On 26 March 2026, the AEMC published a consultation paper to seek stakeholder views on allowing the Australian Energy Market Operator (AEMO) to accept cash as credit support in the National Gas Rules (NGR) in response to a rule change request from Delta Electricity (Delta).

Certain participants in the Declared Wholesale Gas Market (DWGM) and the Short Term Trading Market (STTM) are required to provide an acceptable form of credit support to AEMO, unless exempted by AEMO. This provides financial assurance to AEMO in case a participant defaults and is unable to settle its outstanding dues. Currently, the only forms of credit support allowed by the NGR in these markets are bank guarantees or another immediate, irrevocable and unconditional commitment in a form acceptable to AEMO. The NGR currently does not allow cash as credit support in these markets.

Delta considers that while participants did not face barriers in obtaining bank guarantees historically, there has been an increasing trend of financial institutions no longer providing credit support to participants with exposure to fossil fuels, for example coal and gas fired electricity generation and coal mining. Hence, Delta perceives a real risk that a market participant, while being a profitable and solvent business, may be unable to provide credit support to AEMO.

We are seeking your views

Delta’s proposal is to allow AEMO to accept cash as credit support in the STTM and DWGM, in addition to bank guarantees. According to Delta, this would promote:

• lower financing costs for participants by allowing them to choose the least cost option available to them to provide credit support
• greater market efficiency by reducing barriers to entry and encouraging greater competition, particularly in the retail market
• more predictable and flexible credit support arrangements since participants generally have greater certainty about their own cash availability than obtaining bank guarantees.

We seek your feedback on:

• the issues raised in the rule change request
• the proposed solution to allow cash as credit support, any viable alternative solutions, and associated risks and implementation considerations
• our proposed assessment criteria.

Submissions to the consultation paper close on 30 April 2026.

Background

On 28 July 2025 the AEMC received a rule change request from Delta Electricity to amend the National Gas Rules. This request follows from a similar rule change made by the AEMC on 26 June 2025 allowing AEMO to accept cash as credit support in the National Electricity Market (NEM) up to a limit of $20 million, which will commence on 1 November 2026.