The Australian Energy Regulator (AER) has been progressively tightening the rules around embedded networks, and the latest set of obligations matter for any strata scheme that operates one. This article is a plain-English summary of what has changed, what it means in practice, and how to make sure your scheme is compliant.
A quick refresher on embedded networks
An embedded network is a privately owned network that sits behind a single connection to the public grid and on-sells electricity (and sometimes other utilities) to residents or tenants within the site. They are common in apartment buildings, shopping centres, retirement villages and university campuses.
For an owners corporation, an embedded network can deliver real benefits, including lower bulk-supply rates, better infrastructure, shared use of solar and storage assets, and more control over common-area services. With those benefits come obligations.
What the AER has changed
The AER’s updated framework introduces stronger requirements around four areas in particular.
- Transparency: Exempt sellers (the entity that on-sells electricity within the embedded network) now have to publish their tariffs to customers in a clearer, more accessible way. The era of resident tariffs being available only on request is ending.
- Registration: New small-business and residential embedded networks must be registered on the AER’s public exemption register. Existing exempted providers are not required to retroactively register, but new networks have a clear obligation to do so.
- Consumer protections: Exempt sellers must implement a policy to assist customers experiencing family violence, including identified staff training, account safety measures and tailored hardship arrangements.
- Reporting: Operators must keep registration details current and respond to AER information requests within set timeframes. Stale or incorrect details can trigger compliance action.
What this means in practice for strata schemes
For most owners corporations the practical impact lands in three areas.
The first is documentation. The information the AER expects to see (tariff schedules, complaints handling procedures, family violence policy, contact details, exemption status) needs to be in writing, current, and accessible. Many schemes have parts of this covered and other parts buried in legacy contracts.
The second is operator selection. If the embedded network is operated by a third party (which is common), responsibility for compliance is shared. The owners corporation cannot fully outsource its obligations, even when the day-to-day work is done by the operator. Choose operators that can demonstrate AER-compliant processes from day one.
The third is review timing. Many embedded network agreements were signed years ago, before the latest framework. A periodic review (every two to three years) makes sure that the agreement, the tariff structure and the customer-facing information all match the rules in force.
What to do this year
Three steps in particular.
First, ask your operator for a copy of their current AER-aligned customer information pack. A reputable operator will have one ready to send. If they hesitate or send a thin document, that is a signal worth following up.
Second, make sure resident-facing material on your scheme website (or noticeboard) reflects the current tariff structure and the customer’s right to lodge a complaint. The AER expects this information to be visible, not buried.
Third, review the agreement. Confirm the term, the exit terms, the resident protections and the way infrastructure value flows back to the owners corporation. If anything is unclear or outdated, that is a conversation to have now, not at renewal.
How this connects to the 2026 NSW disclosure reforms
For NSW schemes in particular, the AER’s framework lines up directly with the new disclosure rules that commenced on 1 April 2026. The Strata Information Certificate now has to disclose embedded network details to buyers. Schemes that already meet the AER’s transparency expectations will find the disclosure step straightforward. Schemes that do not will find it exposing.
In other words, complying with the AER framework is not just regulator-pleasing housekeeping. It is also the work that makes the next sale of any unit in the building smoother for everyone.
How Strata Energy Services helps
Strata Energy Services structures embedded network agreements that deliver real value to owners corporations and clear protection to residents, and that meet the AER’s current framework from day one. For schemes with existing agreements, we can run an independent compliance and value review, identify any gaps, and recommend the right path forward (whether that is renegotiation with the existing operator, a market test, or a full re-tender).
If you would like to talk through what the new AER rules mean for your scheme, visit strataenergyservices.com.au.
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