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AGL Energy Limited
T 02 9921 2999 Level 24, 200 George St
Sydney NSW 2000
agl.com.au Locked Bag 14120 MCMC
ABN: 74 115 061 375 Melbourne VIC 8001
Department of Climate Change, the Environment, Energy and Water
Consumer Energy Resources Taskforce
Submission via DCCEEW website portal
12 September 2025
Consultation Paper – National Consumer Energy Resources (CER) Roadmap – National Technical
Regulatory Framework for CER – T2
AGL Energy (AGL) welcomes the opportunity to provide responses to the questions posed by the Department of
Climate Change, the Environment, Energy and Water (DCCEEW) in response its Consultation Paper on a national technical regulatory framework for CER.
AGL supports the establishment of a National Technical Regulatory Framework and the paper’s objectives. The establishment of a national framework could play an important role in harmonising requirements across jurisdictions and network areas. Improved conformance with standards can also support a transition to a high-
CER future by creating greater certainty on the behaviour of CER.
AGL is broadly supportive of four of the functions in the framework prototype (Establishing national CER technical requirements, Mandatory accreditation of CER devices, Mandatory installer accreditation and accountability and Support CER system integrity). While supportive of the intent, AGL’s view is that the function
Mandatory updating of CER connection information would be practically unenforceable in the short term if it seeks to capture remote updates from multiple actors.
The proposed regulatory reforms are extensive and will have far reaching impacts on the supply chain for a range of CER. Disproportionate obligations on original equipment manufacturers (OEMs) and installers risks limiting the pace of electrification and CER installations in Australia. AGL would support a gradual implementation of requirements and encourages the CER Taskforce to ensure technical requirements are supported by evidence of need. A gradual implementation would enable regulators to upskill to deliver their new functions, and DCCEEW to test whether the framework is delivering on its intended traits (e.g., a nimble and responsive regulator).
AGL supports DCCEEW’s objective to emphasise preventing non-compliance rather than punitive enforcement.
If DCCEEW aspires to have a strong CER installation workforce in the future, this should be underpinned by upskilling and streamlining of regulatory processes. Tying some of these obligations to incentives could also help improve compliance beyond what could be achieved by an educational and advisory function.
Appendix A includes responses to select questions in the consultation paper. If you have any queries about this submission, please contact Andrea Espinosa on aespinosa2@agl.com.au.
Yours sincerely,
Kyle Auret
Senior Manager Policy and Markets Regulation
AGL Energy
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About AGL
Proudly Australian for more than 187 years, AGL supplies energy and other essential services to residential, small and large businesses and wholesale customers. AGL is committed to providing our customers with simple, fair and accessible services as they decarbonise and electrify the way they live, move and work. AGL is investing in flexibility and has been making strong progress against our grid-scale battery and distributed energy resources (DER) targets. As of FY25 AGL had 1.49 GW of decentralised assets under orchestration, and a FY27 target of 2.5 GW of demand-side flexibility. AGL is also a market leader in the development of innovative products that enable consumers to make informed choices on how and when to optimise their energy usage to better manage their energy costs.
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Appendix A – Response to consultation questions
Question Response
Do the system outcomes The system outcomes appear appropriate, but AGL notes that stronger
capture what is needed for standards on buildings, vehicles, and appliances that facilitate improvements in
the CER system to energy efficiency and productivity are necessary to support electrification and
function? CER adoption.
Are the current challenges, The National CER Technical Framework could play an important role in
examples and impacts resolving these challenges. AGL observes that:
comprehensive? Is a
National CER Technical • The objective to maintain device conformance and connection of CER
Regulatory Framework the devices throughout the lifecycle is incredibly complex and may not be
best mechanism to resolve best resolved through the national framework.
these? • An additional example of where technical requirements and standards
are applied and interpreted differently across and within jurisdictions is
in the application of PKI to devices communicating via CSIP-Aus.
While this is being harmonised through the not-for-profit NEPKI, the
National CER Technical Regulatory Framework offers an opportunity
to create longer-term arrangements to manage this function within
government.
Are the five regulatory AGL is broadly supportive of functions 1,2,3 and 5: Establishing national CER
functions the appropriate technical requirements, Mandatory accreditation of CER devices, Mandatory
priorities for the National installer accreditation and accountability and Support CER system integrity.
CER Technical Regulatory
AGL’s view is that function 4 Mandatory updating of CER connection
Framework?
information would be practically unenforceable in the short term if it seeks to
capture remote updates.
What are the barriers to • Function 1: AGL strongly supports the objective of ensuring technical
implementing the proposed requirements and standards are applied and interpreted consistently
regulatory functions? What across Australia. However, this objective would not be achieved if
opportunities are there to distribution network service providers (DNSPs) or state regulators are
leverage existing able to modify or add requirements and deviate from the National CER
approaches? Technical Code. Therefore, it would be necessary for DCCEEW and
the regulator (when established) to closely engage with DNSPs, state
regulators and industry to ensure there are no material deviations
between the requirements and its actual implementation.
• Function 2: DCCEEW could consider whether BESS need to be limited
to lithium-based batteries. The regulator should enable technology
development and innovation by ensuring other types of batteries are
not excluded by default from the product list (and therefore installation
in Australia). DCCEEW could also consider an option to list multiple
CER asset types within a single device to reduce the need for separate
accreditation processes.
