Flexible Trading Arrangemements (FTA) is now live: Secondary Settlement Points and the NMI Service Provider explained

November 12, 2026

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Written by

Angus

Flexible trading is now live

From 1 November 2026, customers in the National Electricity Market (NEM) can now establish secondary settlement points within their premises. This is the final stage of the AEMC's Unlocking CER benefits through flexible trading rule, made in August 2024, and AEMO's Flexible Trading Arrangements (FTA) program.

For the first time, a single premises can have more than one point that is metered and settled in the market, without the need for a second physical connection to the distribution network and without setting up an embedded network. A battery, an EV charger, a solar system, or flexible plant can now carry its own National Metering Identifier (NMI), its own meter data, and, for large customers, its own energy service provider/retailer.

The reform also creates a new accredited market role, the NMI Service Provider (NMISP), to create and maintain the NMIs for these secondary settlement points. ENM Solutions is accredited by AEMO as an NMI Service Provider and is ready to support customers, retailers, and aggregators taking up the new framework.

In December 2025, we set out what was coming and when. Now that the rules are live, this article focuses on how they work in practice: the eligibility tests, how the arrangements differ for large and small customers, which meters can be used, and where secondary settlement points can now do the job that once needed an embedded network or a second connection.

What is a secondary settlement point?

A secondary settlement point (SSP) is a metering installation inside a customer's premises that is registered in the market as its own settlement point, with its own NMI. It sits behind the premises connection point (PCP), which is the existing point where the premises connects to the distribution network.

In practice, an SSP lets a customer separate flexible loads and resources, such as batteries, EV chargers, and controllable plant, from passive loads like lighting and refrigeration. The flexible resource can then be priced, traded, or managed as required. When an SSP is classified as a market connection point, its energy is settled on its own NMI and the PCP is settled subtractively. If an SSP is not classified as a market connection point, no subtractive calculation is made and the PCP's FRMP stays financially responsible for that energy.

Under new clause 7.2.6 of the National Electricity Rules (NER), a Market Participant can establish an SSP when the premises and the meter follow a set criteria.

The premises must:

  • be supplied through the national grid
  • not have a PCP that is a connection point for a scheduled resource, or one in a regulated stand-alone power system (SAPS)
  • have a PCP meter that can be read remotely and provides trading interval data (this general test replaced an earlier list of meter types in April 2026, so premises with Victorian AMI meters can now have SSPs too)
  • have a Financially Responsible Market Participant (FRMP) participating in the market at the PCP

The SSP metering installation must:

  • comply with the NER requirements that apply to it
  • in an embedded network, not measure a child connection point or supply to another end user
  • not be a type 8B meter unless the customer is a small customer

Before participating in the market at an SSP, the FRMP must appoint an NMI Service Provider, and keep one appointed for as long as it is the FRMP. AEMO can refuse to let a FRMP participate at an SSP if it has not done so.
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The new NMI Service Provider role

Servicing SSP's are the NMI Service Providers, a new market role that requires AEMO Accreditation to participate within the market. Holding this accreditation requires a MarketNet connection, ability to transact with MSATS, public liability and professional indemnity insurance, and requirement to complete periodic AEMO audits. Importantly, accreditation is required for this role even where a business already holds other accreditations, such as the ENM, Metering Provider, or Metering Data Provider roles.

Every SSP must have an accredited NMI Service Provider. The NMISP creates the SSP's NMI, registers it in AEMO's Market Settlements and Transfer Solution (MSATS), and maintains accurate standing data for as long as the SSP exists.

We covered why the AEMC chose a contestable role over distribution network service providers (DNSPs) in our earlier article. In short, the role builds on functions an Embedded Network Manager (ENM) already performs. Within MSATS, the NMISP sits in the Local Network Service Provider (LNSP) role for the SSP, while the LNSP for the PCP is recorded in a new Premises Network Service Provider (PNSP) role. Noting that for SSP's created behind child connection points - the PNSP would be the ENM of that child NMI.
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Large customers: more than one energy service provider at one site

Large customers get the most flexibility. The FRMP for a large customer SSP can be different from the FRMP at the PCP. That means a manufacturer, cold store, hospital, or shopping centre owner can keep its retailer for the building, and appoint a different party to buy, sell, or optimise the energy flowing through a battery, solar array, or EV charging hub on the same site.

