Australian electricity and gas markets – November 2025 Update

Highlights for October 2025

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

What you need to do

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

National Gas Rules

Final Rule – Extension of the DWGM Dandenong LNG interim arrangements

On 30 October 2025, the Australian Energy Market Commission (AEMC) published its final determination and final rule to extend the Declared Wholesale Gas Market (DWGM) Dandenong liquified natural gas (LNG) interim arrangements. The final rule allows the Australian Energy Market Regulator (AEMO) to address security and reliability risks in the short-term until an enduring fit-for purpose solution is implemented.

The final rule is largely consistent with the draft rule and provides for:

• A four year extension of AEMO’s interim buyer and supplier of last resort powers for the Dandenong LNG storage facility.
• A rules based arbitration mechanism for disputes over extending the LNG storage agreement between AEMO and APA (the Dandenong facility operator).
• Additional measures to limit AEMO’s costs under the interim arrangements.
• Permanent, targeted Part 18 Gas Bulletin Board reporting for the Dandenong liquefaction facility under a standalone facility reporting model (replacing the draft’s joint reporting proposal).
• Permanent extension of Part 19 participant disclosure, LNG storage disclosure, and maintenance reporting and coordination obligations to the Dandenong liquefaction facility, improving AEMO’s operational visibility and efficiency.
• A restriction that AEMO may contract only for uncontracted LNG storage capacity up to the Minister approved target LNG stock level (a new element not in the draft rule).

Draft Determination - Retail customer initiated gas abolishment

On 30 October 2025, the AEMC published its draft determination and draft rule to amend the National Gas Rules (NGR) to introduce a new framework for customer-initiated gas abolishment services in the NGR.

The Rules are currently silent on gas abolishment. Distributors and the Australian Energy Regulator (AER) deal with gas abolishment in access arrangements for pipelines services. This has now been determined as unfit for purpose.

The framework would apply to scheme and any nominated non-scheme gas distribution networks in all jurisdictions except Western Australia. The draft rules would also introduce new information provision requirements in the NGR and National Energy Retail Rules to support more informed decision making by retail customers who are considering ceasing to use gas.

The new framework would be implemented in phases from 2027, with distributors’ key obligations to commence at the start of each network’s subsequent access arrangement. Information provisions would take effect earlier in August 2026.

Submissions on the draft rule are due by 11 December 2025.

Other updates

Queensland Government – Queensland Energy Roadmap 2025

On 10 October 2025, the Queensland Government delivered the Queensland Energy Roadmap 2025. The Energy Roadmap serves as a five-year plan for Queensland’s energy system with a view to delivering affordable, reliable and sustainable energy. Further information about the Roadmap is available in our update here.

NEM Wholesale Market Settings Review

The NEM Wholesale Market Settings Review consultation period closed on 17 September 2025. The Expert Panel will now use the feedback received to finalise the report, which is expected by the end of 2025.

Further information about the draft report is available in our update here.

AER – Market Monitoring Information Order

The Australian Energy Regulator (AER) has published a draft Market Monitoring Information Order and accompanying Explanatory Statement for consultation.

This new draft follows a previous consultation in late 2024, which the AER ultimately decided not to implement after receiving industry feedback. See our previous article here.

The current draft Order details the classes of persons to whom it applies, the information required, and the associated due dates, justifying why the AER needs this data.

Key points of the draft Order:

• Purpose: The Order is considered necessary for the AER to monitor and review the performance, competition, and efficient functioning of wholesale electricity markets and related financial products.
• Applicability: The Order applies to specific Class Members including Retailers, Market Generators, Integrated Resource Providers (IRPs), and Trading Companies.
• Scope: The Order mandates the submission of information from the date the Order is made until February 2031.
• Data Submission Requirements: Class Members must provide
  • One-off Historical Data (2021-2025): Power Purchase Agreements (PPAs).
  • Ongoing Quarterly Reports: Exchange-traded and OTC Standard contracts.
  • Annual Qualitative Responses: Answers to exchange trading, retail qualitative and corporate structure questions.

The decision to limit the scope of the initial order has been welcomed as it simplifies compliance and reduces overall implementation and compliance costs. However, the industry has called for enhancement and independent review of the regulator's arrangements for handling confidential information before any sensitive data is collected. Additionally, the AER's limited high-level communications since the initial draft has caused significant uncertainty, and it has been suggested that businesses be given a minimum of six months to implement reporting systems once the final Order is published.

Submissions on the current draft closed on 04 November 2025.

AEMC – Review of WDRM Mechanism Final Report

On 23 October 2025, AEMC released a final report for the review of the wholesale demand response mechanism (WDRM).

The final report made two recommendations for the WDRM: that the WDRM should continue operating; and that the Expanding eligibility under the WDRM rule change request be initiated.

The final report recognises that the WDRM has enabled some electricity users to have their demand response participation effectively incorporated into market outcomes, which benefits all electricity consumers.

The AEMC's analysis estimates that between October 2021 and June 2025, the WDRM has resulted in:

• $5.32 million ($1.42 million per year) of dispatch energy benefits; and
• $42 757 of emission reduction benefits,

which is greater than its operational costs of $350 000 - $400 000 a year.

Other Authors: Dale Gill, Partner; Paul Newman, Consultant; Savannah Tindiglia, Graduate.