Guide · glossary

Embedded networks explained: why you can't always choose your own energy retailer

An embedded network is a private electricity network inside a bigger site, like a shopping centre or office tower, where the site operator buys power in bulk and on-sells it to tenants. That can limit your ability to switch retailers, and new AER rules from January 2026 change how these networks have to operate.

By Joe Lawrence 7 min read
No cost to you. We're paid by the energy retailer when you switch.

I’m Joe from Smarta Switch in Brisbane. One of the most common calls I get starts the same way: someone’s ready to switch their business electricity, quotes in hand, then finds out they can’t switch at all. Almost every time, it’s because the business sits inside what’s called an embedded network, and it’s one of the least understood corners of the whole energy market. Here’s what’s actually going on, and what changed on 1 January 2026.

We’re paid by the energy retailer when you switch, never by you.


What is an embedded network?

An embedded network is a private electricity network inside a larger site. Instead of every business inside that site having its own direct connection to the state grid, the site itself runs off one, or a small number of, bulk connections. An embedded network operator buys that power, usually in bulk from the wholesale market, and on-sells it to the individual tenants inside.

You’ll find embedded networks in:

  • Shopping centres
  • CBD office towers
  • Industrial or business parks
  • Retirement villages

If your business operates out of any of these, there’s a real chance you’re sitting inside one, whether anyone’s ever explained that to you in plain words or not. You’re still metered and billed individually for what you use, it’s just the site operator doing the billing, not an energy retailer.

Picture a small business renting a kiosk in a suburban shopping centre. The centre has one big connection to the grid, and either the centre’s management or a specialist operator they’ve contracted buys the power in bulk and on-sells it to every tenant inside, from the anchor supermarket down to the coffee cart. Each tenant still gets billed for exactly what they use, they just never see a retailer’s name on that bill.


Why you can’t always choose your own retailer

On the open market, switching electricity retailers is simple: get quotes, compare them properly, pick the sharpest one, sign. (Here’s exactly how we compare quotes.)

Inside an embedded network, that process usually doesn’t apply, because you’re not buying electricity from a retailer in the first place. You’re buying it from the network operator, who bought it in bulk on behalf of the whole site. There’s no retail contract for you to shop around on, because there’s no retailer relationship to begin with, just an on-selling arrangement between you and whoever runs the site.

That’s the real reason so many tenants get told “you can’t switch” the moment they ask. It’s not a brush-off, it’s genuinely how the network is built.

None of this makes the arrangement dodgy or illegal. It’s a legitimate, regulated structure, embedded network operators need an exemption from the Australian Energy Regulator to run one, and that exemption framework is exactly what changed on 1 January 2026.


Not just a Brisbane thing

This isn’t a Queensland quirk. Embedded networks work the same way in every capital city and industrial precinct in Australia. A tenant in a Sydney CBD tower, a Melbourne shopping centre or a Perth business park runs into exactly the same restriction as one in a Brisbane high-rise. Whether the operator on your site is the landlord themselves or a third-party embedded network specialist they’ve contracted in, the tenant experience is the same everywhere: one operator, one bill, no open-market shopping around. If your business operates sites in more than one state, don’t assume the setup is different from one site to the next, the mechanics are national.


What changed on 1 January 2026

The Australian Energy Regulator (AER) published a Final Decision that overhauls the exemptions framework embedded networks run under, bringing in a new Network Exemptions Guideline v7 and Retail Exempt Selling Guideline v7.

The headline changes, from 1 January 2026:

  • Most new embedded networks must formally register for an exemption. Previously, plenty of networks could be set up under an automatic or deemed exemption without actively applying to the AER. Those automatic and deemed exemptions are closing for new configurations.
  • Operators have to publish their tariffs. Tenants, and prospective tenants signing a lease, can actually see the pricing rather than finding out what they’re charged after they’ve moved in.
  • New hardship and family-violence protection obligations now apply to embedded network customers, bringing those protections closer into line with what open-market retail customers already get.

