On 20 October 2026 the AEMC received two requests from the federal energy minister to change the National Electricity Rules, and it had published both by 28 October. ERC0461 would oblige data centres to back their load with firmed supply; ERC0462 would ease connection for sites with their own generation, storage or flexible demand. This note reads each against the inashanu register and market model.
1What each request asks for
Under ERC0461, a data centre would show the AER, before connecting and at later reviews, that its demand is backed by firming in its own NEM region: contracts with generation and storage, by default from new plant, plus behind-the-meter storage and dependable demand flexibility. Financial penalties would be the main sanction, with a possible requirement to cut demand until cover is shown. The obligation would apply above a size threshold, possibly in tiers, and the request leaves the number to the AEMC (ERC0461 request, September 2026). Reports that it has no MW threshold mean that no figure is set.
ERC0462 asks for an integrated connection pathway assessed at the connection point, for a load to join an existing generator without reopening that generator’s performance standards unless the change is material, and for demand flexibility to be written into connection agreements as a binding term. It prescribes no threshold, and it does not intend to serve sites co-located solely with non-renewable generation (ERC0462 request, September 2026).
Neither request is initiated; initiation brings a consultation paper. The AEMC’s July advice gave 12 to 18 months for rule making and as long again for implementation, about 24 to 36 months in all after the trigger, and advised against retrospective obligations. Those times are indicative and the AEMC has not consulted on them (AEMC, advice to ECMC, 28 July 2026, p. 13).
| Request | What it requires | Share of the register’s pipeline it reaches | Timing |
|---|---|---|---|
| ERC0461, firmed energy contracting obligation | Data centres above a threshold not yet set show the AER that their load is backed by firming in the same NEM region, by default from new plant, before connection and at reviews; financial penalties | NEM tranches hold 91% of the register’s pipeline IT load where a figure is published at a 30 MW threshold and 87% at 100 MW; the model’s year-end medians rise 0.49 GW from end-2029 and 1.16 GW from end-2028 to end-2030 | Received 20 Oct 2026; not yet initiated; obligations about 24 to 36 months after the trigger, on the AEMC’s indicative estimate, which it has not consulted on |
| ERC0462, connections for integrated facilities, co-located plant and flexible loads | An integrated connection pathway; co-location beside existing plant without reopening its standards unless the change is material; binding flexibility terms in connection agreements; no threshold prescribed | 16% of the register’s pipeline IT load where a figure is published, in NEM tranches planning on-site plant, none under construction; the flexibility path is open to any large load and cannot be measured from the public record | Received 20 Oct 2026; not yet initiated; no timetable set |
Source: AEMC, ERC0461 and ERC0462 requests (September 2026, received 20 October 2026) and advice to ECMC (28 July 2026, p. 13); inashanu register and market model (21 October 2026).
2The firming obligation: region, timing and size
| NEM region | Register’s pipeline IT load where a figure is published, MW | No planning consent yet, MW | Under construction, MW | Operating at end-2030, mean across the model’s runs, MW |
|---|---|---|---|---|
| New South Wales and the ACT | 9,463 | 6,924 (73%) | 1,512 | 1,453 |
| Victoria | 11,181 | 9,227 (83%) | 1,550 | 1,044 |
| South Australia | 4,119 | 4,117 (99.9%) | 2 | 68 |
| Queensland | 1,676 | 1,466 (87%) | 3 | 62 |
| Tasmania | 379 | 50 (13%) | 84 | 86 |
| NEM | 26,818 | 21,783 (81%) | 3,151 | 2,712 |
| WA and the NT, outside the NEM | 2,524 | 2,270 (90%) | 158 | 179 |
| The register’s pipeline | 29,341 | 24,054 (82%) | 3,309 | 2,890 |
Source: inashanu register and market model, 21 October 2026. Rows may not add because of rounding.
New South Wales, with the ACT, and Victoria hold 92% of a mean across the model’s runs of 2.71 GW of IT that the register’s NEM pipeline puts in operation by the end of 2030 (inashanu market model, 21 October 2026). The same-region rule would call for new firming mainly there. Of that 2.71 GW, a mean across the model’s runs of 1.67 GW comes from tranches already under construction (inashanu market model, 21 October 2026).
The central case puts 4.36 GW of IT in operation in Australia at the end of 2030, including the 1.55 GW operating at the evidence date, so the register’s pipeline adds about 2.81 GW; P10 to P90 is 3.44 to 5.58 GW. The year-end medians are 3.20 GW for 2028 and 3.87 GW for 2029 (inashanu market model, 21 October 2026). If the indicative 24 to 36 months ran from receipt, obligations would start between October 2028 and October 2029; the AEMC’s timeline runs after the trigger and was not consulted on (AEMC, advice to ECMC, 28 July 2026, p. 13). The model’s year-end medians rise 1.16 GW from end-2028 to end-2030 and 0.49 GW from end-2029, so the obligation could reach 0.49 to 1.16 GW of IT added after the end of 2028 or 2029 (0.7 to 1.7 GW of facility power at the register’s ratio of 1.43; inashanu register and market model, 21 October 2026). A rule for new connections alone would reach less, missing later blocks on campuses already connected.
