Last week’s LookUpStrata webinar focused on changes to an embedded network in WA, including the code of practice, a topic that is rapidly gaining importance for strata managers, councils of owners and lot owners. Damian Moran from EnergyTec and Scott Bellerby from B Strata explained how embedded networks work, outlined the current legal landscape in WA, and walked through the upcoming Embedded Network Code of Practice. The session highlighted practical steps schemes can take now to improve transparency, prepare for registration, and position their buildings to benefit from solar, batteries and smart metering.
WA: Embedded networks in strata – what you need to know about upcoming changes | Damien Moran, EnergyTec + Scott Bellerby, B Strata – Aug 2025
What is an embedded network
An embedded network is a private electricity distribution system within a scheme that connects to the main grid through a single master “gate” meter. The scheme then manages internal metering and billing for lots. This is different to a traditional multi-meter arrangement where each lot has a direct account with the retailer. In an embedded network, the owners corporation can procure energy on contestable terms, manage on-selling within the limits of gazetted tariffs, and integrate generation such as solar and batteries.
Common billing models and who owns what
| Model | Who owns meters and assets | How billing works | Key implications |
|---|---|---|---|
| Multi-meter, no embedded network | Network operator owns meters. Scheme owns switchboards and internal wiring. | Each lot holds a direct retail account and receives a bill from the retailer. | Simple for billing, limited flexibility for renewables and on-site optimisation. |
| Embedded network, scheme-owned | Scheme owns internal meters and infrastructure. Scheme already owns internal electrical assets. | Scheme holds a master retail account, reads sub-meters, and on-bills residents. | Control over tariffs within caps, ability to tender supply, integrate solar and batteries, responsibility for compliance. |
| Embedded network, part third-party | Third-party may own meters under development or commercial agreements. | Licensed or exempt seller bills residents, sometimes through the strata manager. | Reduced control for the scheme, reliance on provider for data, billing, and disclosure. Contract diligence is essential. |
Regulatory framework in Western Australia, current and emerging
WA schemes with embedded networks generally operate under exemptions rather than full retailer licences. Existing obligations already arise across several instruments, including the Electricity Industry Act, the Energy Coordination Act for gas, the Strata Titles Act, tenancy legislation and consumer protection laws. The state is introducing a new Electricity Embedded Network Code of Practice under the Alternative Electricity Services framework. The policy intent is to lift customer protections, mandate clear disclosure, and provide access to the Energy and Water Ombudsman for independent dispute resolution.
Embedded Network Code of Practice, timeline and what it means
A voluntary code is already in effect. Government agencies and large customers expect alignment now. The final code is expected following consultation in late 2025. Registration of schemes will commence in the second half of 2026, with mandatory registration deadlines in early 2027. Registration will require an identified Embedded Network Operator, documented policies and procedures, and adherence to billing, hardship and dispute resolution standards.
| Phase | What to expect | What schemes should do |
|---|---|---|
| Now | Voluntary code in effect. Rising expectations for transparency and fair billing. | Align invoices to gazetted tariff caps. Improve itemisation. Prepare disclosure statements. Start policy drafting. |
| Late 2025 | Consultation on the final code and stakeholder engagement. | Review submissions. Update draft policies. Plan software and data changes. Brief council of owners. |
| Jul–Dec 2026 | Registration window opens. Schemes must register with the Economic Regulation Authority and the Energy and Water Ombudsman. | Nominate Embedded Network Operator. Finalise complaint handling and hardship policies. Confirm billing cadence and meter data access. |
| From Jan 2027 | Registration compliance required. Regulator and Ombudsman pathways active. | Demonstrate compliance on billing, disclosure, and dispute processes. Maintain accurate metering and audit trails. |
Pricing guardrails and billing cadence
Residential on-selling must not exceed gazetted A1 tariffs for the applicable supply area. Supply charges recover reasonable metering, data and administration costs, while usage charges reflect consumption. The code is expected to set a maximum billing period of two months, which means schemes and managers will need reliable meter reads, timely data and dependable invoicing workflows. Clear itemisation and advance notice of fee changes will be required. Where a meter fault requires estimation, schemes must document the estimation method and mark invoices accordingly.
Disclosure, hardship and disputes
The code’s focus is transparency. Residents should receive an information pack that explains who supplies electricity, what tariffs apply, how billing works, and how to lodge complaints. Schemes should adopt written hardship and payment support policies that apply consistently to utilities and, where appropriate, to levies. Complaint handling procedures should include an internal pathway and an escalation route to the Energy and Water Ombudsman if issues remain unresolved.
Governance, compliance and record keeping
Councils of owners should move from informal practices to documented policies adopted at a general meeting and reviewed annually. Bylaws may need updating to recognise embedded network operations, metering access, data sharing, renewable integration and billing processes. Schemes should keep meter accuracy records, usage histories and decision logs. They should also understand when utility on-selling creates assessable income that requires an annual tax return. Where a third-party provider is involved, the strata company should still maintain its own policies, request regular data and require clear resident-facing disclosures.
Opportunities for savings and resilience
Embedded networks can unlock value when schemes tender electricity on contestable terms, use smart metering to identify waste, and integrate solar and batteries to offset grid energy. Many schemes choose to recover at the tariff cap and return any surplus as reduced levies or reserve contributions. Interval data enables targeted actions such as adjusting plant schedules, fixing leaks in common services and right-sizing future renewables. Conversion from a traditional multi-meter setup to a scheme-owned embedded network can also create a funding pathway for end-of-life electrical infrastructure upgrades.
Case studies and real-world lessons
Recent WA examples show schemes halving electricity costs after embedding networks and procuring supply competitively, noting that wholesale movements can reduce some gains. Other schemes have used embedded network recoveries to fund switchboard replacements and modern metering. Success correlates with accurate data, clear resident communications and early policy adoption. Where third-party ownership constrains transparency, schemes benefit from negotiated disclosure and service standards written into agreements.
What to do next
Start with a compliance gap review. Assemble current invoices, meter lists, tariff settings and contracts. Draft a resident information pack that explains billing, tariff caps and complaint pathways. Prepare hardship and dispute policies, and set up a two-monthly billing rhythm that your software and meter partners can support. If you plan solar or batteries, commission a feasibility study that incorporates interval data and a procurement strategy. Put policy adoption on the next meeting agenda so the council of owners can formalise the approach and review it each year.
Resources
- Download the presentation slides: Embedded Networks in WA Strata
- EnergyTec News & Insights
Presenters
Damien Moran
EnergyTec
E: [email protected]
P: 08 9382 7700
Scott Bellerby
B Strata
E: [email protected]
P: 08 9382 7700
This post appears in Strata News #757.
Further reading
- WA: Q&A Strata bylaws + bylaw consolidation
- NAT: How fair contract principles are reshaping the strata world
- WA: Q&A Utility services in a strata scheme
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