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September 2025 – Australia
Submission on the National Technical Regulatory Framework for
Consumer Energy Resources.
10th September 2025
CER Taskforce
Department of Climate Change, Energy, the Environment and Water
GPO Box 3090
Canberra ACT 2601
Lodged electronically
SolarEdge Technologies is a global frontrunner in smart energy solutions, particularly renowned for revolutionising how solar power is harvested and managed with its direct current (DC)-optimised inverter systems. Since its foundation in 2006, the company has shipped over 57 GW of systems and monitors more than 4.3 million solar installations across 145 countries, demonstrating its considerable global reach and technological leadership. SolarEdge’s design, pairing optimisers with a string inverter, boosts energy yield, enhancing output by 2%–15% in all settings and delivers up to 50 extra days of energy per year. Its broad, diversified product line (including inverters, power optimisers, monitoring platforms, electric vehicle charging, and battery storage) further underpins its strong market position and appeal to a wide range of energy stakeholders across both residential and commercial distributed markets.
SolarEdge welcomes the opportunity to respond to the Department of Climate Change, Energy, the
Environment and Water’s consultation on the National Technical Regulatory Framework for Consumer
Energy Resources.
Introductory remarks
The National Technical Regulatory as well as the surrounding framework is arguably the most important element of the National CER Roadmap, as products and their appropriate function underpin everything.
The consultation prototype for a National CER Technical Regulatory Framework misses a few very key elements that currently block the smooth uptake and installation of CER in Australia.
Firstly, when the topic of technical standards is raised, it appears that the onus is on the existing
Standards Australia framework and most importantly, the fact that in some circumstances standards can take a long time to produce and can sit somewhere behind the industry. Although this is true, it is not the real issue.
In some circumstances, standards can take a long time to produce; however, once they are produced, they can be amended and updated very quickly, depending on the level of change. Adoption periods can vary, as these are purely optional and at the discretion of the industry. In other circumstances,
September 2025 – Australia technical standards through the Standards Australia process, such as a ‘Technical Specification’, can be produced very quickly without the need for rounds of industry consultation, and again without the necessary need for a transition period.
When Standards such as IEC Standards are referenced, as soon as they become altered or updated, they take effect immediately, which, although in principle sounds good to not delay progress, can actually have a very damaging effect on industry, as there is no time to amend products.
Whatever Standards and technical requirements are developed by the National Technical Regulator, they need to be considered under the existing legal framework of compliance. AS/NZS 3000 is a legally binding set of requirements for electrical installations, known as the wiring rules. In this Standard, it references all of the standards related to the CER industry, so by nature, all of those standards become legally binding and need to be adhered to. Furthermore, AS/NZS 4777.2 is referenced in the NER, so careful consideration needs to be applied to any changes made around these requirements.
One of the biggest issues that faces the CER industry, when it comes to technical requirements, is that any entity can produce its own set of technical requirements at any time and itself dictate the implementation time frame. We have seen this from AEMO, ERAC, ESV, DNSPs and in State and Federal rebate policy.
As the following illustration highlights, all of the entities sitting above the CER industry can create technical requirements for CER, the implementation requirements and self-managed governance.
September 2025 – Australia
The governance structure around the implementation or interpretation of any technical requirements of
CER installation or function is ad hoc at best. In most states, it falls on the electrical inspection regimes to carry out inspections and compliance work. However, in many circumstances, the electrical inspectors may not themselves be certificated CER installers, or they interpret the requirements for products and their installations, which can contradict the intention of the Standards.
There needs to be a full, ground-up approach to governance of the compliance regime considered as part of the National Technical Regulator role, as it is critical to creating national consistency.
In the same context, when considering national consistency, there seems to be a lack of comment or consideration within the consultation prototype of the roles of Distribution Network Service Providers
(DNSPs). Currently, we have the situation where the implementation of the technical requirements contained in AS/NZS 4777.1:2024, for example, is being applied differently by DNSPs throughout
Australia. This kind of lack of consistency is extremely difficult to manage, especially when installer accreditation and training are already nationalised through the SAA. Having to create regional variations in technical requirements is an industry burden that should be addressed as part of this work stream.
It is strongly recommended that the role of the National Technical Regulatory be created through a completely new, dedicated entity. None of the current Australian regulators, such as the AER or CER, has the capability or experience to carry out the role. Furthermore, there is a real risk of conflict of interest from both entities when it comes to designing, creating, implementing and managing the technical requirements for the CER sector.
