If you own, operate or oversee an Embedded Network, compliance with the Australian Energy Regulator (AER) is no longer a background task. It is a core operating requirement.
At ENM Solutions, we see firsthand how quickly compliance gaps translate into operational, commercial and customer-facing problems, particularly since the AER released Version 7 of both the Network Exemption Guideline and the Retail Exempt Selling Guideline in August 2025, and set out its Compliance and Enforcement Priorities for 2025/26.
The good news is that most of these problems are avoidable when Owners and Operators treat compliance as an ongoing program rather than a one-off exercise.
Embedded Networks operate within a detailed regulatory framework, including the National Electricity Rules (NER) and the National Energy Retail Law under the National Energy Customer Framework (NECF), overlaid by the AER's Network and Retail Exemption Guidelines. Failure to meet these obligations can result in penalties, operational disruption or a fundamental change to how the network is structured.
The AER's 2025/26 Compliance and Enforcement Priorities have sharpened the focus in four areas that directly affect Embedded Networks:
Compliance issues almost never appear overnight. Outdated site information, unclear internal processes, incomplete record keeping or an unassigned Authorised Representative may not cause immediate disruption. Over 12 to 24 months, they compound.
We see it most often when Owners need to:
The longer these gaps sit, the more expensive they are to close.
Many aspects of the embedded network framework are designed to support customers.
Exempt providers who invoice customers for network-only charges after they have moved on-market are now subject to a payment difficulties framework that mirrors the Retail Exempt Selling Guideline. Family violence considerations have also been strengthened for retail selling within Embedded Networks.Customers are aware of these changes. Residents in apartment buildings, retirement villages, shopping centres, commercial buildings and caravan parks are asking more informed questions about their rights, their retailer options and how their site is being managed. Owners' Corporations, committees and property managers expect clear answers.Where processes are current, those conversations are straightforward. Where they are not, they escalate to the Energy and Water Ombudsman or the AER.
One of the key objectives of the embedded network framework is to support customer access to retail competition where applicable.
When a customer chooses to move from an off-market arrangement to an on-market arrangement, the relevant systems and processes need to be capable of supporting that transition.
This relies on:
If compliance arrangements have not been maintained, supporting these requests can become significantly more complicated.
A proactive approach places your network in a much stronger position to respond when customer requests arise.
When records, documentation and operational processes are maintained consistently, compliance reviews are generally straightforward.
However, when compliance has been neglected over time, reviewing and correcting issues can become far more resource-intensive.
Additional time may be required to:
Maintaining good practices today helps avoid larger challenges later.
The Embedded Network sector continues to evolve. Beyond the electricity guidelines, the Victorian Government's Gas Embedded Networks General Exemption Order 2025 introduced new obligations for gas Embedded Network Operators, including participation in Energy and Water Ombudsman schemes and compliance with the Gas Distribution Code of Practice. The AEMC has also flagged a broader Electricity Network Regulation Review, and Secondary Settlement Points and the NMI Service Provider role are on the horizon.An Embedded Network carrying unresolved compliance issues from earlier guideline versions will find each of these changes harder to absorb. A network that is already current has a much shorter path.
Reactive compliance costs more in every dimension: cash, time, customer trust and regulatory standing. The Embedded Networks we work with that treat compliance as a program share a few habits:
This is the approach the current regulatory environment rewards.
ENM Solutions is an independent specialist in Embedded Networks and one of the few Embedded Network Managers accredited by AEMO before 1 December 2017. We do not offer billing or retail services, which means our advice on your compliance position sits outside any conflict with your Retailer arrangements.
We work with Embedded Network Owners, Operators, property developers, strata managers and Owners' Corporations across Australia to interpret the current guidelines, review existing site arrangements, and manage the ENM function for customers exercising Power of Choice.
If you would like a review of where your network stands against current AER expectations, our team is available to help.