One important detail: existing embedded networks that already hold an exemption aren’t forced to change under the new rules. This is mainly about how new networks get set up and run from here, not a retrospective overhaul of every site already operating.


What this means if you’re a tenant

A few practical things worth knowing:

  • Check whether you’re actually embedded. Not every multi-tenant site is. Look at your bill: if it doesn’t carry a familiar retailer’s name and logo, or it references an “on-sold” rate or the site’s own energy plan, that’s a strong sign you are.
  • Ask the site operator or body corporate directly. They should be able to tell you who supplies the network and, under the new rules, what the tariff actually is.
  • Some sites allow a direct connection to the grid, sitting outside the embedded network entirely. It’s not guaranteed on every site, and it can carry real cost and lead time, but it exists as an option in some cases.
  • Get your bill checked anyway. Sometimes only part of a site is embedded and your particular tenancy isn’t, or you’ve assumed you’re locked in when you’re not. We’ll look at your bill and tell you straight whether you’ve genuinely got no options or more room to move than you think. If you are properly inside an embedded network with no way out, we’ll say so rather than waste your time, we’re paid by the energy retailer when you switch, never by you, so there’s nothing in it for us to string you along.

What to do this week

  1. Pull your last bill and check who it’s actually from. No familiar retailer name, or wording like “on-sold” or “network tariff”? That’s your first clue you’re on an embedded network.
  2. Ask your landlord, centre management or body corporate who operates the network, and whether anything’s changed for your site since 1 January 2026.
  3. Send us the bill anyway. Upload it on this page or email hello@smartaswitch.com.au. We’ll tell you honestly whether you’re on the open market, embedded, or something in between, and what your real options are. No cost, no commitment, because we’re paid by the energy retailer when you switch, never by you.

Embedded networks aren’t a scam and they’re not illegal, they’re a different structure with different rules, and hardly any tenant has ever had it explained to them properly. Now you know why the switch you tried to make didn’t go through, and what’s actually changing to make the arrangement fairer.

Joe Lawrence, Co-founder, Smarta Switch Australia 0435 642 592 · joe@smartaswitch.com.au

People also ask

Frequently asked questions

What is an embedded network?

An embedded network is a private electricity network inside a larger site, common in shopping centres, CBD office towers, industrial or business parks, and retirement villages. Instead of every business having its own direct connection to the grid, the site has one bulk connection, and an embedded network operator buys the power and on-sells it to the individual tenants inside.

Why can't I just choose my own electricity retailer?

Because you're buying your power from the embedded network operator, not directly from the open retail market, the usual model of comparing retailers and switching often doesn't apply. There's no retailer relationship to shop around on in the first place, just an on-selling arrangement between you and whoever runs the site.

What changed with embedded networks from January 2026?

The Australian Energy Regulator published a Final Decision overhauling the exemptions framework for embedded networks, bringing in a new Network Exemptions Guideline v7 and Retail Exempt Selling Guideline v7. From 1 January 2026, most new embedded networks must formally register for an exemption, and the old automatic or deemed exemptions are closing for new configurations.

Do the new rules make embedded network operators more transparent?

Yes. Operators now have to publish their tariffs, and follow new hardship and family-violence protection obligations, bringing embedded network customers closer into line with the protections open-market retail customers already get. It's aimed at closing the gap between what an embedded network tenant experiences and what an open-market customer experiences.

Does this change the embedded network I'm already in?

Not automatically. The new rules mainly apply to new embedded networks being set up from 1 January 2026 onwards, existing networks that already hold an exemption aren't forced to change. It's still worth asking your site operator directly whether anything has changed for your tenancy.

I think I'm in an embedded network, can Smarta Switch still help?

Sometimes only part of a site is embedded, or you actually have your own connection and are free to switch even though you assumed you weren't, so it's always worth sending us your bill to check. If you are genuinely locked into an embedded network operator our ability to help is limited, but we'll tell you straight rather than waste your time, and we're paid by the energy retailer when you switch, never by you.

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Upload your bill Call, 0435 642 592