Feedback on Consultation Questions
1. Do the system outcomes capture what is needed for the CER system to function?
a. CER investment is attractive for consumers –
Growth in CER is already exceeding all expectations of the CER and AEMO. In
light of the current uptake of the Federal Cheaper Home Battery Program, it is
clear that investment by consumers is already attractive.
Currently, there is no roadblock in the foreseeable future that will hinder this.
What the industry has consistently experienced throughout the last 15 years is
that product prices only continue to fall. This is against the continuously rising
cost of electricity and network charges.
These factors are what make the payback period for CER devices attractive; it has
very little, if anything, to do with any of the technical requirements.
September 2025 – Australia b. Supplying CER devices and services is economically attractive for business –
To maintain the appropriate regulatory settings to ensure CER products are
available, the regulatory cost for industry needs to be managed carefully to
ensure that costs do not increase, and time for commissioning and approvals also
does not increase.
One key element that needs to be considered regarding the competitive nature
of market services, especially in the context of the M3/P5 workstreams, is that the
current regulatory framework for DNSPs often favours incumbents, limiting the
evolution and competitiveness of new entrants and the development of
consumer-centric technology solutions. c. CER devices are installed, configured and connected correctly –
The effective operation of CER for consumers and as a contributor to networks is
already very well defined and understood. The significant majority of all DER
operate and function exactly as they should.
According to the latest memo update from AEMO:
“The available data from various sources consistently indicates that 80-90%
of new inverters installed in early 2024 (Q1/Q2) Australia-wide were
correctly configured to the correct 2020 Standard grid code.
They observed improvements in compliance, have been largely due to
voluntary actions taken by inverter OEMs, such as removing legacy
standards from their product menus to better support installers in selecting
the correct standard at the time of installation. Amendments to product
menu listings have now been mandated under AS/NZS4777.2:2020
Amendment 2, taking effect in August 2025.
Poor disturbance ride-through outcomes persist for 30-100kW DPV and
100kW-5MW PV non-scheduled generation (PVNSG) despite improvements
in inverter compliance. 5-30MW PVNSG appear to successfully perform
disturbance ride-through, based on limited evidence available to date.
Projections indicate a plateauing of the total size of the DPV fleet that
demonstrates poor ride-through capabilities from 2024 onwards.
AEMO continues to recommend that governance gaps in monitoring and
maintaining compliance with technical standards are addressed as a
priority, including defining roles and responsibilities for managing
compliance, and ensuring availability of suitable datasets for monitoring
compliance. Recommended actions include the following, noting that
progress is underway in several cases:
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o OEMs: implement 2020 Standard amendments, improve datasets
for compliance assessment and continue to improve compliance
where feasible.
o DNSPs: develop mature compliance assessment capabilities,
update Model Standing Offers (MSOs) to facilitate remote inverter
updates and update technical standards to reflect recent
AS/NZS4777.1:2024 changes.
o AEMO and DNSPs: collaborate to investigate 30kW–5MW
disconnections, improve visibility of 30kW–30MW systems, develop
technical performance requirements for 200kW to 5MW systems,
improve DER register data and quantify DPV replacement rates.”
To these points, AS/NZS 4777.2:2020 Amd 2_2024 is already mandatory across
Australia; products not meeting these requirements have been removed from the
CEC product list.
The comments regarding the poor disturbance ride-through outcomes persisting
for 30-100kW DPV and 100kW-5MW PV non-scheduled generation come down
to the correct operation of inverters within the context of AS/NZS 4777.2 section
2.11, so this is not due to an issue with devices being installed, configured and
connected incorrectly.
In summary, installation and configuration of CER are on track to meet industry
expectations of compliance. Although there is still room for improvement, the
real focus should be on how compliance is measured and by whom rather than
the what. d. CER devices connected to the grid are visible, coordinated and secure, and support
system security –
It has not been established why, or how the greatest benefit for CER owners and
all consumers is achieved when CER can participate effectively in energy supply,
assuming energy supply relates to participating in a VPP or Flexible Export style
arrangement.
Currently, and for the foreseeable future, the worst financial outcome for a
consumer is to export energy to the grid.
