For property developers designing new Embedded Networks, no single rule change has shaped the market interface as much as Power of Choice.
The reform is not new. The National Electricity Amendment (Embedded Networks) Rule 2015 No.15 commenced on 1 December 2017. Nearly a decade on, its operational implications are still where most developers get caught out at handover, and it now sits alongside a new wave of reform led by Secondary Settlement Points and the NMI Service Provider role from 1 November 2026.
At ENM Solutions, one of the most common challenges we see is developers underestimating how significantly these reforms affect embedded network obligations, particularly around customer access, metering requirements and market participation.
For developers planning apartment buildings, mixed-use precincts, retirement communities or commercial developments, the reforms continue to influence how embedded networks must be structured from the very beginning.
Embedded networks operating under applicable activity classes, particularly larger multi-customer developments may require the appointment of an Embedded Network Manager (ENM) to facilitate customer access to the retail electricity market.
Before Power of Choice, a customer inside an Embedded Network had a practical problem: their meter was not visible to the NEM in a way that let another Retailer pick them up. The Rule solved that by requiring the ENM to sit between the Embedded Network and the market, creating and maintaining a National Meter Identifier (NMI) for the customer's Child meter in MSATS. Once the NMI exists, an authorised Retailer can identify the customer, quote them and take over supply.
One of the clearest outcomes of the Power of Choice reforms was the introduction of the ENM framework.
The ENM is an AEMO-accredited role responsible for managing the market interface within an embedded network. This includes supporting customers who wish to move from an off-market arrangement to an on-market retail arrangement.
The ENM also maintains important market and network information, including:
For developers, this means embedded networks now require far stronger integration between physical infrastructure, metering systems and market-facing operational processes.
The reforms also changed the way embedded networks are viewed by customers.
Historically, many embedded network customers had limited awareness of retail competition or market access rights. Today, expectations around transparency, flexibility and consumer protections are much stronger.
As a result, developers and operators are increasingly expected to ensure their networks can support:
This has made compliance and customer experience far more connected than they once were.
Another important reality in 2026 is that embedded network regulation continues to evolve.
Regulators continue to update exemption guidelines and refine expectations around embedded network operations and customer protections. This means developers should not view Power of Choice obligations as static or “already handled.”
Instead, embedded network compliance should be approached as an ongoing operational responsibility that extends well beyond project completion.
Power of Choice does not sit on its own anymore. Three developments have layered on top of it and matter for any development being designed now.
For a developer, this means Power of Choice is now the floor of the market interface obligation, not the ceiling.
ENM Solutions is an independent specialist in Embedded Networks and an AEMO-accredited Embedded Network Manager. We do not provide billing or retail services, which removes the conflict most developers face when the ENM sits inside the same provider as the ENO and Retailer.
We work with developers, property owners and Owners' Corporations across the NEM on Embedded Network design, ENM appointment, MSATS registration, Power of Choice request handling, and the transition to SSPs and NMI SP arrangements as they come online in November 2026.
To learn how ENM Solutions can assist, contact our team.
