EUAA Submission: Reforming Prices For Customers in Embedded Networks – DEECA Vic
Emily Wood | July 2, 2026
The Vic Min for Energy is proposing to force embedded network operators to charge less than the DMO, which already does not cover the costs to operate.
‘…The EUAA welcomes the opportunity to provide feedback to the Reforming prices for customers in electricity and gas embedded networks Consultation Paper, as published by the Victoria Department of Energy, Environment and Climate Action (DEECA).
The EUAA represents a broad membership base that includes businesses which operate embedded networks, as well as businesses that operate within them as commercial tenants. This dual representation provides the EUAA with a balanced perspective across both sides of the commercial arrangements that underpin embedded networks. Drawing on this experience, we consider that there are issues within the existing framework for commercial businesses which could be compounded, rather than resolved, by the proposed changes.
Commercial embedded networks operate in a fundamentally different context to residential sites, and the regulatory approach should reflect that distinction. While the EUAA supports strengthening consumer protections for residential customers, commercial premises typically operate under bespoke, negotiated arrangements led by procurement teams or energy specialists who secure terms tailored to their operational needs.
These arrangements bear little resemblance to residential supply and are not the focus of the reforms DEECA is seeking to progress. As such, applying residential‑oriented regulatory settings to commercial customers would be inappropriate and risk undermining well‑functioning commercial agreements. It is also not clear that a regulatory failing has been identified within commercial embedded networks, and no justification or evidence has been presented for expanding regulation beyond current requirements….’
Please download attachment to read full submission.