In light of the prolific uptake of the Federal Cheaper Home Battery Program, and
the scale at which consumers are buying batteries (average system size as of
September 2025 – Australia
August 202 at 17.8kWh), it is evident that consumers favour self-sufficiency over grid participation.
The proportion of CER devices recorded in the CER Installed Device Register, as well as the proportion in the register which are up-to-date and conformant, helps the DNSPs as well as AEMO.
It is worth noting that the current market approach from Government, AEMO,
DNSPs and other market bodies is that data without any regulatory structures, ringfencing or governance arrangements is accessible and freely available.
There is no current regulatory framework for DNSPs to access consumer, behind- the-meter data. The use of network-driven (via network utility servers) access to
CER via functions such as CSIP-AUS for mandatory backstop mechanisms is enabling a free ride into data that should, in normal conditions, be out of bounds to networks.
This overreach, under the umbrella of addressing system security risks, is limiting the evolution and competitiveness of new entrants and the development of consumer-centric technology solutions as aggregators and VPP providers have to compete with DNSPs that have first access to visibility and control of CER, thus controlling what should be a competitive market.
It should not be a given, that CER device and functional data is available and free to access, albeit with additional metrics and data sets highlighted in the consultation paper.
It needs to be understood and clearly defined that the DNSP's jurisdiction starts and stops at the connection point, not within the data harvesting and processing region of CER.
The use of protocols such as CSIP-AUS for Emergency Backstop Mechanisms
(EBM) should be for that purpose only, not a route to gain visibility and control permanently.
Access by DNSPs for EBMs should be only when instructed by AEMO that an elevated risk scenario has been reached. There should also be a maximum communication period within which CCSIP-AUS can be used, and after it expires, the utility server should automatically delete the consumer's CER data.
Exceptions apply, specifically when a consumer has granted access to a DNSP of the CER, and as such allows them to harvest and store data; this would normally be when a DOE or Flexible Export product offering has been accepted.
September 2025 – Australia
It is recommended that the National Technical Regulator Framework should be
focused on creating independence in the distribution system operation and
network planning/ownership, improving transparency and accountability of the
performance of DNSPs, and minimising regulatory cost and complexity, as such
the focus should be on enhancing the use of Smart Meter Data in the first
instance.
Throughout the delivery of the outcomes and principles of the National CER
Roadmap, consumers should be considered first, not the system as a whole.
Consumers are pivotal within this transition; without their consent, buy-in and
cooperation, any plan will struggle to become realised.
e. Innovation and new risks are proactively managed –
Having the regulation support continued product and service innovation while
maintaining a stable and secure system is no different to the current situation.
New devices or services already have to meet all Australian product and
installation standards. This is not a new requirement; it is purely a business-as-
usual statement.
2. Are the current challenges, examples and impacts comprehensive? Is a National CER Technical
Regulatory Framework the best mechanism to resolve these?
a. There is a series of critical challenges missing. These can be included in the proposed
framework functions and CER objective, but have not been included:
Current Challenges Proposed Framework Functions
Any entity (including international IEC, etc) can create a technical requirement on Australian CER equipment. Defining and creating all
Technical Requirements should be managed via the Technical regulator
No hierarchy of technical requirements – no national coordination. The development and implementation of all Technical Requirements need to be managed and coordinated to ensure that the industry can National CER Technical Code manage the development and implementation demand.
No governance structure. There needs to be a clearly defined and managed Governance structure throughout Australia detailing the roles and responsibilities of all parties when it comes to the development, implementation and interpretation of technical requirements for CER.
September 2025 – Australia
DNSPs have no jurisdiction over installers. Currently, when trying to retrieve installation data or enforce retrospective compliance activities, often the DNSP cannot enforce the installer to do anything as the relationship is between them and the homeowner. There needs to be consideration for DNSP to have a legal, enforceable relationship with installers for connection and compliance practices.
Support CER system integrity
Technical requirements hinder product development and innovation. All
Technical requirements should be developed with an outcomes- based approach rather than a prescriptive method to ensure innovation and product development do not become hindered.
3. Are the five regulatory functions the appropriate priorities for the National CER Technical
Regulatory Framework?
1. Establishing national CER technical requirements
This function should not only specify the technical requirements and standards for CER
products and protocols, published in a National CER Technical Code, it also needs to
manage the development process. This will include the coordination of national
(Standards Australia) and international (IEC, UL) adoptions, amendments, development
and most importantly, their interpretations.
