National Consumer Energy Resources (CER) Roadmap - Consultation on technical priorities

Level 12 Postal address T 1300 858 724
171 Collins Street GPO Box 2008 F 03 9609 8010
Melbourne VIC 3000 Melbourne VIC 3001 E info@aemo.com.au

10 September 2025

Department of Climate Change, Energy, the Environment and Water
GPO Box 3090 Canberra ACT 2601

Dear Sir/Madam,

National Consumer Energy Resources (CER) Roadmap - National Technical Regulatory Framework for
Consumer Energy Resources Draft Prototype

The Australian Energy Market Operator (AEMO) welcomes the opportunity to respond to the consultation paper on National Technical Regulatory Framework for Consumer Energy Resources (CER), developed under Reform
Priority T2 of the National CER Roadmap. AEMO considers the establishment of a nationally consistent framework to set and enforce clear technical requirements is critical to improving compliance, providing certainty for consumers and industry, and supporting secure and efficient power system operation as CER uptake accelerates.

AEMO supports the development of a unified National CER Technical Regulatory Framework that sets consistent technical standards and ensures compliance across the lifecycle of CER. AEMO emphasises the need for clear governance, national consistency, and end-to-end conformance, recommending a coordinated approach to avoid regulatory overlaps or gaps. AEMO proposes that the framework focuses on CER devices with significant impact on system outcomes, and excludes smart meters, which are already subject to a robust regulatory framework under the National Electricity Rules (NER) and the Western Australian regulatory frameworks. We also support a staged, flexible expansion of scope to include additional categories of CER devices as standards and technologies mature, with all future inclusions guided by clear criteria and coordinated with existing frameworks.

AEMO broadly supports the draft prototype and its five proposed functions, emphasising the need for clear governance, end-to-end device and installer accreditation, unified data registration, and improved consumer and industry information. AEMO notes the identification of device accreditation as a central regulatory function and suggests that its scope should extend beyond market entry certification. The scheme could also establish a basis for ongoing conformance monitoring throughout the device lifecycle, to verify that devices continue to meet system security requirements and consumer needs in practice as well as at certification.

Further detail on AEMO’s perspectives are provided in Appendix 1. Our recommendations are informed by recent
AEMO investigations into compliance of Distributed Energy Resources with technical settings, which reveal persistent gaps that would benefit from being considered within a regulatory framework.

If you would like to discuss this matter further, please contact Hannah Heath, AEMO Group Manager –
Strategic Market Reform (hannah.heath@aemo.com.au).

Yours sincerely,

Violette Mouchaileh
Executive General Manager – Policy and Corporate Affairs aemo.com.au
New South Wales | Queensland | South Australia | Victoria | Australian Capital Territory | Tasmania | Western Australia

Australian Energy Market Operator Ltd ABN 94 072 010 327 1
APPENDIX 1: AEMO’S VIEWS AND INSIGHTS ON THE CER NATIONAL TECHNICAL REGULATORY
FRAMEWORK DRAFT PROTOTYPE
1. General comments on the CER Technical Regulatory Framework
AEMO is supportive of the development and implementation of a comprehensive National CER Technical
Regulatory Framework. This framework can facilitate the setting of nationally consistent CER technical requirements and standards, addressing current challenges in ensuring device conformance and compliance across the CER lifecycle. AEMO agrees that the “CER system outcomes” listed in the Consultation Paper are necessary for the CER ecosystem to function effectively, and we welcome the explicit inclusion of support for power system security as one of these outcomes. A clear and consistent set of technical requirements, backed by compliance measures, will also give industry confidence to invest in CER technologies that meet those standards, thereby supporting both innovation and system security.

End-to-end conformance framework: AEMO recommends that further work be undertaken to develop an end- to-end conformance and compliance framework to support delivery of the CER Technical Regulatory Framework.
While the Consultation Paper acknowledges the challenges of ongoing conformance, it places stronger emphasis on device conformance up to the point of installation and commissioning. The measures outlined for ongoing conformance remain high-level, and the framework does not yet provide a clear regulatory design for how it will be monitored, assessed, enforced, or allocated across parties. As outlined in AEMO’s submission to the Redefine roles for market and power systems operations workstream (M3/P5) workstream 1, an effective end-to-end conformance framework should also cover visibility and data governance, monitoring, assessment, and enforcement of installation and commissioning requirements, device behaviour in response to grid conditions, and device performance in response to communications. Clear accountabilities across all relevant parties are essential to ensure compliance and maintain confidence. Without a coordinated approach, there is a material risk of gaps or duplication in regulatory obligations, which could undermine both system security and consumer outcomes.

AEMO recommends that an end-to-end conformance framework be progressed across the T2 (Technical
Regulation), M2 (Data sharing), and M3/P5 (Redefining roles) workstreams to provide a single, unified, and enforceable regulatory approach to CER compliance across the full device lifecycle and scope of use. The end- to-end framework should include:

• harmonised national standards supported by an adjudication process for interpretation,

• mandatory accreditation for devices and installers backed by independent testing and commissioning
verification,

• enforceable obligations for accurate and complete registration data,

• governance of firmware and remote rectification activities to ensure accountability and consumer
protection,

• defined ongoing roles and responsibilities for OEMs to maintain service levels, cybersecurity, data accuracy
and operational continuity, and

• standardised monitoring methodologies overseen by a National Technical Regulator.

1
National Consumer Energy Resources (CER) Roadmap - Redefine roles for market and power system operations – M3/P5: https://consult.dcceew.gov.au/national-cer-roadmap-redefine-roles-m3-p5

APPENDIX 1: AEMO’S VIEWS AND INSIGHTS ON CER NATIONAL TECHNICAL REGULATORY FRAMEWORK DRAFT PROTOTYPE 2
Clarity on governance, regulatory architecture and national coverage: AEMO considers that further detailed work is required on the regulatory architecture for implementing the proposed CER Technical Regulatory
Framework. Oversight roles must be clearly delineated to avoid overlapping accountabilities and to mitigate unintended consequences for adjacent regulatory frameworks, particularly where interactions arise with the
National Electricity Law (NEL), NER, and jurisdictional legislation across States and Territories. AEMO is supportive of measures that promote national consistency in technical regulation, recognising that actions under the
National CER Roadmap aim to build a harmonised approach that unlocks the full potential of CER. At the same time, the framework must balance consistency with the flexibility for jurisdictions to apply measures suited to their regulatory and market environments, at the discretion of the relevant decision-making bodies. As noted in the Consultation Paper, further analysis is required to determine the most effective approach for assigning obligations to the new customer-facing roles identified in the M3/P5 and M2 workstreams. AEMO emphasises that clearly defining and allocating responsibilities for these roles will be critical to the success of the framework, ensuring effective implementation across both NEM and non-NEM jurisdictions.

