The Market Liquidity Obligation (MLO) is a market making requirement under the Retailer Reliability Obligation (RRO) framework designed to facilitate transparency and liquidity in the trading of electricity futures contracts relating to a forecast reliability gap.
The RRO is triggered by the AER after the Australian Energy Market Operator (AEMO) identifies a potential upcoming reliability gap. Energy Ministers within the National Electricity Market can also trigger the RRO. If the RRO is triggered, at T-3 (3 years out) the National Electricity Rules require obligated parties in the relevant region to commence making bids and offers for MLO products on an approved MLO exchange within 5 business days.
The MLO operates between T-3 and T-1 (one year out) when the RRO is triggered. The MLO provides a source of qualifying contracts for liable entities to purchase to help them meet their RRO contracting requirements.
Consultation
On 7 August 2025, the AER released a consultation package regarding the 2025 Market Liquidity Obligation exchange review and MLO-related applications. The AER is seeking stakeholder views on the Australian Securities Exchange 24’s (ASX 24) current position as a MLO exchange and Time of Day Markets' (TOD Markets) application to be approved as a MLO exchange.
The AER is also considering approval of financial products listed by ASX 24 and TOD Markets, such as morning and evening peak electricity futures, as additional MLO products.
Outcome
In late 2025 the annual MLO exchange review was completed, with no changes made to the approved exchange (ASX 24).
In September 2026, the AER approved TOD Markets as an additional MLO exchange, together with additional MLO products across ASX 24 and TOD Markets.