• Function 4: As noted in the previous question, the requirement to
update the Installed Device Register every time there is a remote
update (e.g., software update or device settings) is likely to be
unenforceable in the short term. This would then lead to poor data
quality which would not deliver on the objectives sought. It would be
preferrable to implement the Installed Device Register gradually – e.g.,
create an obligation to collect information at the time of installation and
servicing on-site. Implementation would also need to consider which
parties can input directly onto the register and be granted access to the
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Question Response
information. AGL’s view is that the FRMP for the associated NMI
should be granted access to this information.
Once that information has been found to be successfully collected with
satisfactory quality and completeness, DCCEEW / the regulator could
consider expanding the obligation to servicing and updates. AGL also
notes that in the case of aggregator updates, it wouldn’t be feasible to
provide updates every time market participation occurs. This sort of
information exchange should remain within the scope of other reforms,
primarily the Integrating Price Responsive Resources Rule
implementation. Information could potentially be provided by
aggregators when there are changes to the asset mode.
DCCEEW should also be mindful of the sensitivity of data related to
CER devices and their operations. Where information is sought on
consumers’ CER, it will be important to ensure this is supported by
customer acceptance either through the creation of the right incentives
or through effective engagement from industry and
governments. DCCEEW should also consider whether elements of the
CDR framework can be leveraged to support this function.
What work is underway Should the function Mandatory updating of CER connection information be which might interact with implemented, this should only come into force after AEMO’s DER Register is the proposed regulatory uplifted and the associated access / data sharing arrangements are finalised functions? How could these (e.g., as part of the CER Data Exchange project). DCCEEW, in collaboration interactions be managed? with AEMO and industry, could then assess whether this is an appropriate tool
to support the intended obligation.
How do we ensure This would be achieved by ensuring the requirements set by the regulator are regulator decisions are based on strong evidence of need (e.g., material risk to the energy system or consumer centric? harm to consumers) to ensure innovation and customer choice are upheld.
Is the suggested As outlined earlier, AGL would support an incremental implementation of the compliance and Installed Device Register. It will also be important to uplift systems (e.g., the enforcement approach DER Register) to support this function effectively before obligations appropriate and commence.
achievable?
However, broadly supportive of compliance-by-design approach. It will be
important to keep data requirements to the minimum necessary and to support
easy data submission. It will also be important to manage registration data
efficiency and reduce data collection frictions. DCCEEW could consider
leveraging the existing supply chain to reduce duplication – for example,
transferring information from electrical compliance certificates into the Installed
Device Register.
How do we maintain Disproportionate obligations on installers risks limiting the pace of effective regulation while electrification and CER installations in Australia. AGL supports DCCEEW’s minimising regulatory objective to emphasise preventing non-compliance rather than punitive burden for installers? enforcement. If DCCEEW aspires to have a strong CER installation workforce
in the future, this should be underpinned by upskilling and streamlining of
regulatory processes. Tying some of these obligations to incentives could also
help improve compliance beyond what could be achieved by an educational
and advisory function.
DCCEEW could leverage existing organisations such as Solar Accreditation
Australia for rooftop solar and battery systems and could consider how other
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Question Response
organisations such as the Electric Vehicle Council could play a part for other
types of installations.
Are these appropriate AGL agrees that obligations on customer agents should be considered in more options for conformance detail and separately (and in the context of the market workstreams).
management? Should others be considered?
When/what are the triggers?
How will the Framework As noted in the previous response, obligations on customer agents (e.g., VPP practically work, particularly operators) should be considered separately. Generally, reforms should seek to in its interactions with those uplift industry obligations to ensure consumers are protected regardless of who currently have a whether their service provider is covered within the scope of the NEL/NERL.
degree of control over The focus should not be on creating additional requirements on parties which aspects of CER within the are already heavily regulated within the electricity framework.
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.
How do we identify and Identification of requirements should occur transparently and in close prioritise the work program consultation with industry. DCCEEW / the regulator should ensure there is a for requirements? balanced representation of interests and expertise as part of this process. The
process should prioritise the adoption of international standards to avoid
impacting consumer choice and, where Australian standards are adopted,
ensure these are implemented consistently across and within jurisdictions.
Appropriate lead time should be given to industry to adjust to new obligations.
What consideration should AGL supports the initial scope, which does not include smart devices.
the framework make, if any,
DCCEEW should also ensure the regulator’s scope only covers devices that of demand shifting devices
interact with the network. For example, in the case of inverter, power such as smart pool pumps
conversion equipment and integrated protection devices this should not include and controlled load hot
devices that are not part of a generating system and grid-connected.
water systems? Should they be addressed, or should the regulator only cover CER that can add power to the grid?
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Question Response
What about other Matters related to smart meters and associated requirements should continue associated elements such to be regulated within NEL/NERL framework.
as smart meters? Should national regulation determine required minimum standards for smart meters, taking into account consumer benefit and desired system outcomes?
One of the key methods of Matters related to DOEs should continue to be regulated within NEL managing CER interaction framework. However, the regulator should play a role in ensuring CSIP-Aus with the grid is the use of requirements for backstops and DOEs are applied and interpreted consistently dynamic operating across DNSPs. In later years, the regulator could also incorporate the functions envelopes (DOEs). DOEs of the not-for-profit NEPKI as this entity is currently authorised to operate until provide upper and lower 30 June 2030.
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?)
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