Scope of technical regulation: AEMO supports the initial scope of the Technical Code and emphasises that it should remain focused on CER devices and functions, avoiding duplication with existing regulatory regimes. In particular, smart meters should not be brought into scope for the CER Technical Framework. Minimum standards and technical requirements for meters are already well established under the NER. The NEM metering framework’s primary purpose is to support accurate billing and market settlement through a single, harmonised set of technical requirements, backed by robust compliance and assurance mechanisms. Similarly, the WEM has its own regulatory framework governing electricity metering. The adaptability of this framework is evident by recent expansions, such as the introduction of Power Quality Data collection and delivery obligations, and the current consultation on real-time data provision. These developments highlight the flexibility and robustness, while maintaining the integrity of its core deliverables. Creating separate obligations for meters within the CER framework would risk undermining the existing metering regime and constraining its ongoing development.

AEMO is supportive of including, at a minimum, inverters and communications protocols (e.g. CSIP-AUS) in the first iteration of the Technical Code. The scope of CER and interoperability standards should also allow for the inclusion of additional products capable of generating, storing, or controlling electricity, or shifting consumption, as technologies and system needs evolve. AEMO considers the scope should initially focus on CER devices with a material impact on power system security, reliability, interoperability, or consumer outcomes. Any future expansion of scope should be guided by clear criteria, be consistent with the Code’s regulatory objectives, and be coordinated with other relevant frameworks to avoid duplication. AEMO supports this staged approach, enabling the inclusion of further product categories over time. As interoperability gaps are addressed and conformance and compliance frameworks mature, expanding the scope will be important to support customer choice and system flexibility.

AEMO also supports additional work to address the gaps in CER interoperability standards identified by the
Technical Standards for CER Interoperability (T1) workstream. This includes standards for Electric Vehicle Supply
Equipment (EVSE) for public use and in-premises EVSE above a defined rating, as well as flexible loads and energy management systems. As noted in the Consultation Paper, additional device categories could be included in the
Technical Code without being brought into the scope of other regulatory measures (such as mandatory device accreditation). AEMO supports this approach, as it provides a pathway to broaden coverage pragmatically while maintaining regulatory flexibility.

APPENDIX 1: AEMO’S VIEWS AND INSIGHTS ON CER NATIONAL TECHNICAL REGULATORY FRAMEWORK DRAFT PROTOTYPE 3
2. Feedback on proposed regulatory functions
Regulatory Function 1- National CER technical requirements: AEMO is broadly supportive of this regulatory function and the proposed structure of the CER Technical Code, which first sets out technical performance requirements and then specifies the standards deemed to satisfy those requirements. This approach provides flexibility while ensuring consistency across industry. Further detailed design work is required to establish a clear governance model for the Code, including transparent processes for updating and maintaining it over time.
AEMO considers that administration of the Code should rest with an accountable body, supported by governance arrangements capable of delivering robust, evidence-based decisions aligned with the regulatory objectives of the Code.

To ensure the Code remains technically rigorous and fit-for-purpose, the Regulator(s) should have flexibility to draw on specialist expertise through mechanisms such as technical committees or expert working groups. This would support effective interpretation of standards and timely incorporation of emerging requirements. AEMO supports the proposed inclusive processes for Code development and updates, including consultation with industry and the public. As a market body, AEMO can provide advice on technical requirements and standards that can strengthen system security and support efficient market development.

In developing and maintaining the Code, it will also be important to put in place mechanisms that ensure consistent application across jurisdictions and reduce scope for divergent interpretations. This should include clear guidance material for national conformance test specifications, transparent processes for resolving ambiguities, and structured pathways for updating the Code as risks evolve. These features are critical to building industry confidence and providing certainty for investment and innovation.

To avoid divergent interpretations (e.g., CSIP-Aus testing and certificate management for emergency backstop), the Code should include: (i) national conformance test specifications, (ii) an adjudication process to resolve ambiguous requirements, and (iii) a change-control pathway to keep guidance current as risks evolve. These elements are critical to ensure industry confidence in the Code.

Regulatory Function 2- Mandatory accreditation of devices: AEMO supports the establishment of a nationally consistent, mandatory accreditation and certification scheme for CER devices. Recent AEMO analysis of compliance with AS/NZS 4777.2:2020 2 (the DER Compliance Report) shows that while inverter compliance rates have improved significantly, compliance rates remain below the level required to ensure system security.
Importantly, much of the improvement has been achieved through voluntary Original Equipment Manufacturers
(OEMs) actions and ad hoc measures. The findings in the compliance report highlight the limitations of current voluntary and fragmented arrangements and reinforce the need for a robust, enforceable accreditation framework. AEMO considers that the framework should include:

• Clear certification and testing requirements to ensure devices conform to the Technical Code at the point of
approval.

• Independent, standardised testing processes, with improvements to laboratory practices to address
inconsistencies in test interpretation and reporting.

• Governance for ongoing compliance, including obligations on OEMs to provide datasets on field
performance and authority for DNSPs or regulators to oversee remote updates where appropriate.

2
AEMO, Compliance of Distributed Energy Resources with Technical Settings: 2025 Update, September 2025.

APPENDIX 1: AEMO’S VIEWS AND INSIGHTS ON CER NATIONAL TECHNICAL REGULATORY FRAMEWORK DRAFT PROTOTYPE 4
• Practical rectification pathways that extend beyond disconnection, allowing non-compliance to be
addressed without unfairly penalising consumers.

While AEMO welcomes the identification of device certification as a central regulatory function, it needs to extend beyond governing entry of devices into the Australian market. The scheme should also provide the foundation for ongoing conformance monitoring throughout the device lifecycle, ensuring devices continue to support system security and consumer outcomes in practice, not just in certification.
Regulatory Function 3- Mandatory accreditation of CER installers: AEMO supports the introduction of a nationally consistent, mandatory accreditation scheme for CER installers, aligned with CER technical requirements and underpinned by effective compliance monitoring and enforcement. It is critical that installer obligations extend beyond safe installation to include correct commissioning and configuration. AEMO considers a mandatory Installer Code of Conduct should require that:

• devices are set to the correct grid code profile (including appropriate standards and regional settings),

• emergency mechanisms (e.g. backstop) or safety functions are correctly configured, and

• all required data is captured and reported into the relevant registry.
AEMO’s analysis in the DER Compliance Report shows that installer practices can be a critical weak point in achieving compliance. The Report findings showed the introduction of DNSP commissioning checklists and export-enablement tests lifted compliance levels quickly and consistently. The installer accreditation scheme should therefore consider:

• requiring adherence to a mandatory commissioning checklist

• providing for suspension or revocation of accreditation for persistent non-compliance, and

• clearly allocating responsibility when installers are required to return to site following failed compliance
checks.