Under the NER, a large customer's SSP can be classified as a market connection point of:

  • the customer itself, if it is registered with AEMO as a Market Customer or an Integrated Resource Provider (IRP)
  • another Market Customer or IRP, with the customer's consent
  • an IRP acting as a Small Resource Aggregator (SRA), for a small resource SSP within the large customer's premises

Common large customer scenarios now include:

  • Separate battery trading. The site retailer keeps the PCP. An aggregator becomes FRMP for the battery SSP and trades it in the wholesale and frequency control markets.
  • Fleet or public EV charging. A charging operator becomes FRMP for the charging hub SSP on a commercial site, with its own tariff and settlement, while the landlord keeps its own retail contract.
  • Solar export under a separate offer. A large solar or solar-and-storage system is placed behind its own SSP so its exports can be sold under a different arrangement to the site's consumption.
  • Multiple SSPs at one site. A site can have more than one SSP behind a single PCP, for example one for a battery and one for a charging hub.

Where a large customer has different retailers at the PCP and an SSP, the National Energy Retail Rules (NERR) treat it as a shared customer of the distributor and each retailer separately. There is no need for a contract between the two FRMPs although they are encouraged to liaise with their customer ot ensure the acticities of one retail arrangement on the network are understood for the other.

Within the AER's Draft Retail Exempt Selling Guideline (version 8), they confirm that a non-authorised FRMP selling energy to a large customer through an SSP can rely on the existing R5 registrable exemption class. On the network side, the AER's draft Network Exemptions Guideline (version 8) confirms that creating an SSP does not, by itself, require a network exemption, including for customers of a Small Resource Aggregator. The AER expected to finalise both guidelines in November 2026.
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Small customers: one retailer, separate settlement

Households and small businesses can also have SSPs, but with one key difference. The FRMP for every SSP must be the same as the FRMP for the PCP. The AEMC chose not to allow multiple FRMPs at small customer premises at this stage, pending further work on consumer protections.

What small customers gain is visibility and choice of product. A retailer can now offer a separate tariff or service for a home battery, EV charger, or hot water system, settled on its own NMI, while the rest of the home stays on the existing plan. The FRMP can also appoint a different Metering Coordinator at the SSP from the one at the PCP.

The NERR amendments keep small customers protected:

  • An SSP arrangement is treated as part of the supply arrangement with the customer's retailer, and existing consumer protections extend to it.
  • Where separate contracts or bills are used for the PCP and SSP, the NERR apply to both in the same way.
  • A retailer cannot de-energise an SSP on its own. It can only do so where de-energising the whole premises is allowed, and re-energising the premises must include the SSP.
  • A retailer cannot repair or replace a customer's secondary meter without the customer's consent.
  • If a customer-provided secondary meter malfunctions and is not repaired in the time the NER allows, the retailer can move the customer to a tariff that does not use SSP data.
  • Standing offers may, but do not have to, include SSP arrangements.

Importantly, if a residential small customer changes retailer at the PCP and no matching transfer is raised for the SSP, MSATS automatically moves the SSP to the new FRMP, sets it to off market, and applies zero settlement data. The SSP is not disconnected, but the new retailer has to choose to support it.
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Which meters can be used?

Throughout the formation of these rules and operational preparation, one question that frequently arises is around the metering that can apply at Secondary Settlement points. Despite common misconceptions, Type 4 meters and/or those that meet a higher burden of measurement/performance/specification and market standards can still be used at an SSP. For a small customer, the NER states a new or replacement meter at an SSP must be either a type 4 or a type 8B meter that meets the minimum services specification. For large customers, the standard meter types remain available alongside the new type 8A. Customers and retailers do not have to adopt the new meter types to take up an SSP, although there are requirements around how these are classified in the market systems.

Despite this, the rule allows for three new metering installation types with lower minimum specifications than type 4. The purpose of this change was to allow in-built measurement devices such as EV chargers and inverters be used for settlement, instead of installing a separate revenue meter.

A few rules apply to types 8A and 8B:

  • The measuring device needs pattern approval from the National Measurement Institute before it can be used for settlement.
  • Any person qualified under the relevant law can install the meter, and it can be provided by the customer or someone acting for them.
  • Where the customer installs the meter, the Metering Coordinator appoints a Metering Provider to commission and maintain it.
  • If a customer-provided type 8A or 8B meter malfunctions, the FRMP must tell the customer that repairs are needed within 20 business days. If they are not done, the SSP is made inactive and its energy reverts to the premises until the repairs are complete.
  • Metering Providers and Metering Data Providers need specific AEMO accreditation to service type 8 and type 9 installations.
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What secondary settlement points can now replace

Before 1 November, a large customer that wanted a second energy service provider on site had two main options. It could set up an embedded network, with a parent connection point and a child NMI for the flexible asset, or it could pay for a second physical connection to the distribution network to get a second NMI. The AEMC noted the embedded network framework was never designed for this, and both options carry cost, time, and compliance overhead.

