What the Incoming Alternative Electricity Services Code Means for Strata Managers with Embedded Networks

Western Australia’s regulatory framework for embedded electricity networks, now referred to as single property networks (SPNs), is moving from voluntary to mandatory. The Alternative Electricity Services (AES) Code of Practice will introduce enforceable obligations for anyone operating an embedded network, including strata companies that manage their own electricity supply arrangements.

For strata managers overseeing buildings with embedded networks, understanding what is required and when is essential to preparing your portfolio.

Where things stand

The Voluntary Embedded Networks Code of Practice has been in effect since February 2024. The enabling legislation, the Electricity Industry Amendment (Alternative Electricity Services) Act 2024, passed through Parliament in April 2024.

The next steps in the regulatory timeline are:

• Energy Policy WA is expected to release information on the AES Code of Practice for consultation in the first half of 2026.

• The Economic Regulation Authority (ERA) is expected to open registration for single property network providers in the second half of 2026.

• Registration and full compliance with the mandatory code is expected to become compulsory in early 2027.

Non-compliance penalties under the mandatory code are expected to be up to $100,000.

What the mandatory code is expected to require

Based on the voluntary code and publicly available consultation materials, the mandatory AES Code is expected to include obligations across several areas.

Customer disclosure. Residents must receive a disclosure statement before electricity supply begins. This needs to clearly set out who supplies their electricity, what tariffs apply, and how billing works. All information must be clear, concise and easily understandable.

Metering standards. Each supply address must have an individual meter. Any meter installed after the code takes effect must meet relevant specifications and standards. Residents can request information about their meter type at any time.

Hardship policy. A written financial hardship policy must be in place, actively maintained, and publicly accessible on a website. It must include provisions for payment plans, fee waivers or reductions, access to financial counselling, and information on government concessions.

Family violence policy. Operators supplying residential customers must have a documented family violence policy. Staff must be trained to respond appropriately where a customer discloses a family violence situation.

Dispute resolution. Small-use customers must have access to the Energy and Water Ombudsman for independent dispute resolution. Buildings will need an internal complaints process in place before escalation to the Ombudsman.

Billing and tariffs. Clear invoicing obligations will cover consumption data, tariff rates, daily supply charges, and billing periods. Disconnection and reconnection must follow prescribed procedures.

Who carries the compliance obligation?

This is the question strata managers should be asking for every embedded network building in their portfolio: who is the Embedded Network Seller (ENS)?

The AES Code attaches obligations to the ENS, being the entity legally responsible for supplying electricity to residents within the network. In many WA apartment buildings, the ENS is not a specialist operator. It is the strata company itself.

If a building manages its own embedded network (collecting electricity payments, managing billing, or holding the master meter supply contract without a specialist provider in place) the strata company is likely the ENS. That means the strata company will need to register with the ERA, maintain all of the above policies, and demonstrate full compliance by early 2027.

The consequences of non-compliance are financial and reputational, and will fall directly on the owners corporation.

Check your compliance position in five minutes

To help strata managers and strata committees understand their obligations, Bright Connect has built a free interactive compliance assessment tool. It is available at aes.brightconnect.live.

The tool takes approximately five minutes to complete. It walks through the key obligations under the current voluntary code and the expected mandatory requirements, identifies where a building may have compliance gaps, and generates a written compliance report and action plan tailored to your building’s situation.

Whether a building currently has a specialist operator in place or the strata company is managing the embedded network directly, the tool provides a clear picture of where things stand and what needs to happen next.

Bright Connect’s approach

Bright Connect provides metering, invoicing, payment collection, debt management and full code compliance as an outsourced service for strata companies operating embedded networks. Under this arrangement, the strata company retains pricing control and the commercial benefits of the embedded network, while compliance obligations are handled by a specialist provider already registered under the voluntary code.

For strata managers looking to understand the compliance position of their buildings ahead of the mandatory code, the assessment tool at aes.brightconnect.live is a practical first step.

This article is brought to you by SCA (WA) sponsor Bright Connect.

Bright Connect Pty Ltd is a Perth-based embedded network utility services provider operating across residential and commercial developments in Western Australia. Bright Connect is registered under the Voluntary Embedded Networks Code of Practice.

1300 908 760 | admin@brightconnect.com.au | aes.brightconnect.live