AEMO seeks clarification on whether the proposed accreditation scheme will operate as a formal scheme with a governing body, including provisions for suspension or revocation of accreditation in cases of persistent non- compliance. Designing this compliance and enforcement framework from the outset is essential to ensure installer obligations are meaningful and consistently applied. This will be particularly important following the expected conclusion of the Small-scale Renewable Energy Scheme (SRES) in 2030, which currently provides financial incentives for consumers to engage accredited installers and purchase approved devices.
Regulatory Function 4- Mandatory updating of CER connection information: AEMO supports the objective of improving the transparency and accuracy of CER device information through a mandatory requirement to update connection and asset information in an “Installed Device Register”. To avoid duplication, fragmentation, and unnecessary cost to industry and consumers, this measure should be aligned with existing frameworks and with the proposed actions in the Data Sharing (M2) workstream of the National CER Roadmap. In particular, AEMO supports the M2 consultation paper proposal to implement a CER Asset Registration and Commissioning Strategy to deliver standardised installation and commissioning 3. AEMO considers this initiative to be directly complementary to Function 4 and recommends the two be developed as a single, integrated approach.

3
DCCEEW, National Consumer Energy Resources (CER) Roadmap - Data Sharing Arrangements – M2.

APPENDIX 1: AEMO’S VIEWS AND INSIGHTS ON CER NATIONAL TECHNICAL REGULATORY FRAMEWORK DRAFT PROTOTYPE 5
AEMO notes that the M2 consultation paper also proposes upgrading the DER registries, and AEMO supports a unified approach whereby enhanced DER registries underpin both the T2 Technical Regulatory Framework and the M2 Data Sharing objectives. These upgraded DER registries should be designed to capture all CER types, with unique device identifiers, technical characteristics, capabilities (such as flexible export limits or emergency remote disconnection), and key configuration data. For this measure to be effective, clear roles and obligations are required. Installers, OEMs, VPPs, and other relevant actors should be accountable for providing and updating device data. These obligations should be considered in conjunction with the emerging customer-facing roles (e.g.
Customer Agent, Communications Manager) being defined under the M3/P5 and M2 workstreams.

AEMO also recognises that work to define a DER Data Coordinator is progressing in the South West
Interconnected System (SWIS) as part of the Government of Western Australia’s DER Roadmap and supports ensuring opportunities for consistency and coordination between jurisdictions in the case that different arrangements emerge.

Regulatory Function 5- Information on CER technical regulation for consumers and industry: AEMO supports the proposal to strengthen the availability and transparency of information on CER technical regulation for consumers, industry participants, and other stakeholders. Improved access to consistent, accurate, and practical information will be critical to building consumer confidence, supporting informed decision-making, and enabling industry to comply efficiently with their obligations. AEMO supports the three key enhanced functions proposed including: improved access to consistent and clear information for consumers and industry, monitoring and reporting on system integrity, and stewardship of the technical regulation of CER. Together, these functions will create a more transparent and trusted CER ecosystem, making it easier for consumers to adopt compliant technologies and for industry to deliver consistent, standards-aligned outcomes.

APPENDIX 1: AEMO’S VIEWS AND INSIGHTS ON CER NATIONAL TECHNICAL REGULATORY FRAMEWORK DRAFT PROTOTYPE 6

Compliance of
Distributed Energy
Resources with
Technical Settings:
2025 Update
August 2025

Compliance to AS/NZS4777.2:2020
A technical report for Australia
We acknowledge the Traditional Custodians of the land, seas and waters across
Australia. We honour the wisdom of Aboriginal and Torres Strait Islander Elders
past and present and embrace future generations.

We acknowledge that, wherever we work, we do so on Aboriginal and Torres
Strait Islander lands. We pay respect to the world's oldest continuing culture and
First Nations peoples' deep and continuing connection to Country; and hope that
our work can benefit both people and Country.

'Journey of unity: AEMO's Reconciliation Path' by Lani Balzan

AEMO Group is proud to have launched its first Reconciliation Action Plan in May 2024. 'Journey
of unity: AEMO's Reconciliation Path' was created by Wiradjuri artist Lani Balzan to visually narrate
our ongoing journey towards reconciliation - a collaborative endeavour that honours First Nations
cultures, fosters mutual understanding, and paves the way for a brighter, more inclusive future.

Important notice
Purpose
The purpose of this report is to provide a status update on the current state of compliance of distributed energy resources
(DER) with technical settings, focusing on compliance of distributed photovoltaic (DPV) inverters with AS/NZS4777.2:2020.
The report provides a status update since AEMO’s report released in December 20231. AEMO has prepared this report to meet its responsibility under clause 4.3.1(n) of the National Electricity Rules (NER) to refer to Registered Participants, as
AEMO deems appropriate, information of which AEMO becomes aware in relation to significant risks to the power system where actions to achieve a resolution of those risks are outside the responsibility or control of AEMO.

Disclaimer
To inform its review and the findings expressed in this report, AEMO has been provided with data by third parties, including original equipment manufacturers (OEMs) and distribution network service providers (DNSPS), and has also collated information from its own observations, records and systems. This report has been prepared by AEMO using data available and observations made at different times as indicated in the report, and other information available to AEMO as at August
2025. AEMO has made reasonable efforts to ensure the quality of the information in this report but cannot guarantee its accuracy or completeness. Any views expressed in this report are those of AEMO unless otherwise stated, and may be based on information given to AEMO by other persons.

This report or the information in it may be subsequently updated or amended. This report does not constitute legal, business, technical or engineering advice, and should not be relied on as a substitute for obtaining detailed advice about the
National Electricity Law, the National Electricity Rules, or any other applicable laws, procedures or policies or the capability or performance of relevant equipment. Accordingly, to the maximum extent permitted by law, AEMO and its officers, employees and consultants involved in the preparation of this report:

• make no representation or warranty, express or implied, as to the currency, accuracy, reliability or completeness of the
information in this document; and

• are not liable (whether by reason of negligence or otherwise) for any statements or representations in this document, or
any omissions from it, or for any use or reliance on the information in it.

Copyright
© 2025 Australian Energy Market Operator Limited. The material in this publication may be used in accordance with the copyright permissions on AEMO’s website.

1
AEMO (December 2023) Compliance of Distributed Energy Resources with Technical Settings: Update, https://www.aemo.com.au/-
/media/files/initiatives/der/2023/oem_compliance_report_2023.pdf?rev=11aeb76499ed4c49834b160cad75a38d&sc_lang=en.
Executive summary

Executive summary
This report provides an update on the state of distributed energy resources (DER) compliance with the technical standard AS/NZS 4777.2 - 2020 (the ‘2020 Standard’) for inverter-based DER installed in early 2024 (Q1/Q2).

The 2020 Standard includes disturbance ride-through requirements that are necessary to maintain power system security during periods of very high inverter-based DER contribution. This report provides an update to AEMO’s previous reports on DER compliance to the 2020 Standard2. It finds the following:

• The available data from various sources consistently indicates that 80-90% of new DER inverters installed in
early 2024 (Q1/Q2) Australia-wide were correctly configured to the 2020 Standard grid code.

