Australian electricity and gas markets – August 2025 Update

Highlights for August 2025

In this update, we take a look at the latest rule changes and market updates published in July 2025, which affect participants in the Australian electricity and gas markets.

Additionally, on 6 August 2025, the NEM Wholesale Market Settings Review draft report was released. Further information about the draft report is available in our update here.

What you need to do

• Stakeholders should note the market updates below, and note any impacts on their compliance obligations.

National Energy Retail Rules

Rule change request – Improving life support processes

On 31 July 2025, the Australian Energy Market Commission (AEMC) published a consultation paper following a rule change request from Essential Energy and SA Power Networks. This proposal seeks to improve life support customers' outcomes by amending definitions and processes. The issues identified by the proponents fall into three specific groups of amendments:

• improved definitions of life support customers to focus resources on those most in need and enable more targeted civil penalties for breaches;
• improved registration and deregistration processes to ensure registers are accurate and up to date; and
• improved communications methods.

Victoria has its own life support framework under the Energy Retail Code of Practice. The Essential Services Commission of Victoria (ESCV) is considering the same or similar reforms as described in the rule change request. The AEMC has stated that it is working closely with the ESCV to ensure life support processes are as closely aligned as possible.

The AEMC is seeking feedback on the consultation paper by 4 September 2025.

Draft Determination – Improving the application of concessions to bills

On 3 July 2025, the AEMC published a draft determination and draft rule to improve customer awareness of electricity and gas concessions and rebates. This is in response to a rule change request from the Hon. Chris Bowen MP, Minister for Climate Change and Energy, as Chair of the Energy and Climate Change Ministerial Council. The draft rule would require retailers to, at the time a customer signs up to an energy plan:

• ask customers about their eligibility for concessions or rebates – prompting consideration and voluntary disclosure.
• Provide jurisdiction-specific information on concessions and rebates – helping consumers understand what is available and how to access it.

The AEMC is seeking feedback on the draft determination and draft rule by 14 August 2025.

National Gas Rules

Draft Determination – ECGS projected assessment of system adequacy

On 17 July 2025, the AEMC published a draft determination proposing the introduction of two new projected assessment of system adequacy (PASA) forecasts for the East Coast Gas System. The two forecasts, to be published by AEMO on its website, are:

• Short-term (ST) PASA: Published daily, covering a seven-day horizon; and
• Medium-term (MT) PASA: Published weekly, covering a 12-month horizon.

Both PASA forecasts would include projections for demand, supply, and infrastructure availability. The ST PASA would also highlight any identified threats to reliability and supply adequacy for the upcoming week.

The assessments would be based on data collected from market participants and/or modelled by AEMO, including information on market and non-market demand, storage, LNG exports, gas-powered generation, and infrastructure availability.

The AEMC is seeking feedback on the draft determination and draft rule by 28 August 2025.

Other Updates

Department of Climate Change, Energy, the Environment and Water - National H2 Regulatory Guidebooks

As part of the National Hydrogen Regulatory Review, Commonwealth, state and territory energy and climate change ministers have developed the National Hydrogen Regulatory Guidebooks for hydrogen production facilities. and hydrogen refuelling facilities.

The purpose of these Guidebooks is to:

• Provide industry participants with a foundational understanding of hydrogen, including its properties, as well as an overview of hydrogen production and refuelling facilities, associated hazards, and mitigation measures.
• Identify current regulatory obligations at the Commonwealth, state and territory levels for both hydrogen production and refuelling facilities.
• Offer guidance on how to meet these regulatory obligations in relation to hydrogen production and refuelling facilities

Feedback is sought on whether the Guidebooks are accurate and correct, comprehensive, and usable.

Consultation closes on 19 August 2025 and submissions can be made here.

AEMC – Draft Report on wholesale demand response mechanism

On 10 July 2025, the AEMC released a draft report on the wholesale demand response mechanism (WDRM). In this report, the AMEC has made two draft recommendations:

• the WDRM should continue operating in the NEM; and
• the Expanding eligibility under the WDRM rule change request should be initiated, to consider whether sites with multiple connection points should be allowed to participate in the mechanism.

The Commission is seeking feedback on the draft recommendations by 14 August 2025. Publication of the final report is expected by 23 October 2025.

Australian Energy Regulator – Annual compliance and enforcement report 2024-25

On 23 July 2025, the Australian Energy Regulator (AER) published their annual compliance and enforcement report  for 2024-25 which details some of the significant compliance and enforcement actions undertaken during this period. The AER notes that over the financial year, they imposed more than $53 million in penalties from four court outcomes and 25 infringement notices; they accepted two enforceable undertakings; released 18 publications including consultations and have two civil proceedings in progress.

AEMO – 2026 Integrated System Plan process

On 31 July 2025, AEMO published several key forecasting and planning reports for use in the 2026 Integrated System Plan (ISP) process:

• The 2025 Inputs, Assumptions and Scenarios Report which outlines the scenarios, modelling inputs, and assumptions that AEMO will use in its forecasting and planning activities over the coming year, serving as inputs for the 2026 ISP.
• The 2025 Electricity Network Options Report, which forms part of AEMO's two-yearly consultation on network inputs to inform the 2026 ISP and identifies potential augmentation options in electricity networks within the NEM.
• The 2025 Gas Infrastructure Options Report, which outlines the gas infrastructure options and cost components suitable for the East Coast Gas Market and will be used to develop gas development projects for the 2026 ISP.

These reports are significant as they mark the halfway point of the 2026 ISP development process.

Authors: Dan Brown, Partner; Dale Gill, Partner; Aylin Cunsolo, Partner; Paul Newman, Consultant; Savannah Tindiglia, Graduate and Isabella Skene, Paralegal.