In addition, the technical requirements’ role should coordinate the national demand for
the development of technical requirements. Technical requirements historically have
come from AEMO, ERAC, DNSPs and the likes of Solar Victoria. It should be the case that
under the new proponent, national CER technical requirements are requested. The
development and implementation of the requirement should also be managed by the
Technical Regulator. This way, the effort to create the technical specification and manage
its implementation can be coordinated along with the rest of the technical requirements
Implementation is a critical function within the CER environment. It has been the case, for
instance, that OEMs have been required to manage both the changes in product
standards (AS/NZS 4777.2:2020 AMD 1) as well as develop and implement the
emergency backstop mechanisms (EBM) across three network servers in Victoria and
implement the VPP and EBM requirements in Synergy region of WA all at the same time.
To achieve the technical implementation and performance required for the CER system
to meet CER system outcomes, there has to be a more transparent update process of
requirements and a work plan that looks at all CER requirements.
September 2025 – Australia
2. Mandatory accreditation of CER devices
This function already exists, the way that is has been described within the draft prototype
implies that this currently is not the case and therefore it is a risk which is not the case.
The main issue that the industry faces when it comes to product accreditation and
product listing is that there are multiples and duplicates within the Australian industry.
All CER that can be connected either directly or indirectly to the grid, including Solar
Modules, inverters, batteries, and bi-directional EV Chargers, have to be tested, certified
and listed on the Clean Energy Council’s website. This process is robust, tested and
extensively proven over many years.
Additionally, products also need to be listed on the ERAC/EESS list, which covers Victoria,
Queensland, Western Australia, and Tasmania. With transitioning jurisdictions are South
Australia, the Northern Territory, and the Australian Capital Territory. The ERAC listing
scheme does not offer any service to check or validate test reports, documentation or
certification, so it is seen as a ‘self-declaration’ process that has no scrutiny or validation,
unlike the robust listing process of the CEC.
For state, or DNSP-based rebate or eligibility schemes, other listing processes exist, such
as in the Synergy or Horizon regions of WA where they hold eligibility lists of products
approved for installation. Or in South Australia, where the Department of Energy and
Mining require all EV Chargers to be listed with them, showing evidence of the capability
to be remotely controlled.
The burden of managing multiple listing processes for OEMs, and the industry as a
whole is excessive and needs to be streamlined into a single listing process to ensure a
single source of truth when it comes to what can be installed and where.
This function would enable a streamlined national market for CER devices for OEMs and
installers, lowering costs for businesses and consumers.
3. Mandatory installer accreditation and accountability
The mandatory installer accreditation function via Solar Accreditation Australia (SAA)
already exists when CER, such as solar modules, inverters and batteries are being
installed and are subject to a rebate scheme.
The only thing to be added with this regard is the need for mandatory installer
accreditation to be extended to all CER, such as EV Chargers, regardless of whether or
not the devices are to be installed under a rebate scheme or are to be used on or off-
grid.
September 2025 – Australia
The requirements for any CER device installer to hold a valid electrical license already
exist; the CER device accreditation should be added to this license, rather than the
individual having to hold two separate licenses.
4. Mandatory updating of CER connection information
This function, in principle, is a good idea but requires careful consideration as it can
become very heavy on industry in terms of administration.
The concept of accountability is important to address; it is agreed by SolarEdge that any
installer who installs, modifies, repairs or upgrades and CER installation should be able to
be traced and registered.
There needs to be very clear definitions, though, on what actions would define or trigger
the need to update registration information. Ideally, it should be any act that changes,
amends or alters the CER device or system function.
5. Support CER system integrity
The regulator/s role and function, as described, seems reasonable.
What is missing, though, and is critical for industry, would be the role of interpreting and
defining the exactness of Standards and technical requirements.
The current situation, whereby the interpretation of installation standards, for example, is
held by electrical inspectors, who individually interpret the requirements, which can differ
within the same region of the same state. Or the situation where the same installation
and connection Standards are interpreted differently by different DNSPs cannot
continue. This is extremely difficult to manage by OEMs and training bodies when the
requirements are not consistent.
4. What are the barriers to implementing the proposed regulatory functions? What opportunities
are there to leverage existing approaches?
There should be no batteries to implement the proposed regulatory functions.