• The observed improvements in compliance have been largely due to voluntary actions taken by inverter
original equipment manufacturers (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 30-100 kilowatts (kW) DPV and 100 kW-5 megawatts (MW)
PV non-scheduled generation (PVNSG), despite improvements in inverter compliance. Based on limited
evidence available to date, 5-30 MW PVNSG appear to successfully perform disturbance ride-through.
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:

– OEMs: implement 2020 Standard amendments, improve datasets for compliance assessment and continue
to improve compliance where feasible.

– DNSPs: develop mature compliance assessment capabilities, consider regulatory changes required to
govern remote inverter updates, and update technical standards to reflect recent AS/NZS4777.1:2024
changes.

– AEMO and DNSPs: collaborate to investigate 30 kW–5 MW disconnections, improve visibility of 30 kW-
30 MW systems, develop technical performance requirement for 200 kW-5 MW systems, improve DER
register data and quantify DPV replacement rates.

– Consumer Energy Resources (CER) Roadmap Workstreams: including governance arrangements
relating to data collection, provision and use, and installation and commissioning. Roles and responsibilities
for monitoring, assessing, and enforcing compliance are clarified.

2
At https://aemo.com.au/initiatives/major-programs/nem-distributed-energy-resources-der-program/standards-and-connections/compliance-of-
der-with-technical-settings.

© AEMO 2025 | Compliance of Distributed Energy Resources with Technical Settings: 2025 Update 3
Contents
Executive summary 3

1 Compliance estimates 5

2 Actions to improve compliance 7

3 Other measures of compliance 8

3.1 Method 2: Volt-VAr assessment 8

3.2 Method 3: Disturbance ride-through in the field 9

3.3 Method 4: Physical inspections 9

3.4 Method 5: Laboratory bench testing of inverters 10

4 Disturbance ride-through 11

5 Datasets 14

6 Governance arrangements 15

7 Recommendations 16

Tables
Table 1 Compliance rate for new installations in early 2024 based on Volt-Var assessments 8
Table 2 Compliance rate for new installations based on CER physical site inspections 10
Table 3 Observed disturbance ride-through performance of DPV by installed capacity 11
Table 4 Recommendations 16

Figures
Figure 1 Estimates of quarterly compliance to the AS/NZS4777.2:2020 grid code 5
Figure 2 Estimated proportions of installations on each setting by region 6
Figure 3 Compliance rates of new installations to the 2020 Standard for individual OEMs, showing
improvement between early 2022, Q1-Q2 2023 and Q1-Q2 2024 7
Figure 4 United Energy and Victorian Power Networks compliance rates over time 9
Figure 5 Ride-through capabilities of installed DPV and PVNSG fleet up to 5 MW in the NEM
(historical and future) 13
Figure 6 Estimated visibility of the Q1&2 2024 inverter installations provided by OEM datasets 14

© AEMO 2025 | Compliance of Distributed Energy Resources with Technical Settings: 2025 Update 4
Compliance estimates

1 Compliance estimates
Analysis of data provided by OEMs indicates that installation compliance has continued to improve, with 94% of new inverters installed in Q1 and Q2 2024 Australia-wide correctly configured to the 2020 Standard grid code3, as illustrated in Figure 1. This finding is based on a sample of internet-connected DPV, representing around
65% of new installs, with data provided by 13 inverter OEMs.

Figure 1 Estimates of quarterly compliance to the AS/NZS4777.2:2020 grid code

Note: the OEMs included in the aggregation vary by quarter, based on which OEMs responded to the data request. Market coverage associated with these OEMs varies from 52% to 95%. Compliance estimates in this plot are scaled by OEM market share in that calendar year and assume that the visible portion of an OEM’s fleet is representative of their entire fleet.

AEMO continues to recommend that governance gaps in monitoring and maintaining compliance with
technical standards are addressed as a priority4. Maintaining high DER compliance is an essential
underpinning of power system security – it delivers benefits to customers through increased DER hosting
capacity (more DER able to be installed) and minimises intervention costs.

Voluntary and temporary actions taken by many stakeholders (particularly by a selection of OEMs who
voluntarily updated product menus and commissioning 5 processes to better assist installers in selecting the
correct grid codes) have achieved the 90% target. To ensure these levels are maintained and monitored, and
that the rollout of future updates to standards is well managed, it is now essential to establish suitable
governance frameworks to ensure clear roles and responsibilities and procedures in place to monitor and
maintain compliance, and availability of suitable datasets.

3
An inverter is taken to be ‘compliant’ when set to any 2020 Standard region code as the inverter is expected to perform disturbance ride-
through requirements irrespective of region code (either Australia A, B, or C).
4
See Section 7 (background provided in sections 3.2 and 4.2) in AEMO (Dec 2023) Compliance of Distributed Energy Resources with
Technical Settings: Update, at https://aemo.com.au/-/media/files/initiatives/der/2023/oem_compliance_report_2023.pdf?la=en.
5
See work underway through the Federal Department of Climate Change, Energy, the Environment and Water (DCCEEW) seeking to establish
a National Regulatory Framework for CER, at https://consult.dcceew.gov.au/natl-cer-roadmap-tech-priorities-consult.

© AEMO 2025 | Compliance of Distributed Energy Resources with Technical Settings: 2025 Update 5
Compliance estimates

AEMO’s analysis indicates that compliance rates have improved consistently across all regions, as shown in
Figure 2. Compliance rates for new installations in all regions were between 91% and 95% in Q1 2024 6.

Figure 2 Estimated proportions of installations on each setting by region
Q1 2023 Q1 2024

Note: in Q1 2023, 7-11 OEMs provided data with regional breakdowns, depending on the state. In Q1 2024, 12 OEMs provided data with regional breakdowns. Data was scaled for state-based market share. Data provided was insufficient to separate Western Australia into South West Integrated
System (SWIS) and non-SWIS.

6
An inverter is taken to be ‘compliant’ when set to any 2020 Standard region code as the inverter is expected to perform disturbance ride-
through requirements irrespective of region code (either Australia A, B, or C). However, it is noted that inverters should be set to Australia B
in the Western Australian South West Integrated System (SWIS) and Australia C in Tasmania and the Western Australian non-SWIS (Horizon)
network.

© AEMO 2025 | Compliance of Distributed Energy Resources with Technical Settings: 2025 Update 6
Actions to improve compliance

2 Actions to improve compliance
The observed improvements in compliance have been largely due to voluntary actions taken by OEMs. As shown in Figure 3, updates to OEM menus that reduce accessibility of incorrect grid codes is effective, however taking action early is essential due to lag times 7,8. One OEM that has relied on installer training alone showed a smaller and slower improvement in compliance outcomes.

An amendment to the 2020 Standard (AS/NZS4777.2 Amd 2:20249) was released in August 2024. This introduced a requirement to label legacy grid codes as ‘obsolete’ 10, so installers are better guided toward correctly selecting the latest grid codes. This will come into effect from 23 August 2025 and be enforced through the Clean Energy
Council’s (CEC’s) inverter listing process11.