Secondary settlement points give these customers a purpose-built path. The table below shows how common arrangements compare.

While embedded networks can still be utilised for these solutions and may be simpler for those already established where a site supplies more than one end user, such as an apartment building, shopping centre, or retirement village, SSPs become a new option for energy solutions providers and customers to consider rather than be restricted to embedded networks. Conversely, SSP's do not replace child connection points. An SSP cannot measure a child connection point or supply to another end user, and a NMI cannot be both an embedded network parent or child and an SSP at the same time. Each are separate NMI allocations for separate connection points.

However, the two frameworks can work together. A customer inside an embedded network can establish an SSP within their own premises, for example for an EV charger or battery behind their child connection point. The AER's draft guideline confirms an embedded network remains an embedded network when individual customers adopt SSPs, and the exempt network operator keeps its existing obligations. Perhaps of most note in these scenarios is that the exempt frameworks of relevant jurisdictions will continue to apply.

Existing arrangements do not have to change. Customers using an embedded network to access a second provider can stay on that framework or move to SSPs if and when it suits them.
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Considering a Secondary Settlement Point? Here's a quick-start checklist:

SSPs are voluntary, but they come with rules that shape what is possible at each site:

  • Site eligibility. SSPs cannot be set up where the PCP serves a scheduled resource or sits in a regulated SAPS. If a site later stops meeting the criteria, the FRMP must stop classifying the SSP as its market connection point.
  • PCP Metering Configuration: The meter at the PCP must be compliant and configured appropriately to be ellgible for SSP Creation.
  • No nesting. An SSP cannot have its own downstream SSPs, although one PCP can have several SSPs.
  • Customer classification. The customer's primary retailer decides whether the customer is small or large under the NERR. Being the same business across several premises does not automatically mean premises can be aggregated. If a site moves from large to small, an SSP with a different FRMP must be adjusted to off-market.
  • Retailer appetite. Small customers depend on their retailer offering an SSP product. Retailers are not required to include SSPs in standing offers.
  • DNSP/LNSP access to data. The LNSP for the premises NMI is recorded against the SSP and can choose to receive SSP metering data, for Child NMI's with SSP's behind them - the LNSP will be the ENM for the Child NMI.
  • Meter malfunctions. Customer-provided type 8 meters carry a 20 business day repair window before the SSP is made inactive, so maintenance arrangements matter.
  • An NMISP at all times. If the FRMP changes, the new FRMP must have an NMISP in place. AEMO can refuse a FRMP change or a new SSP without one.
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ENM Solutions is an accredited NMI Service Provider

ENM Solutions is one of the first providers to be accredited by AEMO as an NMI Service Provider and is ready to create and maintain SSP NMIs from day one of the new framework.

The NMISP role was modelled on the work Embedded Network Managers already do, a service we have also been providing as one of the first accredited since 2017 - an area we have extensive experience. As one of the longest serving and only independent Embedded Network Managers in the NEM, we create and manage NMIs in a variety of scenarios and configurations, along with MSATS standing data and market transfers. Appointing ENM Solutions as your NMISP means you do not need your own accreditation, MarketNet connection, or specialist market systems to offer SSPs. We have also supported Small Resource Aggregators to bring customer resources into the market through embedded network arrangements, meaning our team are experienced and ready to go using SSPs as an option to simplify this process.

Having been actively engaged in this reform from the start and heavily involved in industry testing amongst a vast array of test scenarios prior to the go-live date, our team are ready and waiting to help you get started and be an early mover in Secondary Settlement Points and Flexible Trading. This includes an applied understanding of how these arrangements intersect with embedded networks, exempt frameworks and use cases.

We can help:

  • Retailers and FRMPs appoint an NMISP and arrange SSP NMIs allocation, created, and maintained to AEMO's service levels.
  • Small Resource Aggregators and IRPs set up SSPs at large customer sites, and work out whether an existing embedded network arrangement should move to an SSP.
  • Large customers and site owners understand whether an SSP, an embedded network, or a mix of both suits their site, assets, and commercial goals.
  • Embedded network operators understand how SSPs within their networks affect their exemption and compliance obligations.

As with all our work, we bring a high level of service, transparency, and depth of market knowledge. If you are considering a secondary settlement point, or want to understand what flexible trading means for your sites, talk to our team at 1300 000 366, get in touch online, or read more about our NMI Service Provider services.

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