May 14, 2026
The Australian Energy Market Commission (AEMC) has published a draft determination and more preferable draft retail rule, for the National Energy Retail Rules (NERR) aimed at improving how life support customers are identified, registered and protected across the electricity sector. The rule change responds to issues with inaccurate life support registers, unclear responsibilities between parties, and inconsistent communication during outages and planned works. Importantly, within this draft rule are material changes to the way life support is captured and communicated within Embedded Networks involving Market Retailers.
The draft rule forms part of the Improving Life Support Processes review initiated by SA Power Networks and Essential Energy and applies across jurisdictions that have adopted the National Energy Retail Framework.
The draft rule proposes changes across three main areas.
The draft rule introduces a clearer definition of a life support user as the person who relies on life support equipment, separate from the electricity account holder. It also allows a medical practitioner to identify when a life support user has a life-threatening condition, intended to support better prioritisation during outages. Existing protections for life support customers are not reduced under the draft rule.
Retailers are made responsible for all aspects of life support registration,ongoing maintenance of customer details and de-registration. Retailers would be required to:
- Ask customers at the point of signing up,whether a life support user resides at the premises.
- Maintain current life support information through annual checks.
- Use a new standardised medical confirmation form to support registration where required.
Retailers would be required to record preferred contact methods for life support customers and capture a secondary contact person where nominated. These requirements are intended to support clearer and faster communication with life support customers during interruptions to supply.
Implications for embedded networks
A significant change under the draft rule is the explicit inclusion of embedded networks in life support notification processes.
Under the draft rule, retailers are required to notify the Embedded Network Manager, where one is appointed or the Exempt Embedded Network Service Provider (EENSP) otherwise, when a life support customer is registered at premises within an embedded network. This is intended to improve visibility of life support risk within private electricity networks and support better site level management during outages and planned works.
Embedded networks, however, operate under arrange of different supply and retail arrangements. These include off market and on market customers serviced by market retailers. In most embedded networks,the party with a direct relationship to the customer or the parent NMI retailer,to assist managing outages and physical supply is not the embedded network manager. This creates practical considerations around how life support information is shared and acted on within embedded networks.
ENM Solutions has provided a submission to the AEMC focused specifically on the embedded network impacts of the draft rule.
In that submission, we have:
- Supported the objective of improving life support protections and greater visibility of life support customers within embedded networks.
- Highlighted that embedded networks operate under different retail and metering scenarios that are not consistently distinguished in the draft rule.
- Raised concerns that notification requirements default to the embedded network manager, even where that party may not have a material role with customers,outages, or site energy supply at the embedded network.
- Noted known delays in medical confirmation processes within embedded networks and supported any changes that streamline those processes.
- Identified risks during de-registration and changes in embedded network manager appointments where market records may not reflect current operational arrangements.
Throughout our submission we have also suggested that greater flexibility in notification pathways, clearer recognition of embedded network supply models, and alignment with existing exemption frameworks would support the intent of the draft rule and improve outcomes for life support users within embedded networks.
ENM Solutions continues to engage with the Australian Energy Market Commission on the practical application of the draft rule to embedded networks and will monitor the progression of the rule change as it moves toward final determination.