Establishing national CER technical requirements
Currently, no new technical standards or requirements need to be designed or
developed. The Technical Regulator function can simply leverage what exists and
produce a streamlined and coordinated implementation and interpretation
pathway for the industry.
Mandatory certification of CER devices
The Technical Regulator function can leverage the CEC product list, extend this to
capture all EV Charger devices.
September 2025 – Australia
The listing criteria and contained information can be extended so that entities
such as ERAC, SA’s DEM and DNSPs can defer their listing requirements to this
singular process.
Mandatory installer accreditation and accountability
The Technical Regulator function can leverage the SAA installer accreditation
process but extend the requirements at a national level to ensure that
accreditation is held when installing any defined CER devices, not just within
rebate settings.
Mandatory updating of CER connection information
To the best of SolarEdge's knowledge, there are no existing opportunities or
functions that the Technical Regulator could leverage to deliver this function. It
will have to be created.
Supporting CER system integrity
As with establishing national CER technical requirements, currently, no new
technical standards or requirements need to be designed or developed.
What is missing, though, and is critical for industry, would be the role of
interpreting and defining the exactness of Standards and technical requirements.
The Technical Regulator function can leverage all current technical requirements
and synthesise them into a single set of requirements which are nationally
consistent and clearly interpreted.
5. What work is underway which might interact with the proposed regulatory functions? How
could these interactions be managed?
Existing processes and functions, such as the standards development work of Standards
Australia and the IEC mirror committees, the CEC product list and SAA installer
accreditation, are already well established. Interactions and work processes should be
coordinated and managed by the proposed regulatory functions.
6. How do we ensure regulatory decisions are consumer-centric?
To ensure regulatory decisions are consumer-centric, there needs to be a process where
cost and benefit to the consumer are considered first.
Other than basic electrical safety requirements, all other technical requirements imposed
on CER have been done to support the network; these have all come at the cost to the
consumer.
September 2025 – Australia
7. Is the suggested compliance and enforcement approach appropriate and achievable?
To ensure conformance and compliance is appropriate, we agree that auditing,
surveillance and monitoring to manage accreditation compliance is achievable, the
ability to conduct enforcement activities itself or work with actors who have the
capabilities, however, needs to be defined, i.e. what entities have the capabilities?
When it comes to device functionality, rather than the burden being on the regulator to
carry out the auditing, surveillance and monitoring function, it would be far simpler to
impose a mandatory reporting process to the regulator from both DNSPs and OEMs as
they will be able to very clearly identify products that are either commissioned
incorrectly or are functioning improperly.
Compliance-by-design
This approach seems to focus on a bottom-up regime to surface non-conformant
CER devices. It sounds, from the brief description, to be very open-ended and
retrospective.
Compliance-by-design should be very simple to implement; it would be a process
whereby the product requirements and their installation requirements are pre-
defined. Only approved products are listed and able to be installed. Therefore,
there should be no need for multiple lines of defence at different stages of the
CER lifecycle (import, sell, install, connect) to surface non-conformant CER
devices, as this would all be triaged via the product listing process.
Monitoring compliance
Testing protocols already exist through the independent testing and certification
process, which validates that devices are eligible for certification and meet
performance standards prior to product listing.
Although the CEC currently adopts a risk-based profiling and randomisation
testing approach, it does not rule out OEMs bringing products into the country
that do not have the correct settings, or, which is more likely, installers do not set
the correct values into the device when commissioning it.
Risk-based profiling based on the level of market penetration is not a good idea,
as penetration rates from certain OEMs or product types fluctuate greatly.
Monitoring compliance should be very simple and straightforward; rather than
the Technical Regulator looking to impose a burdensome and expensive
monitoring regime, the regulator should just impose a mandatory reporting
process to the regulator from both DNSPs and OEMs, as they will be able to very
September 2025 – Australia
clearly identify products that are either commissioned incorrectly or are
functioning improperly.
Responding to non-compliance
There needs to be a hierarchy of non-compliance and a risk-based approach
taken. For instance, a warning label placed on the cover of a home battery is
technically non-compliant, but it is not a safety risk. Not placing an emergency
shutdown label, however, would be a safety risk.
Notification and/or publication of non-compliance results is a bit heavy-
handed without defining what is the level of non-compliance and who was
responsible for it, was it the OEM, the installer or others?
