By Sarah Pick, Partner

What is changing for NSW embedded networks?

NSW embedded networks are moving further into the regulatory spotlight.

From 1 July 2026, embedded network sellers must meet new obligations around customer information, access to dispute resolution and transparency. Maximum pricing and billing standard requirements are expected to follow in the first half of 2027, after IPART’s methodology and billing standard have been approved and the commencement date is specified.

For landlords, developers and onsellers, the practical message is clear: this is not just an energy billing issue. The reforms may require changes to contracts, billing systems, customer communications and compliance processes, and they are backed by enforcement risk if sellers do not comply.

Why does this matter?

Embedded networks are common in apartment buildings, strata schemes, retirement villages, caravan parks, shopping centres and mixed-use developments. They are often treated as a property or asset management issue, but these reforms make clear they are also a live regulatory compliance issue.

What do embedded network sellers need to do now?

As of 1 July 2026, embedded network sellers in NSW who supply electricity, gas, hot water or centralised air-conditioning through an embedded network now need to do more than simply pass through charges.

They need to be able to explain what they supply, where they supply it, what they charge, and how customers can get help if something goes wrong.

The immediate obligations are practical, but important. Sellers must be members of the Energy & Water Ombudsman NSW, ensure customers can access their complaints pathway, and publish current information on their website about the embedded network services they provide, the prices they charge, and the premises they supply.

For centralised air-conditioning, there are additional transparency requirements around system efficiency, including information about energy consumed, cooling energy produced, and the system brand or model.

What further changes are coming?

The 1 July changes are only the first step. IPART is consulting on the methodology for maximum prices and the billing standard that should apply to embedded networks. Those requirements are expected to commence in the first half of 2027, but will depend on the final approved framework and commencement date.

Once in force, sellers will not be able to charge more than the applicable maximum price determined by IPART.

Billing will also need to meet new standards, which may affect how energy use is measured, presented and explained to customers.

For landlords, developers and onsellers, this may require changes to contracts, customer communications, metering arrangements, billing systems and internal compliance processes.

There is also enforcement risk. The reforms are backed by penalties for non-compliance, including failures to publish required information, charging above the applicable maximum price, or not complying with billing standards once they are in force. That should be enough to move this from a “watching brief” to an active compliance workstream.

Who should be paying attention?

Landlords, developers, strata managers, retirement village operators, shopping centre owners and other onsellers should be checking now whether they are captured by the new framework.

In practical terms, that means asking some fairly simple questions now:

• Are we supplying electricity, gas, hot water or centralised air-conditioning through a private network?
• Who is actually the seller?
• Are our website disclosures current and complete?
• Do our customer documents and bills explain the charges clearly?
• Are our systems ready for maximum prices and billing standards from 2027?

What this means in practice

• The compliance burden here is not especially complex: website content, complaints pathways, billing information, price limits and systems readiness. But it is significant. Embedded networks have often sat in the background of property transactions and development structures. The NSW reforms bring them much closer to the front of the risk register.
• For anyone owning, developing or on-selling within an embedded network, now is the time to map the arrangements, identify who holds the compliance obligations, and get ready for the next phase of the reforms.

Acknowledgements

My thanks to Sarah Poli for her assistance in preparing this article. If you would like advice on the implications of the NSW embedded network reforms, please feel free to reach out to me as your primary contact.