Frequently Asked Questions on the Alternative Electricity Services framework

Previous consultation on the Voluntary Embedded Network Code of Practice and On-site Power Supply Arrangements (OPSA) occurred in 2024.

Following this consultation, the WA Government has decided to regulate embedded networks and OPS arrangements under the AES framework. The regulation of other services may occur under the AES framework in the future.

Consultation on the AES draft Prescribing Regulations is now open, and further information on the AES Registration Fees and Code of Practice is expected to be provided in the first half of 2026.

Registrations for AES providers is expected to commence in early 2027.

An embedded network is a private electricity network servicing several lots or tenancies in one property. A master meter connects the property to the grid. The master meter also measures the electricity supplied for everyone on that property at that connection point.

The operator of the embedded network may be the property owner (or owners), or a third party under contract.

Embedded networks are often found in apartment buildings, retirement villages, long stay parks, shopping centres and office buildings.

If you receive an electricity bill from Synergy or Horizon Power, you are not part of an embedded network.

For more information about embedded networks visit: Understanding Embedded Networks in Western Australia.

The Prescribing Regulations Reading Guide defines OPS arrangements and outlines what type of business models will have to register under the AES Framework. For information on the Regulations visit Consultation on the Alternative Electricity Services (AES) Prescribing Regulations

At a high level an On-site power supply (OPS) arrangement is an arrangement under which a customer pays a third-party operator to use all or part of the electricity from the energy system that is installed on their property.

A common example is when a business installs its own solar panels on a customer’s rooftop. The customer often does not pay anything upfront for the system. Sometimes, customers pay for the electricity (on a cents per-unit basis). In other cases, customers pay a subscription fee to use or have access to the electricity provided by the solar system.

An OPS can involve the installation of any type of electricity generation of storage system, like solar panels, batteries, but also wind turbines or diesel generator.

For more information on OPS Arrangements visit: Understanding On-site Power Supply Arrangements.

An Energy Policy WA survey conducted in 2022 found that embedded network customer experiences vary greatly. 59% of residential customers have neutral to positive experiences, with 41% reporting poor experiences.

Over 60% of residential customers reported paying less for electricity than non-embedded network customers. However, residential customers have a high-level of distrust in embedded network due to lack of upfront information.

Non-residential embedded network customers reported a higher level of negative experiences being in embedded networks, often due to excessive pricing and inability to access alternative tariffs.

The embedded network customer survey provides more information on the experiences of embedded networks customers. 

The on-supply of electricity in embedded networks emerged as a practical way for electricity to be supplied to end users in properties like caravan parks and shopping centres. It was not the core business of the on-supplier, and so only very limited regulation was considered necessary.

Over time, these arrangements have become more sophisticated and widespread, with service providers stepping in to manage these services.

Some customers are experiencing very poor outcomes in embedded networks due to lack of customer protections and provider obligations

Regulating this kind of service under the existing electricity retail licensing framework would have been extremely onerous and costly for providers, raising costs for consumers.

By creating the AES framework, the Cook Government can apply tailored customer protections under a low-cost regulatory arrangement.

Embedded networks are one of the first two services that will be regulated under the new framework.

The second is on-site power supply (OPS) arrangements, such as ‘solar as a service’. That business model was closed to new entrants in WA by the former Minister for Energy in 2019, due to customer protection concerns.

By regulating OPS arrangements under the AES framework, the market can be safely opened to new entrants again.

After a thorough consultation process, the Cook Government has now decided that the first two services to be regulated under the AES framework will be on‑site power supply arrangements, like solar power purchase agreements, and the supply of electricity in embedded networks.

The Cook Government would like to thank all the stakeholders that attended the public forums and provided submissions as they were invaluable in informing the decision to regulate.

Energy Policy WA released consultation papers to inform the decision to regulate, and went to great lengths to reach as many stakeholders as possible, specifically:

• invited (via email) 1,838 stakeholders to provide feedback, with 37 submissions received; and
• held public forums for stakeholders on embedded networks and OPS Arrangements on 5 and 7 March 2024, which were attended by 104 and 53 stakeholders respectively.

For more information on previous consultations, visit the Alternative Electricity Services Consultations web page.

Consultation on the AES prescribing regulations is currently open to 27 February 2026.

Information on the AES Registration Fees will be provided soon, with further information on the AES Code of Practice to be provided in the first half of 2026.

The AES prescribing regulations will set out what activities are to be regulated and what will be exempt from regulation.

The AES Code of Practice will describe the obligations that providers of each service need to comply with.

The AES Registration Fees will describe how much registration holders are required to pay. 

The AES framework has been designed to be flexible enough to apply to a wide range of electricity services where there is a demonstrated need or additional customer protections. 

To apply customer protections in a flexible and low-cost way, a new regulatory framework was needed. WA is the first jurisdiction to create a bespoke framework to deliver tailored customer protections for new electricity services.

The legislation to create this framework was established in 2024, and since then Energy Policy WA has been undertaking detailed consultation with stakeholders to develop the rules for the first two services to be regulated.

Once the rules are in place, affected providers will need time to prepare and register. The Regulator (the Economic Regulation Authority) and the Energy and Water Ombudsman of WA will also need time to prepare for their new functions under the framework. To allow time for preparation, the new rules are expected to come into effect in 2027. 

These people are encouraged to contact the Consumer Protection Contact Centre on 1300 304 054 or via consumer@lgirs.wa.gov.au

Energy Policy WA will be rolling out communications and awareness and education campaign to reach affected consumers of embedded networks and OPS Arrangements. Resources will be online and available for download for AES providers and organisations to distribute to their patrons and residents. 

The regulation of on-site power supply arrangements will open the WA market to new providers of these arrangements. This business model was closed to new entrants in 2019 due to customer protection concerns.

New providers can expect to be able to enter the market in 2027.

The National Credit Code governing Australian Credit Licences offers protections relating to the financial arrangements between customers and lenders or providers of hire-purchases.

However, it doesn’t offer electricity-specific customer protections, for instance, the disclosure of information to customers that allow them to understand the implications of the electricity supply arrangements, such as whether there can be external control of an electricity system, the process for it to be connected and how much electricity the system produces over time.

Additional regulation is also needed to give customers access to the Energy and Water Ombudsman to assist with dispute resolution. 

Core protections will focus on matters such as suitable disclosure of information and access to an independent dispute resolution body.

Where the service involves the primary supply of electricity, such as in embedded networks, there will be a broader suite of protections for matters such as customers experiencing financial hardship and/or family and domestic violence.

The AES Code of Practice will set out the obligations for providers of each service covered by the AES framework. These obligations will be tailored and fit-for-purpose for each service.

The AES Code of Practice is currently being drafted, information on the Code is expected to be provided in 2026.

The Voluntary Embedded Networks Code of Practice and the Draft OPS Code describe the types of obligations that may become mandatory.

The first priority will be to ensure providers are educated and given opportunity to comply with the obligations under the framework.

If that does not resolve the issue, the regulator will have a toolkit of enforcement options that it can use if a service provider remains not compliant. These include enforceable undertakings, and the ability for the regulator to take actions to cause the non-compliance to be rectified.

Ultimately, if a service provider continues to fail to register or fail to comply with requirements, they could face penalties of up to $100,000 plus $5,000 per day.

There will be an information program to raise awareness of the coming reforms, with detailed material to be made available about who will be affected and how to prepare.

Energy Policy WA will be publishing a range of resources, including guidance materials and standard form documents and policies, for service providers to use to prepare for the changes.

Ensure you’re registered to receive Sharing the Power Updates to keep up to date with the latest information.