A National Regulatory CER Framework: What it means for retailers and their customers

Australia’s energy system reform continues to be dominated by consumer energy resource (CER) integration. The Draft Prototype National Technical Regulatory Framework for CER proposes a unified national approach to device standards, to device accreditation and to data visibility.  For retailers this is both a tightening of compliance obligations and potentially improves commercial opportunity, whilst for their customers it promises the potential for safer, more reliable and more transparent CER products and services.  We expand on the core implications, and elaborate on the practical outcomes for customers, for retailers, and other stakeholders. 

From fragmentation to a unified code 

The Draft ambitiously proposes a single National CER Technical Code (the Code) to harmonise requirements across PV, batteries, inverters, EV chargers and communications protocols (eg CSIP-AUS).  I say ambitiously because whilst the Australian Energy Market Commission (AEMC) and others have repeatedly flagged the problem and recommended a more enduring national approach, a glance in the rear-view mirror reveals divergent jurisdictional requirements, a product of the multi-jurisdictional ‘competition for good ideas,’ which, while well-intentioned, has in practice added costs and slowed the pace of large-scale commercial deployment.  But we can’t give up.   

The Code is also intended to be updated on an approximate two-year cycle so rule makers can keep pace with innovation, while giving industry some certainty about the timing of shifts in baseline technical requirements.  So, for customers, a functioning single national code should reduce confusion and variation between states, and mean fewer surprises at installation, easier comparison shopping, and a clearer pathway to warranty and dispute resolution if the devices or their associated products fail.  Over time, we would hope that consumers see even smoother interoperability between systems.  For example, solar plus storage plus EV charging that actually plays well together. 

And for industry, harmonised rules should logically shrink compliance complexity, and other duplications such as divergent testing regimes across jurisdictions.  Thus, making the longed for national product lines and cross jurisdictional offers easier to develop and manage.  As noted above, the two-year update cadence gives merchant product developers a predictable horizon for any certification planning.  But it also means retailers and others must watch the Code cycle and plan their product and compliance pipelines accordingly. 

Accreditation: raising the bar 

Under the proposal, only accredited devices could be imported, sold, installed or connected. Installers would need to be accredited with electrical licencesplus CER specific training and will be required to undertake annual continuing professional development (CPD).  Sellers and Distribution Network Service Providers (DNSPs) would be required to verify installer accreditation before enabling a connection. 

In theory, this raises the bar on safety and reduces the risk of incorrect installations or mis-specified systems, a clear benefit for customers who should therefore experience better workmanship, clearer accountability and a smaller chance of expensive failures or performance shortfalls.  Done well, this is clearly an important initiative. 

Raising the bar always means more effort is required to clear it, and that effort comes at a cost.  For those selling CER-related products and services to customers, their product procurement, partner selection and channel management will require strict controls and oversight.  They will need, for example, formal processes to verify installer accreditation before accepting their connection services.  This means those selling CER-related products and services to customers may need to invest more in installer training partnerships or build accredited installer networks themselves. Within all of this there will inevitably be both short and long-term costs, and a potentially slower time to commercialisation for new products.  But the clear long-term benefit should theoretically be fewer product warranty issues and higher customer confidence in CER services.   

Data and visibility obligations 

A nationally maintained Installed Device Register is central to the Draft.  Installers, OEMs, aggregators, VPP operators and DNSPs and potentially others will be required to update the register at installation, during servicing, or whenever device settings are changed remotely. This is designed to close visibility gaps that currently hinder system planning and security. 

You’d have a right to be skeptical here.  The Australian Energy Market Operator’s (AEMO) Distributed Energy Resources (DER) Register was launched in 2020 to improve visibility of rooftop solar, batteries, and other small-scale resources connected to the grid.  It was intended to give network operators, AEMO, and policymakers the data needed to plan, operate, and integrate these resources into the power system. 

The DER Register was built primarily as a compliance mechanism.  It required installers to input data, but as a tool didn’t create operational or planning value. This meant the original policy intent of improving visibility of DER for system security and planning wasn’t matched by the mechanism. The result being data that was incomplete, lagging, and often unusable in real-world operations.  So, what’s different this time? 

At this stage, the register remains largely a theoretical construct, with many of its potential benefits yet to be demonstrated in practice.  In theory a central register supports faster fault diagnosis, transparent provenance for hardware and easier transfer of service when moving home.  All of which are useful to CER owners and customers.  It could also, for example, make it easier to trace a recalled model or confirm that an installer was or is accredited. 

And in theory the register might be a potential operational asset.  Retailers and others will face new reporting requirements the register could manage, as well as leverage register data to manage their fleets, reduce internal operational costs, and provide better service like, for example, proactively contacting customers with CER devices with known issues. 