Figure 3 Compliance rates of new installations to the 2020 Standard for individual OEMs, showing improvement
between early 2022, Q1-Q2 2023 and Q1-Q2 2024

Note: compliance rates shown for earliest quarter in 2022 (first bar, dark blue), Q1&Q2 2023 (second bar, various colours) and Q1&Q2 2024 (third bar, various colours), as provided by each OEM. Compliance rates do not include any improvements due to remote updates. Error bars indicate uncertainty related to sample sizes of data provided by OEMs, but do not account for potential bias due to lack of visibility of non-internet-connected fleet.
Information for OEM E was not available for early 2022.

7
Several OEMs have also undertaken remote updates to inverter settings to correct to the 2020 Standard and have developed bulk remote
update capabilities. However a lack of clear governance arrangements has meant that some OEMs are seeking authority from DNSPs to
update inverter settings, and it is understood DNSPs require appropriate contractual arrangements to grant this authority as discussed in
Section 3.2 of AEMO (Dec 2023) Compliance of Distributed Energy Resources with Technical Settings: Update, at https://aemo.com.au/-
/media/files/initiatives/der/2023/oem_compliance_report_2023.pdf?la=en.
8
The impact of different OEM actions including lag times are discussed in greater detail in Section 3.1 of AEMO (Dec 2023) Compliance of
Distributed Energy Resources with Technical Settings: Update, at https://aemo.com.au/-/media/files/initiatives/der/2023/
oem_compliance_report_2023.pdf?la=en.
9
Standards Australia, at https://www.standards.org.au/standards-catalogue/standard-details?designation=AS-NZS-4777-2-2020-Amd-2-2024.
Published on 23 August 2024, with a one-year transition period for manufacturers to implement.
10
Where these legacy settings are provided for service and repair purposes. OEMs may also opt to remove legacy settings.
11
See CEC 2024 inverter standards update and inverter products listing at https://cleanenergycouncil.org.au/industry-programs/products-
program/inverters/standards-change, noting that this process involves a manufacturer self-declaration of compliance.

© AEMO 2025 | Compliance of Distributed Energy Resources with Technical Settings: 2025 Update 7
Other measures of compliance

3 Other measures of compliance
The assessments above are based on data provided by OEMs on the settings applied to their devices in the field 12.
A number of other methods were also used to further validate these compliance estimates, as discussed below.
Validation and cross-checks are critical to providing robust compliance estimates, given the known dataset limitations13.

3.1 Method 2: Volt-VAr assessment

United Energy (UE), Victorian Power Networks (VPN) and SA Power Networks (SAPN) have developed Volt-VAr compliance monitoring systems. These systems use smart meter data to assess individual DER device compliance with the Volt-VAr settings in technical standards. This method allows tracking of continuing compliance over time, enabling identification of issues that can emerge after installation such as firmware changes or batch issues that have been observed to affect compliance.

Compliance rates for installs in early 2024, based on Volt-VAr assessments of a sample of DPV, are shown in
Table 1 and indicate compliance rates have improved to within a similar range across multiple regions. These estimates of compliance are lower than the 94% estimate based on OEM data, which may be caused by a bias towards internet connected sites in the OEM datasets14.

Table 1 Compliance rate for new installations in early 2024 based on Volt-Var assessments

Network Compliance rate for new installs Date range for new installs

United Energy (UE) 92% Q1&Q2 2024

Victorian Power Networks (VPN) 89% Q1&Q2 2024

SA Power Networks 82% Q2 2024
A
AusGrid 72-84% Q1&Q2 2024
A. A range is provided for Ausgrid, as both the methods used by UE/VPN and SAPN were applied to the Ausgrid dataset.

Compliance rates measured via Volt-VAr assessment in the VPN/UE networks over time are shown in Figure
4Figure 4, showing the considerable improvement achieved. This provides an important validation of the datasets provided by OEMs.

12
An inverter is taken to be ‘compliant’ when set to any 2020 Standard region code as the inverter is expected to perform disturbance ride-
through requirements irrespective of region code (either Australia A, B, or C). However, it is noted that inverters should be set to Australia B
in the WA SWIS and Australia C in Tasmania and the WA non-SWIS (Horizon) network.
13
For further information on dataset limitations, see Section 4.1 in AEMO (Dec 2023) Compliance of Distributed Energy Resources with
Technical Settings: Update, at https://aemo.com.au/-/media/files/initiatives/der/2023/oem_compliance_report_2023.pdf?la=en.
14
It is also plausible that the discrepancy is in part due to cases where the 2020 Standard was selected correctly, however changes have then
been made to the Volt-VAr settings during or after commissioning.

© AEMO 2025 | Compliance of Distributed Energy Resources with Technical Settings: 2025 Update 8
Other measures of compliance

Figure 4 United Energy and Victorian Power Networks compliance rates over time

Note: the sample size reduces over winter due to fewer cases where voltage exceeds the threshold (248 volts [V]) to undertake Volt-Var assessment.

3.2 Method 3: Disturbance ride-through in the field

When power system disturbances occur, AEMO assesses the ride-through performance of DPV inverters in the field based on active power measurements from a sample of DPV inverters. Analysis of DPV performance during disturbance events in 2024 has indicated that rooftop DPV (<30 kW) installed since April 2023 (likely set to the
2020 Standard) shows significantly improved ride-through performance15,16,17. However, sample sizes in the datasets available for DPV on the 2020 Standard are small. Improved datasets are required to confirm this finding.

3.3 Method 4: Physical inspections

The Clean Energy Regulator (CER) undertakes physical site inspections as part of its administration of the Small- scale Renewable Energy Scheme (SRES)18. A statistically significant sample of DPV installations are inspected at random on a rolling basis19. Two CER audits have been completed that inspected compliance with the 2020

15
Based on available data during the 13 February 2024 event, only 1%-8% DPV installed post April 2023 experienced shake-off compared with
6-9% installed prior to April 2023. During 25 and 27 March 2024 events there were zero observations of < 30 kW DPV installed post April
2023 experiencing shake-off, compared with ~8-16% of DPV installed prior to April 2023.
16
AEMO (July 2025) Final Report – Trip of Moorabool – Sydenham 500 kV No. 1 and No. 2 lines on 13 February 2024, at https://aemo.com.au/-
/media/files/electricity/nem/market_notices_and_events/power_system_incident_reports/2024/final-report---loss-of-moorabool---sydenham-
500-kv-lines-on-13-feb-2024.pdf?la=en.
17
AEMO (October 2024) Addendum on DPV and load behaviour: 275 kV current transformer failures in South Australia 14-27 March 2024, at
https://aemo.com.au/-/media/files/electricity/nem/market_notices_and_events/power_system_incident_reports/2024/addendum-on-dpv-and-
load-behaviour275-kv-current-transformer-failures-in-south-australia-1427-march.pdf?la=en.
18
Discussed further in Section 2.2 of AEMO’s April 2023 report, Compliance of Distributed Energy Resources with Technical Settings, at
https://aemo.com.au/-/media/files/initiatives/der/2023/compliance-of-der-with-technical-settings.pdf?la=en. Further information on the SRES
scheme is at http://www.cleanenergyregulator.gov.au/RET/Scheme-participants-and-industry/Agents-and-installers/Small-scale-Renewable-
Energy-Scheme-inspections.
19
This sample is taken from across Australia for installations where SRES applications have been created in the previous 12-18 months. This
time delay is to allow for small-scale technology certificates (STCs) to be claimed.

