In November 2023, the AER commenced its Review of the AER exemptions framework for embedded networks. The objectives of this review included:
- Better understanding the harms, or risk of harms, residential embedded network customers may be facing.
- Better understanding the benefits of residential embedded networks, and the extent to which customers are receiving them.
- Determining whether we should make changes to our Network Exemptions Guideline and Retail Exempt Selling Guideline (the guidelines), to address any issues we identified. For example, by strengthening regulatory oversight of embedded networks, enhancing reporting arrangements and consumer protections, or restricting the growth of future residential embedded networks.
Issues paper
On 30 November 2023, the AER published an issues paper seeking stakeholder feedback on the benefits and harms due to embedded networks, and possible policy approaches. We received 37 submissions. As part of the consultation process, we also held an online public forum on 13 December 2023 to present on and discuss topics from the issues paper. About 100 guests attended.
Draft decision
On 17 March 2025, the AER released our draft decision for public consultation, alongside draft guidelines (both version 7).
The draft decision sets out the information we received, how we have considered stakeholders’ feedback, and the proposed actions we have taken to amend the guidelines to strengthen protections for consumers and increase the AER’s visibility of embedded networks. It also set out our reasoning for the proposed guideline amendments.
Stakeholders were invited to provide submissions on the draft guidelines. We received 34 submissions.
Bastion Insights supported the AER by conducting qualitative and quantitative research into embedded network customer experiences. Bastion Insights’ final report, Review of the Exemptions Framework for Embedded Networks Research Report, was published alongside the draft decision.
Additionally, family violence specialists Safe and Equal supported us by providing expert advice on implementing family violence protections for exempt customers. Its report Policy Advice on Family Violence Obligations for Exempt Sellers, Final Report, July 2024, was also published alongside the draft decision.
Additional consultation
On 23 June 2025, stakeholders were invited to provide submissions, on 2 new proposed retail conditions, following consideration of public submissions to the draft Retail Exempt Selling Guideline (v7). We received 7 submissions.
Notice of extension to publish final decision
On 23 June 2025, the AER published a notice of extension under clause 8.9.2(d) of the National Electricity Rules.
Final decision
On 29 August 2025, the AER released the final decision, alongside the revised Network Exemptions Guideline and Retail Exempt Selling Guideline (versions 7).
Our final decision acknowledges that all energy customers should have a comparable level of consumer protections, to the extent possible, regardless of their energy supplier. However, to achieve this, jurisdictional governments will need to act, to address consumer protection gaps outside the scope of the AER’s regulatory powers.
The accompanying guidelines include several new conditions or measures to address the issues we identified through the review.
Background
Embedded networks are private electricity networks that can serve multiple customers. In most cases, the embedded network operator buys energy from an energy retailer and on-sells it to the occupants of the site. Residential embedded networks include retirement villages, caravan parks and large apartment complexes.
The AER regulates who can operate embedded networks and on-sell energy within them. We do this through a framework that exempts entities, who sell or supply energy within embedded networks, from aspects of the standard energy framework. We govern this exemptions framework through our Network Exemptions Guideline and the Retail Exempt Selling Guideline.