AER invites submissions on assessing an insurance coverage pass through event

Under the National Electricity Rules and Gas Access Arrangements, the Australian Energy Regulator (AER) is required to consider a broad range of factors in assessing whether a cost pass through event has occurred. Insurance coverage pass through events allow a Network Service Provider to recover material costs that are incurred above the Network Service Provider’s insurance policy limit or coverage.

Network operators face changing liability insurance market conditions, and following feedback from stakeholders, we are seeking to provide the industry and consumers with greater clarity on the principles the AER will use and evidence we will require to guide and inform our decision making to assess an insurance coverage pass through event should one arise.

Interested stakeholders are encouraged to provide submissions to our consultation paper to ensure all key issues are considered in developing a guidance note that will provide this clarity.

We expect to release a draft guidance note in January 2021 for further consultation, followed by the final guidance note in June 2021.

Invitation for submissions 

We invite interested parties to make submissions on the principles and evidence required to assess an insurance coverage pass through event by Friday 30 October 2020.

Submissions should be emailed to: with the subject line Attention: General Manager, Transmission & Gas - Submission on assessing an insurance coverage pass through event.

Alternatively, you may mail submissions to:

Mr Sebastian Roberts
General Manager, Transmission & Gas
Australian Energy Regulator
GPO Box 520
Melbourne, Victoria, 3001

We prefer that all submissions be publicly available to facilitate an informed and transparent consultative process. We will treat submissions as public documents unless otherwise requested. All non-confidential submissions will be placed on the AER's website. For further information regarding the AER's use and disclosure of information provided to it, see the ACCC/AER Information Policy.

We request parties wishing to submit confidential information:

  • clearly identify the information that is the subject of the confidentiality claim
  • provide a non-confidential version of the submission in a form suitable for publication.
Issued date: 
28 August 2020
AER reference: 
AC 123/20
AER General Inquiries