But a major open question for retailers and others is whether they’ll get real-time read/write access.  This is important given the DER Register already exists as a compliance mechanism requiring installers to input data.  As mentioned, the policy intent of improving visibility of DER for system security and planning was never matched by the original mechanism.  For the new Installed Device Register, this real time access is the difference between operationally useful and administratively cumbersome reporting. 

Orchestration and consumer offers 

In good news, the Draft explicitly supports dynamic device management by embedding the technical and data expectations into the Code.  I think that strengthens the foundation for retailer-led orchestration and also introduces clearer oversight where devices’ remote settings are changed.  For retailers this might mean that orchestration becomes a much nearer term and more widespread product channel for customer engagement.  Of course, the Draft also brings compliance requirements, but these may well be a positive for consumer confidence.  Retailers will need robust demonstrations of consent, accurate records of remote changes, and processes to demonstrate compliance with the devices register and other Code requirements.

For retail customers, dynamic services promise better value through both payments for exported energy and lower bills through coordinated dispatch.  And of course, the likely reliability benefits for the broader grid.  Retailers will need to work out clear, simple consent proformas and straightforward opt-outs.  Customers will also still need clear explanations of how orchestration affects appliance use or warranties; a complex matter often not easy to put in layman’s terms. 

Building consumer confidence 

To help with all this required information and explanation provision, the regulator plans consumer-facing tools such as accredited device and installer lists, clearer complaint pathways, and educational guides.  The Draft describes adopting a regulatory posture focused on guidance and education. The aim is to raise trust in CER technologies and related products, and to give consumers clear ways to check device and supplier/installer credentials and to raise issues. 

For engaged customers, access to an accredited device/installer list and plain language guides should reduce perceived risk and increase confidence to buy CER and related products.  But we should learn from experience like the Better Bills Guideline in this regard.  Requirements for orchestration products that are set too high with limited consumer benefit are both ineffective and expensive.  And they can have the unintended consequence of limiting innovation.  The messaging in these regulatory materials will be very important. 

To ensure customers find consistent information across regulator and retailer channels, retailers aligning public messaging with the regulators materials will also be important.  If well made by regulators, then retailers can potentially lean into these consumer tools to demonstrate their own commitments, for example by advertising that the devices and installers they use appear on the national lists.  Not unlike Clean Energy Council (CEC) accreditation.   

The regulator’s posture and capabilities 

The Draft signals a consumer-centric, facilitative regulatory approach with an emphasis on prevention, guidance, and collaboration over heavy-handed punitive enforcement, at least initially. While this has been said before, it matters because such an approach should create opportunities for co-design through consultation. It should allow for staged implementation, sensible customer education windows, and time to bring all actors up to standard before penalties are applied 

So retailers should lean in because it should mean a runway to adapt processes, to engage in consultation, and to influence practical aspects of implementation.  It also means retailers could actively engage in the consultation to shape workable compliance paths and avoid last-minute surprises.  And for retail customers, a facilitative approach that prioritises education, reduces abrupt market disruptions and builds consumer confidence is obviously ideal.   

 The challenge, however, is that a facilitative approach with an emphasis on prevention is often seen as slow or even dismissive. Regulators can quickly find themselves under pressure from ministers, consumer advocates, or the media if they are perceived as too lenient and failing in their watchdog role. Every complaint carries potential political and reputational weight. For this posture to succeed, consistent commitment will be required from both regulators and stakeholders. If achieved, it could mark a shift toward more constructive regulation— or maybe this is an idea that’s time is still to come. 

Compliance burden or market opportunity? 

The Draft leaves several practical issues to be clarified in consultation, including: 

• How retailer-led orchestration and DOEs will be regulated in practice. 
• The cost and time burdens of accreditation. 
• Real time updates and the specific fields of the Installed Device Register, and  
• Whether demand shifting devices like hot water systems, pool pumps etc. are brought into scope. 

For retailers and their customers, the Framework is both a compliance obligation and a potential platform for growth, the net effect of which should be safer, better integrated CER products and fewer dodgy installations.  Customers should benefit from improved product reliability and clearer value propositions. 

At face value, this Draft is an early but meaningful step toward a more consistent, visible, and consumer-friendly CER ecosystem. For retailers, the path forward is pretty straightforward in principle: line up accredited products and partners, build operations that work with the Installed Device Register, and design orchestration offers that are simple and transparent for customers. For consumers, the promise is a safer, easier, and more rewarding way to participate. 

Of course, much depends on how the regulatory posture and the many open implementation questions are resolved. If these land in ways that are practical and well-communicated, then maybe it’s worth topping up your coffee and sticking with the journey to see how it unfolds.