WA AES Code for embedded networks and commercial sites

    WA Energy Market · AES Code
    A whole category of electricity services just got regulated.

    The Alternative Electricity Services Code brings embedded networks and adjacent services in WA under a formal regulatory regime for the first time. The biggest effect is on the buildings and operators running those arrangements. The broader signal is on every commercial site.

    Last updated · 21 May 2026
    What It Is

    The first formal regulation of services that weren't.

    For most of the history of the WA electricity market, the rules covered the standard arrangement: a customer connected to the grid, supplied by a licensed retailer, billed against published tariffs. A series of arrangements that didn't fit that mould, including embedded networks, on-supply, and shared metering, sat outside the formal regulatory framework. They were legal, they were widespread, and they were largely unregulated.

    The Alternative Electricity Services Code is the government's response to that gap. It brings those arrangements under a formal regulatory regime covering operator obligations, customer protections, pricing transparency, dispute resolution, and code of conduct.

    The Code is being implemented in stages, with operator registration, compliance requirements, and customer-facing obligations rolling out across the implementation period.

    What It Covers

    Four areas under the new regulatory scope.

    Embedded networks

    Apartment buildings, shopping centres, mixed-use.

    Buildings where electricity is bought in bulk and on-sold to occupants are now formally regulated. Operator obligations, billing standards, and customer rights all apply.

    On-supply arrangements

    Sites that pass electricity costs through.

    Caravan parks, residential parks, lifestyle villages, and other arrangements where electricity is supplied through a master meter and passed through to occupants come under the Code.

    Pricing transparency

    What occupants pay and why.

    Pricing structures, fee disclosure, and billing format are now subject to formal rules. The arrangements that have run on private contracts are being brought into public regulation.

    Customer protections

    Connection, disconnection, dispute resolution.

    Standard customer protections that have existed for grid customers are extended to alternative supply customers. Disconnection procedures, hardship arrangements, and dispute pathways are formalised.

    Who's Affected Most

    Three groups carrying the change.

    Embedded network operators

    Operators running existing embedded networks across apartment buildings, mixed-use sites, shopping centres, and commercial complexes carry the largest direct compliance load. Registration, code of conduct, billing standards, and customer protections all apply.

    Strata buildings with shared supply

    Strata-titled buildings where electricity is supplied through a master meter and on-charged to lots are within scope, regardless of whether they were set up as a "formal" embedded network.

    Commercial sites with behind-the-meter arrangements

    Commercial sites with internal billing arrangements, tenant on-supply, or other behind-the-meter electricity services need to assess whether they fall within the Code's definitions.

    What It Means In Practice

    More compliance overhead. Clearer rules.

    For operators of existing embedded networks and on-supply arrangements, the Code adds compliance overhead. Registration, formal customer agreements, standardised billing, and ongoing reporting obligations all apply. Some operators will find their existing arrangements need restructuring to comply. Others will find compliance straightforward.

    For buildings considering setting up an embedded network or moving to a behind-the-meter arrangement, the Code provides clarity that wasn't there before. The rules of the game are written down. The cost of compliance is knowable.

    For commercial sites on standard supply with no embedded network or on-supply arrangements, the Code is a signal rather than a direct change. It indicates the broader regulatory direction in WA: more formal rules, more transparency, more obligations across electricity arrangements that previously sat outside the regulatory net.

    How We Work With It

    The same lever, inside the new rules.

    The AES Code regulates how alternative electricity services are operated and how customers in those services are treated. It doesn't change the underlying maths of active energy management. The opportunity to reduce common-area consumption, run solar properly, dispatch batteries against demand and tariffs, and optimise supply arrangements all sit inside whatever regulatory regime the site operates under.

    What the Code changes is the surrounding accountability. Operators have clearer obligations. Customers have clearer rights. Pricing has to be transparent and defensible. Active management lands more naturally inside that framework because the underlying numbers it works with become the official record of what's happening on the site.

    For embedded network operators, active management is one of the levers that makes the new compliance overhead worth carrying. For strata buildings within scope, it's one of the levers that makes the building's energy position defensible to owners under the new standards.

    Common Questions

    What operators ask about the Code.

    If electricity is supplied to the building through a single master meter and then sold or on-charged to individual occupants or tenants, the answer is usually yes. The technical determination depends on the metering arrangement and the contracts in place. We can assess it as part of a building review.

    The Code is being implemented in stages, with operator obligations rolling out across the implementation period. Operators who fall within scope and don't register or comply face regulatory action over time. The realistic path for non-compliant arrangements is restructure, register, or exit the arrangement.

    No. The Code formalises the rules, it doesn't ban the arrangements. Well-run embedded networks remain viable and in many cases more defensible under formal regulation than they were under the previous ambiguity.

    Not directly. The AES Code regulates alternative arrangements outside standard retail supply. Sites on standard supply from a licensed retailer are unaffected by the Code itself, though related regulatory work touches retail customer protections.

    The Alternative Electricity Services Code and supporting implementation documents are published by Energy Policy WA. The framework is referred to in adjacent ERA work on retail contestability and prescribed customer definitions.

    The WEM rules govern the wholesale market and the licensed retail layer. The AES Code governs the layer underneath, where alternative arrangements sit. The two operate in parallel and a single building can be affected by both.
    Start With a Building Review

    Find out where your site sits under the Code.

    Free building review. We assess whether your arrangements fall within the AES Code, what compliance looks like, and how active management fits inside the new framework. No commitment.