© AEMO 2025 | Compliance of Distributed Energy Resources with Technical Settings: 2025 Update 9
Other measures of compliance

Standard. Overall, only half the sites inspected had settings visible to the inspector during both audit rounds 20.
Compliance outcomes21 from the FY23-24 and FY24-25 audits are summarised in Table 2, with compliance rates based on OEM data for the same period shown for comparison. The audit outcomes are aligned with the compliance rates observed in OEM datasets. This higher compliance rate based on OEM data for the FY23-24 audit round may be caused by a bias towards internet connected sites in the OEM datasets. There is a noticeable drop in the visibility of the CER audit inspections, it is understood that this is due to the challenges with the accessibility of settings data, such as challenges with password protection, or OEMs shifting from physical displays on the inverter, to an app-based interface.

Table 2 Compliance rate for new installations based on CER physical site inspections

Audit round Installation period Sample size A Visible proportion Compliance rate B Compliance rate
(number of sites) of sites (physical (based on OEM
inspections) data)

FY23-24 1 July 2022 – 30 June 2023 2,799 68% 69% 75%

FY24-25 1 July 2023 – 30 June 2024 2,532 42% 89% -

Subset 1 January 2024 – 30 June 2024 1,197 40% 92% 94%
FY24-25 C
A. Including visible and non-visible sites.
B. Compliance rate calculated based on visible portion only.
C. AEMO requested OEM data for installations from 1 January 2024 to 30 June 2024.

3.4 Method 5: Laboratory bench testing of inverters

AEMO is collaborating with researchers at University of NSW Sydney and University of Wollongong to perform laboratory bench testing of individual inverters and loads to investigate potential risks related to their performance under various grid conditions. This work is funded through the CSIRO and GPS-T research roadmap partnership22.

A total of 21 inverters set to the 2020 Standard have been tested. Several inverters failed to pass ride-through tests as well as reconnection and power quality responses, as stipulated in the 2020 Standard. This could mean that even if inverters are set correctly to the 2020 standard, some may demonstrate poor ride-through performance in the field. On investigation, this identified challenges around the interpretation of the standard test requirements, and highlights limitations in the current Standards testing and evaluation process.

Additionally, the bench testing sought to test for scenarios beyond the Standard requirements, that represent realistic or plausible future cases. This included testing for altered grid parameters (such as weak grid conditions) and DPV parameters (such as its power output levels), resulting in the inverters performing undesirable responses. This highlights the continued challenge of understanding these devices and the need for visibility of their behaviour in the field.

20
In the FY23-24 audit 42% were not visible, and in 3% of cases the inspector left all fields blank. In the FY24-25 audit, 58% were not visible
and in 4% of cases the inspector left all fields blank. For further details refer to Section 2.2.1 of AEMO’s April 2023 report, Compliance of
Distributed Energy Resources with Technical Settings, at https://aemo.coCouldm.au/-/media/files/initiatives/der/2023/compliance-of-der-with-
technical-settings.pdf?la=en.
21
An inverter was generally taken to be correct when a 2020 Standard was selected (that is, Region A, B or C irrespective of the local network
requirements). In the FY23-24 audit, 17% were on the incorrect standard, and 14% partially correct. In the FY24-25 audit, 5% were on the
incorrect standard, and 6% partially correct.
22
GPS-T Consortium Research Roadmap; for more information, see https://globalpst.org/csiro-aemo-and-g-pst-release-research-roadmap-to-
support-australias-energy-transition/.

© AEMO 2025 | Compliance of Distributed Energy Resources with Technical Settings: 2025 Update 10
Disturbance ride-through

4 Disturbance ride-through
To fulfil its responsibility to manage power system security, AEMO needs to understand the likely disturbance ride--through performance of the installed DPV and PVNSG fleet. Table 3 provides a summary of observed behaviours for the various size categories of DPV and PVNSG.

Table 3 Observed disturbance ride-through performance of DPV by installed capacity

Category of DPV Available evidence Dataset limitations Considerations for power
system analysis (based on
evidence available as at August
2025)A

Rooftop (<30 kW) Analysis of behaviour in power system Sample sizes in the It is likely appropriate to assume
disturbances suggests that rooftop DPV available datasets remain that <30 kW DPV installed after 1
(<30 kW) installed since April 2023 small at present. AEMO will April 2023 successfully rides
demonstrates significantly improved ride- continue to monitor through power system
through performance. performance and seek disturbances as per specifications
improved datasets to verify in the 2020 Standard, and that
this finding. <30kW DPV installed prior to April
2023 has poor disturbance ride-
through capabilities.
30-100 kW • Analysis since 2018 consistently shows that Suitable datasets to Based on available evidence, it is
these systems have a higher disturbance diagnose the cause of likely appropriate in power system
shake-off rate than systems <30 kW; in 30-100 kW DPV disturbance studies to assume very poor
some events this can be up to 20 times shake-off are very limited at disturbance ride-through
greater. present. AEMO is working capabilities, until further evidence
• These systems have not shown any with DNSPs to improve becomes available to confirm
observable improvement in ride-through availability of this data. improvements.
behaviours in disturbances since
introduction of the 2020 Standard.
• Shake-off is apparent across all National
Electricity Market (NEM) regions and
inverter manufacturers.
• Central protectionB has been identified as a
possible cause of these high disconnection
rates, but suitable data to confirm this have
not been sourced.
• Recent updates to AS/NZS4777.1 seek to
address this possible issue, but the extent
to which governance arrangements
effectively ensure correct application of the
new requirements is unclear for some
jurisdictions.

PVNSG 100-200 kW Based on preliminary assessment of Analysis has relied on third As above.
disturbance events occurring from mid-2023 party monitoring to date as
to mid-2025: DNSPs monitoring
• This size category demonstrates high requirements typically only
disturbance shake-off rates, similar to apply for sites exporting
30-100 kW DPV. above 200 kW. Datasets
can be complex to interpret
• Shake-off is apparent across all NEM due to multiple monitoring
regions and inverter manufacturers. points and varied inverter
configurations.

© AEMO 2025 | Compliance of Distributed Energy Resources with Technical Settings: 2025 Update 11
Disturbance ride-through

Category of DPV Available evidence Dataset limitations Considerations for power
system analysis (based on
evidence available as at August
2025)A
PVNSG 200 kW to Based on assessment in South Australia: Analysis has been limited to As above.
5 MW • This size category demonstrates high South Australia to date due
disturbance shake-off rates, similar to to limited data availability for
30-100 kW DPV. this size category in other
regions.
• This applies to both 100-500 kW and
500 kW-5 MW PVNSG.

