Your Generator Compliance Program is a Tier 1 Obligation. Is it built to prove it?

Under the National Electricity Rules, failing to maintain a compliance program consistent with the AEMC's Compliance Template isn't a paperwork problem — it's a Tier 1 civil penalty provision, the most serious category in the framework. For a corporation, that exposure runs up to $10 million. The fines the AER has levied over the last 5 years act as a reminder that the AER is prepared to use the full reach of that power when performance standards aren't met.

Now the bar is moving. The new draft Template (Compliance Template Review 2026 | AEMC) is broader and noticeably stricter on documentation. Most importantly, it makes explicit something the AER has been signalling for years: reactive record-keeping — producing information only when someone asks for it — no longer meets expectations. The regulator has been clear that ex-post assessments can't be relied on in isolation; they need to sit alongside an ongoing monitoring and testing regime.

We believe this is a healthy shift. As the grid fills with new generation and storage technologies, the gap between a compliance program that exists on paper and one that actually runs every day is the gap between knowing how your plant is performing and hoping it's fine. A document in a folder has never been the same thing as compliance — and the draft Template draws that line more firmly than ever.

What "running a program" actually looks like

A modern compliance program is a living system of record. Every power system event, every compliance assessment, every field test, every deviation and the action taken to resolve it — captured automatically, time-stamped, and retained for the full seven years the Rules require. Not a spreadsheet someone updates when there's a spare afternoon. Not knowledge that walks out the door when an experienced engineer changes jobs.

That's the principle COMET is built on. It digitises your registered GPS and compliance program, automatically detects the power system events that need assessing, evaluates plant response against your registered standards, manages the follow-up workflows, and archives the lot — so your evidence is assembled before anyone asks for it, not scrambled together afterwards.

When the auditor calls, your answer shouldn't be "let me go find that." It should already be on the screen.

Built for where the grid is heading

VeriConneX manages compliance for over 4.5 GW of generation and storage assets through COMET — Australia's purpose-built GPS compliance management platform. As the draft Template firms up, the operators who fare best won't be the ones reacting to it; they'll be the ones already running continuous, audit-ready compliance as business as usual.

We'd welcome the chance to walk you through what that looks like for your portfolio. Explore COMET, or get in touch to start the conversation.