The Australian Energy Regulator (AER) has published a consultation note on its Market Liquidity Obligation (MLO) exchange annual review and MLO-related applications. This note invites submissions on:
- the extent to which the current MLO exchange, Australian Securities Exchange 24 (ASX 24), continues to meet the relevant criteria to facilitate the trading of MLO products as set out in the National Electricity Rules (Rules)
- Time of Day Markets’ (TOD Markets) application to be approved as a MLO exchange
- implications of the AER approving additional MLO products, including morning and evening peak electricity futures.
The consultation note outlines key questions on the topics outlined above to facilitate stakeholder feedback.
The annual MLO exchange review, and the application and approval processes for MLO exchanges and additional MLO products are set out in clause 4A.G.23 of the Rules and the AER’s Interim MLO Guidelines.
Background
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 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 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.
Invitation for submissions
The AER invites submissions from interested stakeholders by close of business, 28 August 2025. Written submissions should be emailed to rro
aer [dot] gov [dot] au (rro[at]aer[dot]gov[dot]au(link sends e-mail)).
The AER prefers that all submissions be sent in an electronic format in Microsoft Word or other text readable document form and publicly available, to facilitate an informed, transparent and robust consultation process. Accordingly, submissions will be treated as public documents and posted on the AER’s website unless prior arrangements are made with the AER to treat the submission as confidential. Those wishing to submit confidential information are requested to:
- clearly identify the information that is the subject of the confidentiality claim; and
- provide a non-confidential version of the submission.