PVNSG 5-30 MW Based on assessment in South Australia, this Analysis has been limited to Based on available evidence, it is
size category appears to ride-through South Australia to date due likely appropriate to assume that
disturbances successfully (no evidence of to limited data availability for these systems successfully ride-
disturbance shake-off is observed). this size category in other through power system
regions. disturbances in power system
analysis.
Note: The AEMO distributed PV model (DERAEMO1) for PSS®E does not currently incorporate the assumed poor ride-through performance of systems sized 30 kW to 5 MW, where only 50% of installed capacity is expected to ride through power system disturbances. This exclusion is due to limited evidence to date for PVNSG >200kW, the relatively small installed fleet compared to the 0 to 30 kW range, and the minimal difference such systems would have on dynamic simulations given known error margins (±30%) for DPV shake-off behaviour. If the 30 kW to 5 MW fleet continues to demonstrate poor ride-through characteristics, AEMO may revise the DERAEMO1 model parameters accordingly.
A. Subject to change as more information becomes available over time.
B. Also referred to as Integrated Protection in AS/NZS4777.1:2024.

AEMO is collaborating with DNSPs and other stakeholders to understand the underlying causes of shake-off, and to clarify technical requirements for 200 kW-5 MW DER connections23.

Figure 5 provides a forward projection of the total DPV and <5 MW PVNSG fleet in the National Electricity Market
(NEM) that is expected to correctly perform the necessary disturbance ride-through behaviours. This projection assumes that legacy DPV systems retire after a 10-year lifetime24, and indicates a plateauing of the total size of the
DPV fleet that demonstrates poor ride-through capabilities from 2024 onwards.

23
AEMO (September 2024), Technical Requirements for 200 kW to 5 MW DER connections, Public consultation report, at
https://aemo.com.au/-/media/files/initiatives/engineering-framework/2024/aemo_technical-requirements-for-200kw-to-5mw-der-
connections_sept-2024_final_.pdf?la=en.
24
It is assumed that inverters retiring from December 2021 will be replaced with new inverters set correctly to the 2020 Standard at the same
compliance rate observed for the fleet during that quarter (that is, compliance rates based on OEM data, as shown in Figure 1).

© AEMO 2025 | Compliance of Distributed Energy Resources with Technical Settings: 2025 Update 12
Disturbance ride-through

Figure 5 Ride-through capabilities of installed DPV and PVNSG fleet up to 5 MW in the NEM (historical and future)

Note: OEM compliance rates prior to January 2024 are weighted by state-based market share in Q1 2023, while compliance rates after this date are weighted by their state-based market share in Q1 2024.

© AEMO 2025 | Compliance of Distributed Energy Resources with Technical Settings: 2025 Update 13
Datasets

5 Datasets
One of the most important datasets for assessing compliance is the data on inverter settings applied in the field, which has been provided voluntarily by selected OEMs to date. There are currently no guidelines or obligations for
OEMs to collect data on compliance of their product settings in the field, or to provide this data to external parties.
OEM capabilities to collect and extract this data vary considerably. It is estimated that the OEM datasets used in this analysis represent around 65% of new installs, as shown in Figure 6, taking into account market share and approximate internet connectivity rates.

Figure 6 Estimated visibility of the Q1&2 2024 inverter installations provided by OEM datasets

Overall, these OEM datasets have improved in quality since AEMO’s previous assessment 25, with the majority of
OEMs providing larger sample sizes and an increased number of OEMs providing regional information (such as postcode or state). However, all datasets continue to be provided in OEM-specific formats, with varying degrees of completeness. Further, OEMs have varied capabilities to extract data; some are able to automatically extract data for all online sites in Australia, whereas others require a list of serial numbers to extract data 26 and some rely on a manual extraction process.

Minimal data on DPV replacement rates is available. The DER Register will ideally provide this visibility going forward, however the DER Register has a number of data quality challenges including uneven regional coverage and poor data quality27.

25
AEMO (Dec 2023) Compliance of Distributed Energy Resources with Technical Settings: Update, at https://aemo.com.au/-/media/files/
initiatives/der/2023/oem_compliance_report_2023.pdf?la=en.
26
For some sites, AEMO can extract serial numbers from the DER Register to provide to OEMs. However, the DER Register has significant
data quality issues that limit the number of sites where this can be successfully achieved.
27
Observed issues with the DER Register include:
• uneven regional coverage (for instance in New South Wales around 10,000 were listed in the DER Register compared with 60,000 in the
CER Register for the same period),
• poor serial number quality (approximately 35-55% of serial numbers for six OEMs not conforming with the standard format as advised by
each OEM), and
• incorrect Standard information (where specific sites were able to be matched between the OEM provided data and DER Register, up to
~30% of sites in the DER Register did not contain a standard version (such as the 2020 Standard) consistent with that provided by the
OEM.

© AEMO 2025 | Compliance of Distributed Energy Resources with Technical Settings: 2025 Update 14
Governance arrangements

6 Governance arrangements
High rates of compliance have been achieved following voluntary product menu and other improvements by
OEMs in 2023. However, the process of working with OEMs and other stakeholders on these improvements has revealed significant gaps in the governance processes around assessing and managing compliance to CER technical performance standards. These gaps relate to the need for a clear definition and regulation of roles and responsibilities in monitoring, enforcing, and rectification of compliance to technical standards, both at point of install and ongoing. Specific activities that should be pursued include:

• recognising the crucial role and influence of OEMs in managing compliance, with clear guidelines and
obligations defined,

• collection and provision of suitable datasets to monitor and assess compliance,

• managing firmware updates that can affect ongoing compliance with technical standards,.

• evaluating the testing and certification process for inverter products to ensure that testing laboratories interpret
and satisfy the Standard specifications as intended, and certification processes more robustly confirm
compliance,

• developing appropriate processes to address and enforce non-compliance with technical settings – the existing
and available lever for DNSPs to disconnect the customer from the network is considered excessive and
penalises the incorrect party (the customer), and

• improved installation accreditation frameworks that extend to power system security needs and capture the
end-to-end installation process, including commissioning.

AEMO is engaging in the National CER Technical Regulatory Framework, Data Sharing Arrangements 28, and
Redefining Roles for Market and power system operations 29 workstreams as part of the National CER Roadmap 30, aiming to address these gaps. These workstreams are focused on establishing a nationally consistent regulatory framework, enabling secure and coordinated data exchange, and clarifying roles and responsibilities across the ecosystem. AEMO sees these workstreams as the appropriate avenue to address the identified gaps in compliance governance.

