Submissions were invited to inform South Australia’s implementation of the National Energy Market (NEM) market making obligation (MMO) under the Firm Energy Reliability Mechanism (FERM).

Background

With South Australia at the forefront of the national energy transition to low emission sources, it is vital to ensure that electricity financial market structures support wider system advances.

In late 2025, NEM Energy Ministers agreed in-principle to the recommendations of the NEM wholesale market settings review expert panel, led by Associate Professor Tim Nelson. These recommendations included that South Australia lead the introduction of a market making obligation (MMO) to address declining electricity contract market liquidity, and improve transparency, accessibility and price discovery of hedging products, with MMO products to be determined by an industry-led co-design process.

The MMO will initially be empowered through the National (South Australia) (Firm Energy Reliability and Orderly Exit Management) Regulations 2025 (FERM Regulations), before transitioning to a national approach in 2027 following required legislative amendments. It will impose minimum daily contracting requirements on long duration firm capacity providers with obligations outlined in the FERM Minister’s guidelines. The MMO will be implemented as the FERM market liquidity obligation (MLO).

What is being decided

While the MMO framework being implemented in South Australia adopts the national approach developed by the NEM review, there are a number of design elements that are still to be finalised. This consultation asked for specific feedback to inform these remaining elements of the MMO framework ahead of implementation mid-2026.

Find out more

Consultation paper

More information on the MMO framework to be adopted, and the design elements that are still to be finalised, is available in the consultation paper. This document included a Consultation Response Template for providing feedback on the questions posed in the consultation paper.

• Firm Energy Reliability Mechanism Market Making Obligation Consultation Paper
  (PDF, 648.0 KB)

Online industry webinar

DEM hosted an online industry session on Tuesday 3 February 2026.

Have your say

You were invited to have your say on the FERM MMO by:

• Reading more about the consultation on the South Australian government YourSAy website
• Downloading and providing your feedback via the Consultation Response Template (DOCX, 1.1 MB)
• Emailing a submission to dem.ferm@sa.gov.au

Date for submissions has now closed.

Submissions received

The development of South Australia's Firm Energy Reliability Mechanism