Rectification power to formally require corrections or mitigations of non-
compliance, however, is important; having the power to enforce installers to go
back to rectify issues of non-compliance should be the number one priority.
Suspension of processing new listing applications. This statement makes no
sense. I believe the intention here is to stop installers from applying for a new
CER device to be connected. If so, this is not going to achieve anything, as it’s
very often the CER sales company that applies for a device connection from a
DNSP; the installer could be one of many who get the job of installing it.
Suspension or cancellation CER device listing; and potentially of other
devices for the same OEM. This requirement is very concerning. What is the
threshold that would define this decision to be made? Secondly, if an OEM did
have a product issue, and the solution was to introduce a new product that could
be used to replace the defective ones, suspending them from being able to list
the replacement product would be a very poor outcome.
Relevant actions under Australian Consumer Law seem to be reasonable,
although the obligations are on the OEM or retailer acting on their behalf. The
use of the ACL will have limited application unless it is extended to the actions of
the installer.
Infringement notices, penalties, etc., again sound reasonable, but who would
these be directed at? OEM, installer, aggregator, DNSP? More definition is
required.
National Consistency
Having a single certification scheme to be adopted nationally for the overarching
benefit of national consistency would be an ideal and supported outcome.
September 2025 – Australia
8. How do we maintain effective regulation while minimising the regulatory burden for installers?
It needs to be simple and clear.
Once the roles and responsibilities are defined in regulation, the obligations which
underpin them will be enforceable and clear.
9. Are these appropriate options for conformance management? Should others be considered?
When/what are the triggers?
Scope
It is acknowledged that further work is required on the specific fields to be included (with
reference to existing registers and work underway).
We recommend that the Installed Device Register should include the pertinent
information:
• Device Type (inverter, battery, PV module etc)
• Device Manufacturer
• Device Model
• Device Rated Power (KVA Vac Aac)
• Device Capacity (kWh, kWp)
• Device Phase Type
• Device Export or Generation Limit Set Point
• Connection Address
• National Metering Identifier (NMI)
• DNSP provider
• Export Capability (Y/N)
• Generation Capability (Y/N)
• Multiple Inverter Combinations (Y/N)
• Regional Grid Code Set (Region A,B,C, etc.)
• Grid Service Function Enabled (Y/N)
• Grid Service Function Provider (VPP aggregator, etc.)
• Enrolled in DNSP EBM (Y/N)
• Enrolled in DNSP Service (Y/N) (TOU Flexible Exports, etc.)
• Installation Date
• Commissioning Date
• Accredited installer details (Name, Contact Details & Accreditation & Electrical
License Number),
Information not required, or an over-reach would be:
• Inverter and battery configuration
• Software updates
• Device servicing
September 2025 – Australia
• OEM and installer details and nature of updates and servicing.
How will this function benefit consumers?
The most significant benefit for consumers is the accountability of installers.
It is often the case that when there are issues or the consumers want to have the system configuration updated or enhanced, they do not know who to go to.
It is also worth noting that a system and product warranty may be in excess of 10years on most systems, but when properties change hands, new homeowners will often not know who to contact if an issue arises.
Having this level of information available will grater help with product and system care and installer obligations throughout he life of the installations.
Why is national consistency important for this measure?
It is also worth noting that it is simpler to implement.
What obligations would be placed on actors?
• Retailers: provide information when an application to a DNSP for a system has
been approved and what components are to be installed
• Installers: provide information when installing, adding components, servicing
and decommissioning
• OEMs: provide information when services or replacing devices under warranty.
(Providing firmware updates is an overreach and not necessary)
• VPPs and aggregators: provide information when they enrol a device onto their
services (When remotely changing device settings is an overreach, as this would
apply to whenever they are remotely controlling a device)
• DNSPs: provide information when they have approved an installation and which
devices have been approved for connection (When remotely changing device
settings is an overreach, as this would apply to whenever they are remotely
controlling a device)
• Electrical Inspectors: provide information when they assessed and approve the
system for functional operation, conforming to the appropriate technical
requirements and standards.
Compliance and enforcement approach
Compliance-by-design
• Points detailed are agreed to be reasonable.
September 2025 – Australia
Detecting non-compliance
• Points detailed are agreed to be reasonable.
