Can You Opt-Out of an Embedded Network? Consumer Rights, Legal Frameworks & Switching Options

Embedded networks are increasingly common across Australia’s multi-user developments, servicing high-rise apartment blocks, shopping centres, retirement villages, commercial precincts, caravan parks and more. Delivered through private infrastructure, they offer efficiency, cost savings and emerging sustainability solutions. But what rights do consumers have to opt out if they want to make their own energy choices?

This post explores consumer rights, legal frameworks and switching options, leveraging insights and guidance provided by ENM Solutions.

What Is an Embedded Network?

An embedded network is a private electricity network owned or controlled by a property owner or operator. The network purchases energy at a parent meter and redistributes it to occupants through internal infrastructure .This arrangement often delivers cost efficiencies and centralised energy management across multi-tenant facilities.

Legal Framework: Power of Choice & the Role of ENMs

All embedded networks fall under the Power of Choice reforms introduced on 1 December 2017. These reforms aim to empower consumers by enabling access to competitive energy retail offers and smart meter deployment.

A central enabler under this regime is the Embedded Network Manager (ENM), a role accredited by AEMO (Australian Energy Market Operator). An ENM facilitates market access by assigning a National Meter Identifier (NMI) to consumers, enabling them to switch to an on-market retailer of their choice.

Once designated “on-market”, a consumer may later revert to the embedded network (as “off-market”) if they accept an offer from the Embedded Network Service Provider (ENSP).

Regulatory Oversight & Evolving Consumer Protections

AER’s Ongoing Framework Review

The Australian Energy Regulator (AER) continues to refine the embedded network regulatory framework. Its Issues Paper (Nov 2023) outlines key principles: exempt customers should have similar consumer protections as regular retail customers, including the right to choose a retailer.

ENM Solutions further examines the proposed update to the Network Exemption Guideline (Version 7 draft), with important reforms such as:

  • Streamlined regulatory guidance
  • Appointment timelines for ENMs
  • Stronger informed consent obligations
  • Enhanced consumer protections around disconnection and de-energisation for retail customers

Additionally, recent rule changes aim to curb “loyalty penalties”, ensuring embedded network retailers cannot charge prices exceeding the standing offer when contract benefits change or expire, backed by civil penalties. Electricity tariffs cannot rise more than once per year, and certain vulnerable consumers are protected from fees.

Can You Opt Out? Yes, with an ENM’s Support

In summary, yes, many embedded network customers can opt out, but the process involves multiple steps:

  1. Appoint an Embedded Network manager (ENM) – Once appointed, they facilitate the process to go on-market with the retailer of your choice.
  2. Embedded Network Site Information– The operator must supply the necessary data and support conversion.
  3. Technical Viability – Metering and other electrical infrastructure may need upgrading to comply with market requirements and safety standards..
  4. Retailer Willingness– Not all retailers service embedded networks, so you may need to explore options.

While legal rights exist, their feasibility depends on infrastructure, operator cooperation and retailer availability.

Switching to a Retailer of Choice

By understanding the role of ENMs and the broader implications of Power of Choice, businesses can leverage the benefits of this reform to make informed decisions about their energy usage and costs.

How Power of Choice Works

  1. ENM Role: For customers within embedded networks, an Embedded Network Manager (ENM) facilitates their access to the NEM and ensures accurate dataentry into the market systems. The ENM acts as the Local Network Service Provider (LNSP) for ‘On-Market’ customers and, as such, requiressite-specific information to be maintained. The appointment of an ENM is required for certain types and sizes of embedded network.
  2. Metering Choice: Consumers can choose whether to have a smart meter installed, which provides detailed energy usage data.
  3. Retailer Choice: Consumers can select their preferred electricity retailer, who will be responsible for billing and customer service.
  4. Metering Coordinator: A metering coordinator, independent of both the retailer anddistributor, is responsible for managing meter installations,maintenance, and data collection.

Impact on Embedded Networks

For embedded network operators, the creation of the role of an Embedded Network Manager (ENM) is significant. The ENM facilitates the connection between embedded networkcustomers and the broader National Electricity Market (NEM), ensuring accurate registration in market systems.

The Bottom Line

If you’re navigating this process and need clarity or technical support, ENM Solutions specialises in embedded network compliance,  and ENM accreditation to help ensure a seamless transition.

Contact us today!