such as Altogether, which can administer and assume the compliance burden under its existing licence.

Preparing for the Future

Proactive preparation is vital as these frameworks evolve further ahead of 2027 when national Embedded Network Codes of Practice (ENCoP) take effect. Early compliance planning avoids disruption, administrative burden, and potential penalties for late adaptation.

Throughout 2026, operators should treat guideline version 7 and the NSW reforms as a “dress rehearsal” for the ENCoP, using this period to embed better data, billing and customer‑care practices that will make future accreditation or code compliance processes simpler. Developers and new projects also need to factor these changes into feasibility, metering design and governance structures, as fewer configurations will qualify for deemed exemptions and more will require active registration and oversight.

Frequently Asked Questions (FAQs)

What prompted these changes to embedded network legislation?

The 2025 Final Decision closes long-standing regulatory gaps and ensures customers in embedded networks have fairer protections comparable to on-market users.​

Which businesses are affected?

The reforms apply to all embedded network operators, including strata bodies, retirement villages, caravan parks, and shopping centres that sell or supply electricity or water through private distribution systems.​ In NSW, the Energy Legislation Amendment Act 2025 extends key obligations to hot water and centralised air‑conditioning embedded networks, broadening the reach of consumer protections beyond electricity alone.

What is the new requirement for tariffs and billing transparency?

From July 2026, exemption holders must publish customer tariff information online, showing a comparison against local standing offers, and include energy ombudsman details on customer bills.​​

How will family violence protections change internal policies?

Each embedded network operator must introduce a family violence policy outlining customer identification, account privacy measures, and referral protocols to specialist services. Training on trauma-informed communication is mandatory.​​ In 2026, the AER’s new guidance gives exempt sellers template wording and checklists, so operators are expected to move quickly to adopt formal policies, adjust scripts for frontline staff and ensure technology systems can restrict unsafe account access where required.

Will future fees apply for ombudsman membership?

Yes. Although free initially, usage and complaint levels will inform future cost recovery models. This aligns embedded network costs with authorised retailer obligations. Operators should budget for ombudsman membership and complaint‑handling costs, becoming a normal part of running embedded networks, particularly where large resident populations or complex billing arrangements increase dispute volumes.

What steps can operators take now?

Operators should:

• Audit existing documentation to align with AER guidelines.

• Update billing systems to accommodate tariff publishing and ombudsman details.

• Engage expert support, or talk to your Altogether key account manager to see how we can help you manage the transition effectively.

• Develop or refresh life support, hardship and family violence procedures with clear internal owners, training schedules and board‑level reporting so that consumer protection becomes a standing governance item rather than an ad‑hoc task.
  
  

Final Thoughts

These recent regulatory changes mark a pivotal shift in Australia’s approach to embedded network legislation. In 2026, the focus has moved squarely from design to demonstrable compliance and better consumer outcomes across every site and customer account. While reforms increase compliance pressure, they also strengthen transparency, accountability, and customer confidence. 

Partnering with Altogether helps embedded network operators maintain compliance efficiently while focusing on community outcomes. With updated systems, reporting and specialist regulatory expertise, Altogether can support body corporates, developers and embedded network operators to meet AER and state‑based requirements through 2026 and into the ENCoP era, without losing sight of resident experience and sustainability goals.

Watch our webinar for more information.