As Australia’s energy market continues to evolve, the Australian Energy Market Commission’s (AEMC) latest rule change proposal on Unlocking Consumer Energy Resources (CER) Benefits through Flexible Trading marks a significant step forward. At ENM Solutions, we’re proud to be part of the conversation: bringing our deep expertise in embedded networks to help shape a more flexible, consumer-centric energy future.
The AEMC is proposing a new way for consumers to access and trade their energy more flexibly. This includes the introduction of “secondary settlement points” (also known as child NMIs), allowing customers to appoint different electricity retailers for different parts of their usage. For example, exporting solar to one retailer and consuming energy from another.
At the heart of this proposal is the creation and maintenance of these NMIs through a newly proposed “NMI Service Provider” role - functions that ENM Solutions already delivers at scale.
Embedded networks are often used in multi-unit dwellings, commercial precincts and large customer sites to streamline energy supply and improve efficiency. For years, ENM Solutions has provided consultancy Embedded Network Manager (ENM) services, ensuring customers within embedded networks can access retail competition. While we specialise in NMI creation and maintenance, we remain independent - we do not provide billing or operator services.
The AEMC’s proposal aligns closely with the ENM function, especially around NMI creation and management. With years of industry experience and frameworks already in place, we believe existing ENMs are ideally placed to support the rollout of secondary settlement points.
One of the biggest opportunities in this rule change is customer empowerment. By decoupling generation and consumption at the metering level, customers, especially those with solar PV or batteries gain more control over how they manage and monetise their energy. This flexibility is particularly valuable for:
However, barriers still exist. Current delays in creating embedded network codes and NMIs often stretching up to 12 months can hinder customer access. By allowing accredited ENMs to take on this role, the process can be streamlined significantly.
We support the AEMC’s approach in making this an optional role for existing ENMs. Not all ENMs may be set up for these additional tasks, but for those of us already managing NMI creation, taking on the NMI Service Provider role would be a seamless transition. With proper governance, system access (such as MSATS permissions), and clear commercial arrangements, ENMs could help accelerate market adoption of flexible trading models.
The proposal also raises interesting questions about embedded networks within embedded networks, and how grandchild NMIs might work in complex arrangements. ENM Solutions has long been involved in such scenarios and is well positioned to support innovative models, including behind-the-meter energy trading and new market roles.
ENM Solutions welcomes the AEMC’s proposed rule change and supports a pathway that enables embedded network customers, large and small, to unlock the full benefits of CER. With our established track record in NMI creation, embedded network management, and support for small generation aggregation, we’re ready to help the industry take this next step.
Read our full submission to the AEMC here.
Want to understand how this could apply to your building or development?
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