Responding to non-compliance
• Notices and warnings to update information
• Accreditation suspension or cancellation for installers with repeated
compliance issues
• Actions taken on retail (or VPP and system aggregators) causing actions that
result in the system operating in a manner deemed not to be compliant.
• Penalties for sustained non-compliance.
• Temporary suspension from accrediting new devices for OEMs with repeated
non-compliance is a poor outcome. Recalling products deemed to be non-
compliant would be a better outcome. If an OEM did have a product issue,
and the solution was to introduce a new product that could be used to
replace the defective ones, suspending them from being able to list the
replacement product would be a roadblock to remediation.
10. How will the Framework practically work, particularly in its interactions with those who currently
have a degree of control over aspects of CER within the system? An OEM has product
requirements, how does a DNSP/aggregator have to fit in with those requirements? e.g. VPPs
currently have no regulation.
The current situation is that the OEM designs products that focus on and meet the
requirements of the consumer.
In order to have devices approved for CEC listing and approved for installation in certain
regions, the OEM then has to develop additional layers of compliance for functions such
as CSIP-AUS and EBM functionality.
Once both of the above have been met, OEMs will then work with VPP providers and
aggregators to be able to have their products enrolled onto grid-services programs and
benefit from market incentives.
The Framework should continue to work practically as the CER industry already does
when considering interactions with those who currently have a degree of control over
aspects of CER within the system. Nothing is proposed within the framework that will
change any of the interactions; all that is being proposed is that the DNSP approval and
connection process should be simpler when a nationally consistent approach is adopted
to system and device approvals and the interpretation of technical standards.
September 2025 – Australia
It is acknowledged that VPPs currently have no regulation; it is advisable to include VPP
and aggregator obligations under conformance management, as they have the ability to
send control commands to CER that may exceed the approved parameters by a DNSP or
override a central system security command.
11. How do you reflect the priorities? What parts of the Code need to be tackled immediately ahead
of the Regulator commencing. What other standards/requirements could/should be tackled
immediately?
The priorities and parts of the code that should be tackled immediately ahead of the
regulator commencing, are as follows:
1. Establishing national CER technical requirements
• Coordinate all existing standards and technical requirements into a national
policy
• Produce a streamlined and coordinated implementation pathway.
• Create a clear interpretation of existing Standards and Technical requirements
for CER to be applied nationally.
• Other than the Standards Australia processes, halt the development of any
new technical requirements on CER devices until the Technical Regulator has
been established.
2. Mandatory certification of CER devices
• Work with the CEC product listing process to extend it to capture all
additional data fields as defined.
• Include in the CEC product listing process all of the listing criteria and
information required by entities such as ERAC, SA’s DEM and DNSPs so that
all additional listing processes can be removed for the industry.
3. Mandatory installer accreditation and accountability
• Extend the reach of the SAA installer accreditation process to ensure that
accreditation is held when installing any defined CER devices, not just within
rebate settings.
12. How do we identify and prioritise the work program for requirements?
The best outcome for consumers would be to adopt the components of the three
priorities as detailed in question 11, as this will help to reduce the cost burden on OEMs
and industry, as well as smooth the installation and conformance processes.
13. What happens when things go wrong? What are the ongoing roles and responsibilities? e.g. a
manufacturer folds or withdraws from the market, who is responsible for software updates, any
remaining warranty, etc.
September 2025 – Australia
This situation is not new; the industry has been dealing with such a scenario since it began. The definitions for roles and responsibilities cover all of the following actors if an issue were to arise:
• Retailers: It is most often the case in the industry that retailers fold; this often
leaves consumers without a point of contact for support. In this scenario, the
OEM will still have product warranty obligations and the installer for the system.
The consumer will be able to identify the Device OEM as it will be evident on the
component itself. In this situation, they can contact the OEM and gain support if
there is a product issue.
What the consumer will often find hard to find is the installer. In this situation, the
OEM will be able to support, normally with a list of alternative installers in the
region, with the proposed scope of the Installed Device Register, the consumer
should be able to find the installer.
Installers: As has already been described, what the consumer will often find hard
to find is the installer. In this situation, the OEM will be able to support, normally
with a list of alternative installers in the region, with the proposed scope of the
Installed Device Register, the consumer should be able to find the installer.
If the OEM has folded, then the installer will find it hard to support the device/s;
they will not be able to access parts or software unless a service arrangement has
been set up with a 3rd party in Australia prior to the OEM folding. This is often the
case.
