From 1 July 2026,  new NSW Government regulations will introduce requirements for embedded network sellers that supply electricity, gas, hot water or centralised air-conditioning to customers within an embedded network. 

These regulations will also give IPART a compliance and enforcement role for these new requirements. 

Are you an Embedded network customer

You must meet the following requirements

Join the Energy & Water Ombudsman NSW (EWON):

  • be a member of EWON (if you are not already)
  • confirm that your membership covers all the embedded network services (electricity, gas, hot water or centralised air-conditioning) for the number of customers that you supply
  • work with EWON to resolve complaints and comply with EWON binding decisions relating to disputes or complaints involving small customers.

Publish and keep up to date information on your website including:

  • the embedded network services that you supply at each premises  
  • current prices for electricity, gas, hot water or centralised air-conditioning supplied through embedded networks
  • the address of each of the premises where you supply electricity, gas, hot water or centralised air-conditioning through embedded networks
  • If applicable, publish information on centralised air conditioning system efficiency.

If you supply centralised air-conditioning through an embedded network, you must publish on your website:

  • the ratio of cooling energy produced to electrical energy consumed
  • total electrical energy consumed in the previous financial year
  • total cooling energy produced in the previous financial year
  • system brand name or model number.

Centralised air conditioning is the centralised system operated by an embedded network operator for the distribution of heated or cooled air to embedded network customers.

If you are unsure whether these regulations apply to you, you should seek advice or contact IPART.

We recognise these new regulations may require changes to the existing practices of embedded network sellers. Our initial focus will be on engaging with industry to assist embedded network seller in meeting these new requirements and providing information and guidance.

What‘s next

Additional requirements expected to commence in the first half of 2027 will means sellers must comply with:

  • maximum prices published by IPART
  • a billing standard - this may include requirements for how energy use is measured and reflected in customer bills to improve transparency and better align charges with energy use.
Prepare for compliance
Frequently asked questions
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Who do these requirements apply to?

These requirements apply to entities that supply electricity, gas, hot water and centralised air--conditioning to customers in an embedded network in NSW. 

If you are unsure, you should seek advice or contact IPART.

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Do these requirements apply to both embedded network operators and sellers?

The regulations apply to embedded network sellers. In some cases, the same entity may operate and sell energy within a network. Obligations apply based on the role you perform.

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Do I need to register with IPART?

There is no separate registration requirement at this stage. You must comply with obligations set out in the regulations.

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What happens if I am already an EWON member?

If you are already a member of EWON, ensure your membership covers all relevant services and that you comply with EWON requirements.

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Do I have to comply with EWON decisions?

Yes. Sellers must comply with EWON decisions relating to disputes involving small customers. In practice, EWON works with members to resolve complaints. Binding Decisions are a last resort.

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What if I do not have a website?

Sellers will need to establish a website to comply with the reforms.

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When will maximum prices apply?

Maximum prices are expected to start in the first half of 2027. This will give sellers time to prepare.

Under the proposed timeline:

  • IPART expects to publish what the maximum prices will be for embedded networks in September 2026 (subject to Ministerial approval)
  • These prices are expected to commence in the first half of 2027.

Until that time:

  • IPART will determine and publish maximum prices
  • Embedded network sellers will have time to prepare for implementation, including updating systems and processes.

For residential land lease communities, IPART will make a determination of maximum electricity prices in September 2026. This will apply in the short term and remain in place until the embedded network maximum prices commence.

We will provide further updates on timing and implementation, and any consultation opportunities. 

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Will I need to change my billing systems?

You may need to update billing systems to comply with the billing standard. 

This may include:

  • changes to how charges are calculated or presented on bills
  • updates to ensure compliance with maximum prices.

We will consult on these requirements and provide notice before they take effect.

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Will I need to change how I measure or bill energy use?

Possibly. Future billing requirements may include how energy use is measured and reflected in customer bills.

We will consult on these requirements and provide further guidance before they take effect.

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How will IPART’s maximum prices for embedded networks interact with a potential Default Market Offer for embedded networks?

In 2025, the Department of Climate Change, Energy, the Environment and Water published the Outcomes from the review into the Default Market Offer. 

This review recommended that the Default Market Offer (DMO), which set a maximum price for standing offer electricity contracts, be extended to all customers on standing offers and small customers supply by authorised retailers in embedded networks. These protections are expected to commence from 2027-28. 

The Australian Energy Regulator (AER) has explained that it intends to consult with stakeholders on DMO guidelines and in developing a DMO for embedded networks.

IPART will continue to set maximum prices for embedded network services in NSW. IPART’s maximum prices will cover electricity, gas, hot water and centralised air-conditioning.

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Do the embedded network seller requirements only apply where there is a parent-child metering arrangement?

No. While parent-child metering is common in embedded networks, it is not the sole determinant of whether the requirements apply.

IPART will consider the relevant definitions in the National Energy Retail Law (NSW), including the definitions of embedded network, embedded network seller, embedded network customer and embedded network commodity. The overall circumstances of the arrangement must be considered.

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Does IPART administer an exemption or authorisation scheme for embedded network sellers?

No. The embedded network seller requirements do not create a separate IPART authorisation or exemption scheme.

Questions about retailer authorisations, retail exemptions or compliance with other provisions of the National Energy Retail Law should be directed to the AER. If you are unsure how the law applies to your circumstances, you should consider seeking your own legal advice.

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My centralised air-conditioning system cannot directly measure the information required under section 116E. What should I do?

If actual figures are not available, IPART would generally consider it reasonable to publish estimates, provided a reasonable methodology is used and any assumptions and limitations are clearly explained.

Sellers should keep records supporting any estimates they publish.

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Will IPART's billing standard duplicate existing AER or NERL requirements?

No. IPART's billing standard is intended to complement, rather than duplicate, existing obligations under the National Energy Retail Law, National Energy Retail Rules and relevant AER requirements.

Embedded network sellers remain responsible for complying with any applicable obligations administered by the AER.