On 5 August 2026, the Australian Energy Regulator (AER) issued the Compliance Bulletin clarifying its expectations for the use of automated bidding and third-party bidding service providers in the National Electricity Market (NEM). Market Participants are expected to maintain appropriate oversight and control over automated bidding processes and implement suitable risk management measures. Importantly, the AER reminds third-party bidding providers that they may face accessorial liability if their services contribute to a Market Participant’s breach of the National Electricity Law. Contemporaneous Records for Automated RebidsThe Compliance Bulletin also gives guidance on record-keeping for automated rebids. If you use optimisation platforms, bidding aggregators or third-party market services, the key takeaways are as follows: