EUAA Submission: AEMC Security Framework Enhancements, and, Clarity and Transparency in Security Frameworks Consultation Paper
Emily Wood | April 16, 2026
The Consultation Paper combines two rule change requests on system security, essential system services and the NSCAS framework:
• one from AEC/CEC that considers clarifying the governance of system security, and
• one from AEMO who want to extend timelines and have more powers to intervene in system security
‘Thank you for the opportunity to make a submission under the AEMC’s Security Framework Enhancements (ERC0424) and Clarity and Transparency in Security Frameworks (ERC0428) Consultation Paper.
While we understand why the AEMC has chosen to consider the two rule change requests together, we view them as addressing distinct issues and recommend that they be progressed sequentially rather than concurrently.
The AEC/CEC request is fundamentally about governance, with some targeted operational improvements. In contrast, AEMO’s request seeks broader operational changes to the NSCAS framework. The fact that AEMO has sought these changes suggests that the AEMC’s Improving Security Frameworks for the Energy Transition rule change is not operating as intended.
We were optimistic that the intent of that rule change would be upheld. At the time, the AEMC stated:
“Specifically, the final rule evolves existing frameworks with the aim of ensuring sufficient security services are provided as the power system continues to transition to higher penetrations of inverter-based resources. It also ensures AEMO can procure necessary security services that fall outside these frameworks, and ‘enable’ security services in operational timeframes to ensure that the power system is secure day-to-day.”
We had expected TNSPs to continue proactively investing in system security where generators were not providing it, with AEMO acting as a back‑stop for broader NEM security issues. Instead, implementation has diverged from this intent. TNSPs are generally waiting for AEMO’s system security plan before commencing their own procurement processes. This has created several issues…’
Please download the attached document to read our full submission.
