The last time the AER reviewed its ‘Rebidding and Technical Parameters Guideline’ was back in 2019:

• prior to the commencement of Five Minute Settlement
• as described in the WattClarity Glossary Page pertaining to Rebids.

In recent months our cups have runneth over with new clients coming onboard, and other busyness of business – as a result of which the ‘part-time job’ of posting analysis and commentary here on WattClarity has suffered its own form of (economic or network?) curtailment.

One of the various reviews that we missed the opportunity to comment on was the AER commencement, via this Consultation paper into possible updates to the AER’s ‘Rebidding and Technical Parameters Guideline’:

… that paper was published on 24th March 2026 (i.e. 3 months ago now), but is still worth noting here:

Skimming through the document, we noted a couple things;

Proximate trigger

On p5/19 the AER notes that the IPRR reform is a trigger for the conduct of this review.

Scope of Review

Also on p5/19 under section 1.1 (Scope of Review) the following jumped out to us:

‘Beyond this, we are seeking stakeholder views on market developments and emerging risks including:

− failures for VSRs to meet dispatch instructions as a result of passive load and whether this could be considered non-compliance related to an “abnormal plant condition or other abnormal operating requirements” (NER, clause 3.8.19(a));

− ramp rate rebidding and the minimum safe operating level (MSOL) of a plant (including addressing concerns around rebidding of ramp rates below minimum allowable levels during periods where units may need to be dispatched out of merit order to manage network or other operating constraints); and

− expectations for Auto-bidding, otherwise known as the use of a computer algorithm by Market Participants to submit bids and rebids automatically with limited or no human intervention (including the utilisation of third-party providers), and the rebidding of batteries.

We are also seeking views from stakeholders in relation to the use of Artificial Intelligence (AI) in the bidding process, with a view to building understanding of emerging opportunities and risks. Specifically, we are seeking views on:

− the benefits and risks relating to the use of Auto-bidding and asset optimisation technologies in the bidding process; and

− potential mechanisms to ensure sufficient transparency, performance and accountability to maintain market integrity in relation to the utilisation of these technologies.

The increase in the usage and sophistication of AI is a broad issue which will impact all parts of the energy sector. Determining the appropriate regulatory response is a complex issue and will require significant consultation between market bodies and participants. Given the nexus between rebidding and technical parameters and the use of AI, we consider there are efficiencies to begin seeking this information as part of this process.’

… with some formatting added, for ease of readability.

Consultation Questions

Worth copying the consultation questions in here (from p6 & 7), for ease of future reference:

‘Question 1.

Are there any other items related to the IPRR rule change that may need to be addressed in the Guideline outside of those set out in sections 2.1.1 and 2.1.2, and if so, what are they?

Question 2.

Given the policy intent and broader benefits of the IPRR rule change, do you consider that it would be appropriate for the ‘other abnormal operating requirement’ categorisation to be used for VSRs in circumstances where the dispatch mode mechanism does not allow the accurate offering of VSR capacity during certain conditions (such as during a supply scarcity event)? Why?

Question 3.

Do you have any views on other ways in which this passive load issue could be addressed, for example, by rebidding a unit’s ramp rate down to zero if required?

Question 4.

Does the Guideline need to provide greater detail in relation to establishing the MSOL of a unit, and if so, what further detail is required? What criteria should be used to evaluate a unit’s MSOL?

Question 5.

Would further specificity regarding the MSOL in specific conditions (for example, any time that a unit may need to be dispatched out of merit order to manage network constraints) be useful? If so, what specific guidance would be of use?

Question 6.

What additional guidance on ramp rates would be of use? Do you think the Guideline clearly explains that ramp rates should not be utilised to manage the commercial impacts of network constraints?

Question 7.

What guidance (outside of reference to the ST PASA Procedures) would be beneficial in relation to the ST PASA Recall Period?

Question 8.

Do you consider additional guidance relating to the expectations for Market Participants utilising Auto-bidding software (including third party software) and for the third party providers would be useful? If so, what guidance would be of assistance?

Question 9.

Do you consider there would be any benefit from adding additional transparency on the utilisation of Auto-bidding in a rebid reason? Why?

Question 10.

Explain whether the proposed methodology for receiving this information listed above would be effective in providing market transparency.

Question 11.

How could the volume of battery rebids (particularly when we are seeing numerous rebids within the same dispatch interval) be reduced, whilst maintaining the necessary market integrity?

Question 12.

Do you consider there are any changes to the requirements for the recording of contemporaneous notes for battery rebids that could be implemented to help to reduce regulatory burden whilst still providing necessary integrity?

Question 13.

What are your views regarding the utilisation of AI in Auto-bidding technology? What do you consider the potential benefits and harms as this technology becomes more utilised and sophisticated?

Question 14.

How can the AER ensure sufficient transparency and accountability of technology being utilised for bidding and rebidding?

Question 15.

What, if any, amendments to the NER are required to address the utilisation of AI in the bidding process?

Question 16.

Do you consider there are AI issues that are directly relevant to the Guideline which require it to be amended? If so, how?’

I’ve added some highlights, for ease of our future reference.

Indicative Timing

Also worth pulling out Table 1 here, which spoke to an Indicative timeline for Guideline review:

I might have missed it, but could not find any publication of a Draft Guideline, which the indicative timetable suggested might happen by 10th June 2026 (10 days ago).

15 + 3 Submissions (and one we did not submit)

Readers can find more information about this review process here on the AER website, including now:

• 15 submissions received before submissions closed on 31st March 2026, from:
  • #1 = AEMO
  • #2 = AFMA
  • #3 = Akaysha Energy
  • #4 = Alinta Energy
  • #5 = CS Energy
  • #6 = EnergyAustralia
  • #7 = Engie
  • #8 = Ergon Energy Retail
  • #9 = Iberdrola
  • #10 = Justin and Equity Centre
  • #11 = OptiGrid
  • #12 = Origin Energy
  • #13 = Shell Energy
  • #14 = Snowy Hydro
  • #15 = Telsa
• and 3 late submissions (from Eku Energy, Fluence and Neoen) received after submissions closed.

As one of our team noted recently on an internal Slack channel, this would have been an opportunity for us to make a submission to reiterate our suggestion that ‘each rebid should cost $10’ :

• under Question 11 (and potentially also Q13).
• note here where we’ve mentioned this.