The energy regulator names its priorities a year ahead. We checked all five against what it did

Why this comparison is possible at all

Most regulators tell you what they did. The AER also tells you, a year in advance, what it intends to concentrate on, and then structures the following year’s report around those same headings. The 2024-25 report, published July 2025, sets out five priorities for 2025-26. The 2025-26 report, published 30 July 2026, carries sections 2.1 to 2.5 that map onto them one for one.

That matters more than it sounds. It means the comparison is the regulator’s own framing rather than ours, and it avoids the trap that makes enforcement totals nearly meaningless year to year: a single large court penalty landing in one year and not the next swings the figure without telling you anything about conduct. Priorities and outcomes are stable categories. Dollar totals are not.

The five, and what each produced

Priorities as stated in the 2024-25 report, July 2025. Outcomes as reported in the corresponding section of the 2025-26 report, July 2026. The summary in the right column is ours; the detail behind each is below.

Where the enforcement actually landed

The vulnerability priority is the one with completed outcomes, and they are the matters we covered separately in the Centrepay story. Alinta Energy Retail Sales paid $1.089 million after 15 infringement notices, and EnergyAustralia paid $142,800 after two. Both were for alleged breaches, and paying an infringement notice is expressly not an admission of liability, which is a distinction worth keeping because it is easy to lose. Alongside that, the AER reports approving three retailer hardship policies with six more under review.

The power system priority produced Federal Court proceedings against Transgrid, instituted on 17 December 2025 following an investigation into the October 2024 power system events behind the Broken Hill outages. Those are allegations before a court and nothing more should be read into them.

The report’s own appendix table is the cleanest thing in it for anyone tracking legal status, because it gives the date proceedings commenced beside the outcome. The AGL Centrepay matter shows proceedings commenced 16 December 2022 and a $25 million penalty ordered 19 December 2024, and elsewhere the report records that AGL has appealed both the decision and the penalty, that the appeal was heard on 27 and 28 November 2025, and that judgment was reserved. Two years from filing to first-instance penalty, and still not final.

Where it did not, and why that is not automatically a failure

Three priorities produced no completed enforcement, and the reasons are not the same.

Smart meters is a rollout the AER is overseeing rather than policing after the fact. The reforms require distributors to submit Legacy Meter Replacement Plans setting out how legacy meters are replaced in a timely, cost-effective, fair and safe way to reach universal uptake by 1 December 2030. In 2025-26 the AER reviewed and published 13 distributor plans and issued guidance to retailers in September 2025 on site defects, tariff structure changes and shared fusing. Reviewing plans before meters go on walls is the right order of operations.

Gas reporting was in its first compulsory year. The Annual Compliance Order covers 17 service providers across 76 pipelines. The AER’s assessment found 10 compliance concerns: four on confidentiality obligations including isolated instances of improper disclosure, five on non-price terms and conditions, and one on user access guides. It wrote to 14 providers, and says it considered most issues had a limited market impact. A first round that maps the field and sets rectification timeframes is a reasonable use of a new power.

Connections and ring-fencing is the one where the gap between the priority and the activity is widest. The report describes the AER as engaging in research and monitoring related to current practices and monitoring to improve visibility of connection timeframes. It names real pressure on the system: growing connection volumes, and large inverter-based loads (such as data centres) alongside system security risks and uncertainty about who pays for upstream augmentation. A priority named for a year that produces visibility work is a priority still being scoped.

The change worth noticing

Buried in the priorities section is a decision about the mechanism itself. The AER states it will now undertake a full review of the priorities every 2 years, with consultation on the 2027-28 priorities to commence in early 2027.

There is a real argument for it: an enforcement priority that changes every twelve months is hard to build a multi-year case around, and the matters above show why, with two years between filing and a first-instance penalty. Steadier priorities may suit the work better.

The cost is the thing this article is made of. An annual statement of intent followed by an annual report against it is a tight accountability loop that very few regulators offer. Stretching it to two years halves how often anyone can check, and the AER did not frame it as a trade-off. It is worth saying that it is one.

What it means for a household here

None of this happened in the Hunter, and the Broken Hill matter is far-west New South Wales. The connection is that the same rules apply here and two of the five priorities are squarely domestic. Every household in this region is inside the smart meter transition, with universal uptake due by 1 December 2030 and the plans for replacing legacy meters now public. And the hardship protections the first priority is about apply to every retailer serving the Hunter.

The connections priority is the one to watch locally rather than nationally. Data centres and other large inverter-based loads are named in the report as pressure on the connection framework, and this region is where a great deal of new generation and transmission is being connected. A priority that is currently research is the one most likely to become enforcement.

Our view, labelled as such

Reading two of these reports side by side, the honest summary is that the AER did what it said it would in the two areas where the tools were already sharp, and spent the year building the instruments in the three where they were not. That is a defensible year. It is also a year in which the phrase doing most of the work is “monitoring”, and monitoring is not a result.

What we would ask for is not more penalties. It is that the next report say what the monitoring found. The gas section does exactly that, with a count of compliance concerns by rule, and it is much the most informative part of the document as a result. The connections section does not, and it is the least. The difference between those two sections is the difference between a regulator reporting on its work and describing it.