Submissions - 2026

Date Title & Summary Topic Area Sent to
13-Mar-2026

Gas market review implementation

AFMA's submission urged a considered implementation of the Gas Martket Review's recommendations and suggested improvements to the governments  approach to consultation.

Regulation DCCEEW/DISR
12-Mar-2026

Sustainable Investment Product Labelling regime- policy design

AFMA's submission raised concern that the paper and current design lacks appropriate scoping and that there is material risk of unintended capture. AFMA recommended that further consultation was required. 

Regulation Treasury
10-Mar-2026

AML/CTF Transitional Rule

AFMA's submission made seven recommendations to the proposed transitional rules. These included recommendations on how the rules are applied, clarity that all travel rule obligations are deferred, and for the rules to  allow for different business lines within the same  reporting entity to transition from ACIP to ICDD when operationally ready as opposed to simultaneously across the reporting entity.

Regulation Department of Home Affairs
06-Mar-2026

AEMO governance review

AFMA's submission supports the continued indeendance of AEMO in its market operation function, but sees merit in greater oversight of its budget and the separation of ASL from AEMO.

Regulation DCCEEW
20-Feb-2026

Consultation on Updates to the AML/CTF Rules

AFMA's submission supported the  proposed changes to Rule 2 1(1) and noted that proposed changes to Rule 2-1(2)(c) are consistent with AFMA's request. While supportive of the theme of the proposed changes to the customer due diligence rules, AFMA recommended tighter language in the drafting of the proposed Rules. 

Regulation AUSTRAC
20-Feb-2026

Energy Security Safeguard: Rule Change Paper

AFMA supports proposals that incentivise stacking as well as the intent to introduce or re-introduce methodologies and activities. AFMA further supports proposals to incentivise C&I and multi-dwelling residential batteries. 

Regulation NSW DCCEEW
20-Feb-2026

Energy Security Safeguard: Policy Reform Paper

AFMA broadly supports proposals to make changes to targets to reduce the ESC surplus to stimulate an increase in scheme activity but maintains that safeguarding  supply through the approval of new methodologies should be a high priority . AFMA also supports the proposed changes to existing and new PDRS activities.  

Regulation NSW DCCEEW
16-Feb-2026

Select Committee on Productivity in Australia

AFMA's submission outlined Australia’s competitiveness, benchmarking against comparable jurisdictions and highlighted the cumulative detreimental impacts of regulatory and tax burden.  The submission noted recent important publications and made 12 key recommendations. 

Regulation Select Committee on Productivity in Australia
16-Feb-2026

Firm Energy Reliability Mechanism: Market Liquidity Obligation

AFMA's submission, although ultimately supportive of  DEM’s decision to align with the national reforms, made a number of technical recommendations.  AFMA maintains that SA specific settings are not required. AFMA's key recommendations are  to adopt a wider spread specification and that the prompt quarter should be excluded.

Regulation South Australia Department for Energy and Mining
16-Feb-2026

SOFIA Draft Methodology and Conventions Consultation

AFMA's submission  was generally supportive of the proposed methodology and conventions. The submission raised some technical questions to deepen AFMA's understanding of proposals and to see if there are refinements that may be possible before go live.

Regulation ASX
13-Feb-2026

Extension of AEMO’s East Coast Gas System Reliability and Supply Adequacy Functions

AFMA supported the Government's intention to better coordinate gas market intervention powers but cautioned that the framework should be designed to minimise its impact on the market.

Regulation DCCEEW
30-Jan-2026

2026/27 Pre- Budget submission

AFMA's submision made sixteen clear and actionable proposals that would  generate genuine boosts in the productivity  and economic growth in the wholesale financial services sector. 

Regulation Treasury
30-Jan-2026

GHG Protocol Consultations- Scope 2

AFMA's submission  highlighted that Australian specific considerations are required and should be aligned with domestic policy and that the proposed deliverability market boundaries for Australia are inappropriate. AFMA recommended that the  SSS guidance should be clarified to explicitly not capture government owned enterprises, ensuring continued competitive neutrality. 

Regulation Greenhouse Gas Protocol
30-Jan-2026

Targeted Amendments to CPS 230 Operational Risk Management

AFMA's submission outlined how APRA can further reduce the burden on industry and service providers, without undermining entity or system resilience, by incorporating additional amendments. 

Regulation Australian Prudential Regulation Authority
30-Jan-2026

Prohibited Energy Market Misconduct – Consultation Paper

AFMA supported  DCCEEW’s proposals to streamline regulatory governance arrangements but noted the proposed cross-market misconduct provisions confuse the AER and ASIC’s responsibilities and risk penalising beneficial market activity.

Regulation DCCEEW
29-Jan-2026

2026 Reliability Standard and Settings Review – Draft Report

AFMA's submission supported the Panel’s decision to retain the current approach to market settings and recommended that APC be indexed to ensure it remains commercially appropriate. 

Regulation Reliability Panel
21-Jan-2026

Treasury Laws Amendment (Genetic Testing Protections in Life Insurance and Other Measures) Bill 2025- Schedule 2

AFMA's submission recommended this Bill’s efficient  passage, without amendment.

Regulation Senate Standing Committees on Economics
05-Jan-2026

Scams Prevention Framework – Draft Law Package and Position Paper

AFMA's submission was broadly supportive of the approach taken in the position paper and made two recommendations to give effect to the policy position of excluding wholesale banking.

Regulation Treasury