Size matters more for 2030 load than for the register’s pipeline. Of the 113 pipeline tranches with a published figure, 27 are under 30 MW of facility power and hold 0.2 GW of IT, and 52 are under 100 MW and hold 1.4 GW, or 4.8% (inashanu register, 21 October 2026). In the model, smaller tranches reach operation sooner; 18 of the 52 are under construction (inashanu register, 21 October 2026). Those under 100 MW supply 0.61 GW, or 21%, of a mean across the model’s runs of 2.89 GW from the register’s pipeline by the end of 2030, and 14% when counted by campus with what already operates there (inashanu market model, 21 October 2026).
The request could size firming to the connection agreement’s ramp profile or the full daily load (ERC0461 request, s4.2), and names over-procurement during ramp-up as a risk (s7). Operating NEM data centres drew about 27% of their connection capacity in FY26 (AEMO, data centre forecasting overview, 25 August 2026), against 45% to 51% expected at maturity (AEMO 2026 ESOO, 25 August 2026), so cover sized to the connection would run well ahead of use.
3The connection path
Of the register’s pipeline IT load, where a figure is published, 6.7 GW (23%) plans on-site or off-grid power; none is under construction, and a mean across the model’s runs of about 120 MW of it is in operation by the end of 2030 (inashanu register and market model, 21 October 2026). In the NEM it is 4.6 GW, 16% of the register’s pipeline, with 4.2 GW in three campuses only announced: Yallourn (2.0 GW; EnergyAustralia fact sheet, June 2026) and Cooke Plains (1.2 GW; SkyLab project page, 19 October 2026), both taken as IT, no basis stated, and Mayfield, near Denman (up to 1.0 GW of IT; Akaysha Energy project page, read 20 October 2026; AltEnergy, 25 June 2026). A mean across the model’s runs of 89 MW of the NEM share is in operation by the end of 2030, 3% of the NEM’s 2.71 GW on the same measure; the other 2.1 GW lies in Western Australia and the Northern Territory. One approved NSW campus, at Moss Vale, plans gas alone, outside the stated intent (scoping report for SSD-102795459, 25 September 2025; NSW Department of Planning, Housing and Infrastructure, SEARs for SSD-102795459, 22 December 2025). The register does not record flexibility offers, so that path’s reach is unmeasured.
For the path to matter, more projects would have to design for it, and the 24.1 GW with no planning consent yet, where a figure is published, still can. The other condition sits in ERC0461: if behind-the-meter storage and flexibility earn a useful firmness rating, co-location becomes a way to meet the obligation.
4Timing against the register’s pipeline
A mean across the model’s runs of 0.66 GW of the 24.1 GW with no planning consent yet, where a figure is published, is in operation by the end of 2030, so nearly all of it would reach operation, if at all, after an obligation could start; in the delivery record the net median time to first operation is 41 months from announcement or lodgement (inashanu market model and delivery record, 21 October 2026). The 13.1 GW (45%) with no planning application on record, where a figure is published, would seek consent while the rules are made (inashanu register, 21 October 2026).
5Our reading
On the model’s year-end medians, 0.5 to 1.2 GW of IT would be added after the firming obligation starts and before the end of 2030. Its larger effect falls on projects with no planning consent yet, which would carry the cost of new firmed supply in their own region into siting and design. 16% of the register’s pipeline IT load, where a figure is published, plans on-site plant in the NEM, nearly all of it announced only, and the connection path’s weight turns on how ERC0461 rates on-site plant. A threshold anywhere from 5 to 100 MW changes the register’s pipeline covered by under five points, and the 2030 load, on a mean across the model’s runs, by up to a fifth.
inashanu has made a submission on the AEMC’s separate consultation on network cost recovery.
6What to watch
- The consultation papers: the threshold, any tiers, and whether data centres already connected are covered.
- ERC0455, the visibility rule the minister asked on 10 September 2026 to be progressed as a priority, whose registration ERC0461 may use to apply the obligation.
- How demand is measured (ramp profile, daily load or metered use), and how behind-the-meter storage and flexibility are rated.
- The cut-off date for new plant, and any settings ministers vary by jurisdiction, which would need ECMC consent.
- The next register release, for proposals with no planning consent yet that add on-site plant.
This note is research and analysis. It is general information only, it is not investment advice, and it does not take account of any reader’s objectives or circumstances.