In parallel, AEMO acknowledges the Government of Western Australia’s DER Roadmap 31 is developing a DER
Compliance Framework for the South West Interconnected System (SWIS), aimed at establishing DER device compliance mechanisms tailored to Western Australia's unique grid conditions, regulatory environment and existing linear contracting relationship between the Network Operator and Network User (Retailer) in the non-contestable market.

28
DCCEEW, National CER Roadmap – Data Sharing Arrangements (M2), at https://app.converlens.com/climate-au/national-cer-roadmap-data-
sharing-arrangements-m2.
29
DCCEEW, National CER Roadmap – Redefine roles for market and power system operations (M3/P5), at https://app.converlens.com/climate-
au/national-cer-roadmap-redefine-roles-m3-p5.
30
Energy and Climate Change Ministerial Council (ECMC) National CER Roadmap, at https://www.energy.gov.au/sites/default/files/2024-
07/national-consumer-energy-resources-roadmap.pdf.
31
Government of Western Australia, Distributed Energy Resources Roadmap, Third Progress Report, July 2024, Status of Actions, Table 2,
Action 4, at https://www.wa.gov.au/system/files/2024-07/248948epwaderrroadmap26_july.pdf.

© AEMO 2025 | Compliance of Distributed Energy Resources with Technical Settings: 2025 Update 15
Recommendations

7 Recommendations
There is a broad suite of recommended actions by various parties in the industry to maintain and improve compliance with the 2020 Standard. Detailed recommendations are outlined in Table 4Table 4, noting that progress is underway in a number of cases. AEMO is actively engaging with all the parties noted on these actions, and will continue to monitor compliance rates based on the datasets available.

Table 4 Recommendations

Key parties Proposed actions

OEMs • Implement 2024 amendments to AS/NZS4777.2:2020: update product menus as detailed in the amendment
as soon as possible, if not already done so, in line with the August 2025 requirement.
• Improve data:
– Develop robust data systems that can be readily queried to provide ongoing assessment of compliance to
the 2020 standard as well as individual 2020 standard settings.
– Recommended fields include accurate and complete regional information (postcode/region), grid
code/standard and settings, installation date (or first online date), inverter serial number, National Metering
Identifier (NMI) where available, inverter model, firmware version, installer.
• Continue to improve compliance where feasible:
– Continue pursuing all available actions to maximise compliance rates for all new installs.
– Where feasible, undertake remote updates to maximise compliance for all installs from December 2021
(when the 2020 standard became mandatory)

DNSPs • Continue to develop conformance monitoring capabilities to assess and support ongoing compliance
to Standard: formalisation of conformance monitoring roles is being considered in the National CER
Workstreams (as mentioned below). Other short-term activities could include developing:
– standard compliance reporting processes for new and existing installs such as identifying compliance
through volt-var assessments,
– dashboards to allow for frequent reporting, ideally including breakdowns by OEM and ideally by specific
inverter models,
– suitable cross-checks (for instance between smart meter and OEM datasets), and
– close out processes that are underpinned by compliance checks and rectification pathways.
• Remote inverter updates: consider regulatory changes required in all regions in partnership with relevant
regulatory bodies to govern remote inverter updates. Work with Standards bodies and industry to develop
remote update use-cases and capability.
• Update technical standards: as part of updating embedded generation technical standards to reflect
AS/NZS4777.1:2024 changes (particularly regarding interface protection and disturbance withstand
requirements), ensure governance arrangements assess and validate compliance.

© AEMO 2025 | Compliance of Distributed Energy Resources with Technical Settings: 2025 Update 16
Recommendations

Key parties Proposed actions

AEMO & DNSPs • Investigate 30 kW-5 MW disconnections: investigate and address high rates of disconnection for 30-100 kW
DPV and 100 kW-5 MW PVNSG systems.
• Develop technical performance requirements for 200 kW- 5 MW systems: continue to collaborate on
technical requirements, starting with DNSP adoption of AEMO’s guidelinesA within their connection policy and
practices.
• Improve visibility of 30 kW-30 MW systems: establish appropriate operational visibility of the performance
of these systems (may consider existing metering options and investigation of future options), collate standing
data and develop suitable analysis tools to assess disturbance ride-through.
• Improve DER register data: continue to work togetherB on improving the quality of new and existing DER
Register data through improved data collection, cross-checking and validation, updating the DER Register
guidelines to reflect the 2020 Standard and improve consistency between the guidelines and Application
Programming Interface (API).
• Quantify replacement rates: AEMO and DNSPs collaborate to develop improved estimates of
replacement/retirement rates.
• Engage with Standards Australia relevant Technical Committees and industry:
– Improve inverter settings compliance through remote validation and update of settings: standardise
and map inverter parameters and functions to communication protocols (such as CSIP-Aus), to improve the
pathways in which inverter settings data is accessed, collected, and in future rectified.
– Standardise test reporting (as part of AS/NZS4777.2): develop a standardised test report format that all
test labs are required to follow and provide. This could include specification of the methodology followed,
results reporting structure and content. A clear and consistent reporting format could ensure that the test
reporting assessment and approval can be correctly evaluated.
CER Roadmap • Data collection, provision, and use governance arrangements: the governance arrangements around the
Workstreams collection and provision of data, and monitoring of data for the purpose of compliance assessment to
(T.2, M.2, and technical standards (at both install and ongoing operation) and for the purpose of enforcement, should be
M.3/P.5)C considered.
• Device testing and certification: the governance arrangements for device certification and testing should
consider identified challenges with the existing certification process, and address issues around interpretation
of testing, and clear guidelines on reporting and assessment.
• Installation, and commissioning governance arrangements: the governance arrangements around the
installation, commissioning, and point of sale of product should be extended to ensure compliance of devices
to technical standards and technical settings.
• Clear roles and responsibilities for monitoring, assessing, and enforcing compliance: clear roles and
responsibilities for relevant parties in monitoring datasets, assessing compliance, and enforcing requirements
to enhance regulatory oversight.
A. AEMO is working closely with DNSPs to align the 200 kW to 5 MW connection standards with the minimum performance requirements needed to manage bulk power system risks; systems of this size are not currently addressed under AS 4777 or NER Chapter 5 technical standards. AEMO is seeking to publish guidelines in Q4 2025, incorporating technical feedback through ongoing engagement with DNSPs, and providing a first step towards nationally consistent requirements.
B. AEMO is engaging with the New South Wales “Smart Connect” project as a step towards improved DER Register data capture. More information is available at https://arena.gov.au/knowledge-innovation/smart-connect-initiative/#:~:text=Smart%20Connect%20is%20focused%20on%20supporting%20 industry%20collaboration,key%20activity%20or%20coordination%20gaps%20in%20these%20areas.
C. T.2 refers to National regulatory framework for CER to enforce standards; M.2 refers to Data sharing arrangements to inform planning and enable future markets; M.3/P.5 refers to Redefining roles for market and power system operations.

© AEMO 2025 | Compliance of Distributed Energy Resources with Technical Settings: 2025 Update 17