If an OEM folds and the retailer still exists, the retailer then takes on the role and
responsibility for the devices, as under ACL, they become the responsible party.
Again, they may not be able to access parts or software unless a service
arrangement has been set up with a 3rd party in Australia prior to the OEM
folding. This is often the case.
OEMs: If an OEM folds, retailers or installers may not be able to access parts or
software unless a service arrangement has been set up with a 3rd party in
Australia prior to the OEM folding. This is often the case.
If the installer or retailer has ceased to exist, then the OEM will, in most cases, be
able to support the consumer.
September 2025 – Australia
It is worth highlighting that, other than entities being able to access information with the
proposed scope of the Installed Device Register, the Technical Regulator will be able to
do very little if things go wrong.
14. What consideration should the framework make, if any, of demand shifting devices such as
smart pool pumps and controlled load hot water systems? Should they be addressed, or should
the regulator only cover CER that can add power to the grid?
This question centers around the definition of CER. In principle, any consumer device,
which, when installed, can be controlled should be considered CER.
Demand shifting devices such as smart pool pumps, air-conditioning units and
controlled hot water systems should all be considered CER, not if they can add power to
the grid, but because they can be controlled.
What is important for the grid of the future is controllability. Controlling and managing
loads is equally important as controlling grid exports.
15. What about other associated elements such as smart meters? Should national regulation
determine required minimum standards for smart meters, taking into account consumer benefit
and desired system outcomes?
National regulation to determine the required minimum standards for Smart Meters is
not necessary in the context of CER. These are currently billing and DNSP supporting
assets.
What should be a key consideration, however, is the data itself and its use/access rather
than the data-gathering device:
I. The use of Smart Meter data for network planning and determining CER device
level compliance needs to be explored in greater detail. This data has been
justified for many years as being critical for network planning. It does not infringe
on consumer rights and comes without any of the social licensing issues or cost
burden to OEMs. The recommendation is that this data be used to build out all
scenarios before considering CER device-level data access.
II. There is an overarching assumption within industry, especially at a DNSP and
AEMO level, that consumers' CER data is freely available; this is not true. Without
offering an incentive for consumers to part with their data, policymakers will
either not get the desired outcome or will have to mandate CER data access,
which will be a poor outcome. To overcome this gap, the recommendation would
September 2025 – Australia
be first to assign financial value to the data and then create a mechanism to
compensate for access.
III. The social license to access consumers’ behind-the-meter CER data needs to be
addressed. Without the buy-in from consumers, a backlash could be possible,
resulting in them being unwilling to share their device-level data. As previously
mentioned, to overcome this gap, the recommendation would be first to assign
financial value to the data and then create a mechanism to compensate for
access.
IV. The role of the OEM has not been considered when policy design looks to access
and use CER-centric device and system-level data. OEMs will play a vital role in
developing and facilitating access to CER data. Similar to the data itself, to
overcome this gap, the recommendation would be first to assign financial value
to the data and then create a mechanism to compensate for the infrastructure
and device-level development required for access. This level of infrastructure
development, such as the establishment of DNSP utility servers and the teams
that operate them, already has financial CAPEX/OPEX support, which is ultimately
passed through to the consumer to pay for. It is unreasonable that OEMs would
be expected to pay for a unique, Australian CER-data strategy implementation
and delivery without any means of support.
16. One of the key methods of managing CER interaction with the grid is the use of dynamic
operating envelopes (DOEs). DOEs provide upper and lower bounds on the maximum and
minimum flow of power through a given point within an electricity distribution network during a
particular time interval for CER device(s). Where do you think the responsibility for regulating
DOEs should sit? (And why?)
The responsibility for regulating DOEs should sit with the National Technical Regulator,
as this is a technical requirement; it requires technical standards to be developed,
enforced and managed, as well as coordination to support the roles and responsibilities
of entities establishing the connections between devices and DNSPs, as well as ongoing
conformance.
Thank you for the opportunity to provide input into the Consultation Paper.
If you would like to have any further information or would like clarification to any of the points raised, please contact me directly to discuss.
Yours sincerely,
SolarEdge Technologies (Australia) PTY LTD.
Level 13, 222 Exhibition Street,
Melbourne
James Sturch VIC 3000
Technical Director, International Markets Australia
