December 18, 2025
On 15 August 2024, the AEMC finalised the flexible trading rule changes, enabling Secondary Settlement Points (SSPs) for large customers to engage multiple energy service providers at the same premises, and giving small customers options to separately measure and manage flexible Consumer Energy Resources (CER) with their existing Retailer/Financially Responsible Market Participants (FRMP). The determination also introduced two new meter types—Type 8 (for CER behind the primary meter) and Type 9 (for street furniture / previously unmetered supply)—to reduce measurement cost and complexity. Most of the new arrangements commence by 1 November 2026 (with Type 9 commencing 31 May 2026).
Through this process, the AEMC considered who would be responsible for creating and maintaining secondary National Metering Identifiers(NMI). Following workshops and industry submissions in 2024 it was initially proposed that Distribution Network Service Providers (DNSPs) should perform this function, as they do with primary NMIs. However, following additional consultation and feedback, the Commission settled on the creation of a contestable NMI Service Provider role to reduce DNSP system changes and costs.Stakeholder feedback highlighted significant DNSP implementation costs($7m–$70m across DNSPs) and supported a specialised accredited service provider model, similar in concept to an Embedded Network Manager (ENM) for embedded networks.
AEMO’s 2025 Flexible Trading Arrangements (FTA) consultation has translated these rules and determinations into changes to Retail Electricity Market Procedures, MSATS roles, device service levels,and market transactions needed to stand SSPs up in the market. Currently, these are being drafted and finalised for release in early 2026.
Large customers: Multiple FRMPs, Clearer Allocation of Value
For large Commercial & Industrial(C&I) sites, SSPs allow a second FRMP to manage flexible resources separately from inflexible “passive” load, without the need to create a second connection point or establish an embedded network. This enables dedicated retail tariffs, wholesale market participation, and ancillary services to be structured specifically for flexible CER (e.g., battery discharge, EV smart charging), improving the economics of flexibility and the visibility of CER in settlement and operations.
Importantly, the flexible trading framework will operate parallel to existing embedded network arrangements— meaning there is no requirement for large customers currently using embedded networks to switch.SSPs offer a different solution that allows for a more fit-for-purpose mechanism to engage multiple FRMPs for flexibility; embedded networks remain valid where their specific site configuration and objectives warrant it.
Small customers: Measuring New Value Opportunities
For households and small businesses (small customers),SSPs provide a way to separately measure CER (battery, EV charger, smart hot water) under an arrangement the same FRMP as the Primary Connection Point. This enables tailored retail products (e.g. dynamic tariffs for CER while keeping linear tariffs for passive load), better orchestration signals, and more accurate attribution of value streams from CER to the customer or aggregator without introducing multiple retailers at the premises. Overall, reducing complexity for the average customer while improving opportunities to access new energy products.
Street furniture and public infrastructure - Type 9 metering
The rule also introduces Type 9 metering for streetlights, public EV chargers,smart street furniture—areas previously unmetered or measured via bespoke or convoluted methods. The AEMC forecasts up to $100m in benefits over 20 years from lower installation/maintenance costs, reduced wholesale costs, and emissions reductions, with Type 9 metering set to commence 31 May 2026.
Under AEMO’s FTA design, the NMISP is responsible for establishing, linking, and maintaining secondary settlement point NMIs in MSATS behind the primary NMI. That includes NMI allocation to the SSP, MSATS setup, ongoing standing data maintenance, under defined service levels under AEMO’s procedures, published in November 2025. This role will mirror many of the same functions as the existing Embedded Network Manager function, without the connection and requirement of site responsibility,retaining only management and maintenance responsibilities at the secondary connection point.
AEMC’s May 2024 consultation note weighed DNSPs vs. FRMPs vs. metering parties vs. a new accredited role; submissions positions were mixed with some DNSPs pointing to high system costs and complexity in building connection-point hierarchies and billing/analytics changes. The introduction of a contestable NMISP model avoids those DNSP costs, leverages existing market accreditation pathways (akin to those of ENMs), and promotes competition and responsiveness for secondary NMI services. DNSPs retain visibility of SSP metering data via a Premises Network Service Provider access mechanism in MSATS, allowing them to opt out of meter data delivery, but ensuring right to access this data as a support for network planning and safety.
While some industry providers (including ENM Solutions) are already signalling a readiness to offer NMI SP services to retailers, energy service providers, and asset owners ahead of the 2026 go-live,not all participants will be able to support market delivery of these services at scale and in line with new market procedures.
VPP orchestration with cleaner settlement: With separate NMIs for CER, dispatch, baselining, and settlement can become cleaner, reducing allocation disputes and smoothing compliance with market procedures. Retailers can develop product lines that price flexibility separately from passive load, increasing customer uptake and portfolio value (e.g., peakshaving, ancillary services).
Street furniture portfolios: Type 9 opens standardised measurement and settlement for municipal lighting and public EV charging, enabling retailers/aggregators to scale offers with lower costs and fewer bespoke agreements.
Tariff innovation without multi-retailer complexity: SSPs enable differentiated tariffs and incentives for CER (e.g., EV smart charging plans) while maintaining one FRMP, reducing the consumer confusion risk flaggedin submissions and the AER’s Better Bills Guideline context.
Type 8service levels: Ensure devices used for SSP measurement meet Type 8 performance and data requirements. AEMO’s procedure changes codify new metering installation type codes and substitution rules; metering providers and coordinators will need updates to processes and inventory management.
Wiring and subtractive settlement: Electrical installation updates must support subtractive metering (i.e., accurate separation of flows to flexible devices). AEMO’s high level impact assessment (HLIA) and FTA documents outline data model/schema impacts and subtractive metering tables you’ll need to map into site design and commissioning processes.
FRMPs require MSATS transactions to nominate an NMISP, create SSP NMIs, and maintain links to the primary NMI. Market participants should plan system changes and operating procedures now to meet the 2026 dates.
De-energisation protections: The final design prohibits separate de‑energisation of SSPs for small customers, a safeguard raised during draft-to-final changes,to protect vulnerable customers and avoid unintended loss of essential services controlled via CER.
Communication and consent: Customer journeys and consent flows must becrystal clear to ensure that customers can clearly distinguish between products, and make informed choices with clear lines of consent.
Victorian eligibility refinement: AEMO has proposed a follow-on rule change to fix drafting that unintentionally restricted SSPs at premises with Victoria AMI (Type 5 under Orders in Council). The amendment would focus on remote acquisition capability rather than specific meter types, to enable equitable access in Victoria; this proposal is pending AEMC initiation and consultation.
SSPs and the NMISP role bring flexibility into the heart of NEM settlement and retail operations—without the overhead of new physical connection points or embedded network constructs where they’renot necessary. For retailers, aggregators, asset owners, and large customers,the prize is cleaner market access to CER value, better product design, and less friction in measurement and settlement. The timeline is tight, but clear. Those who standardise SSP processes in 2025 willbe the ones offering compelling, scalable CER propositions in 2026.
AEMC Final Rule & Overview: Unlocking CER benefits through flexible trading
AEMO FTA Issues Paper & Draft Report
AEMO Consultations Page (FTA Final Report)
AEMC Consultation Note (May 2024)
AEMO Draft Service Level Procedure - NMI SP
Refining the eligibility requirements for Secondary Settlement Points
