INSIGHT

From intent to action: the long-term role of natural gas in Australia's energy transition

By Jacqui Rowell, George Salter, Ethna Caulfield, Noa Gubbay
Energy Oil & Gas

Strategy, reform and what's next 11 min read

The past year has seen a number of strategic developments, across both regulation and industry, that reinforce the importance of natural gas in Australia's energy transition.

It is now increasingly clear from a policy perspective that natural gas has a long-term role as a transition fuel in the net zero journey, remaining a critical part of the energy mix and central to Australia's energy security through to 2050 and beyond.

In this Insight, we examine the developments that have helped clarify the path ahead and outline the Federal Government's latest proposed changes.

Key takeaways 

  • Natural gas remains critical to Australia's energy security and transition: while Australia's energy mix evolves, natural gas will continue to play a vital role as a transition fuel for domestic consumption and a key export commodity, due to its reliability and the current lack of commercially viable alternatives.
  • Policy shift towards balance: recent Federal Government strategies reflect a more measured approach to natural gas, aiming to meet emissions reduction targets while ensuring energy security, affordability and international competitiveness.
  • Regulatory reforms signal support for certainty: the Government will undertake a comprehensive review of current gas market policies with an aim to streamline regulations, address market imbalances and ensure domestic supply security without compromising Australia's international trade or investment reputation.
  • Stakeholder engagement is crucial: stakeholders are encouraged to participate by responding to the Government's proposed review, and have their say on the proposed changes to Australia's future gas market regulation. Submissions close on 15 August 2025.

The long-term role of natural gas as a transition fuel

Previously, when perspectives were more varied, we considered two possible pathways for natural gas in the energy transition:

  • a rapid transition away from natural gas as a source of fuel; or
  • a continued, longer-term role for natural gas as a transition fuel in the journey to net zero.

Recent shifts in government strategy now reflect a growing recognition that phasing out natural gas too quickly, particularly alongside the closure of coal-fired power stations and before lower-carbon alternatives are commercially viable, would be premature. Such an approach would undermine energy reliability, with flow-on effects for consumers, industry and the broader economy.

In response, the policy focus has shifted toward a more balanced approach: one that meets Australia's emissions reduction targets while also safeguarding energy security, affordability and international competitiveness.

Supporting this direction will require not just continued investment in gas supply and infrastructure, but also a policy and regulatory environment that encourages capital deployment and mitigates unnecessary complexity or risk.

Policy updates supporting the long-term role of gas 

Any future changes to the regulatory framework will need to be carefully managed to ensure the already significant compliance burden on the gas industry does not limit its ability to fulfil its critical role as a transition fuel. Overregulation risks undermining further investment and development of Australia's natural gas resources and, ultimately, supply, at a time when energy security and regulatory certainty is crucial.

Over the past year, several key policy and market updates have reinforced the role of gas in Australia's energy transition:

These developments signal a clear direction from government that natural gas will continue to play a strategic role in Australia's energy mix and transition to net zero.  

  • the Department of Industry, Science and Resources' report, 'Future Gas Strategy', released 9 May 2024 (Future Gas Strategy).
  • the Australian Energy Market Operator's (AEMO) Gas Statement of Opportunities for Australia's East Coast Gas Market, released March 2025 (East Coast GSOO).
  • AEMO's Gas Statement of Opportunities for Western Australia's Gas Market, released December 2024 (WA GSOO).
  • the national Gas Market Review, announced 30 June 2025 by the Department of Industry, Science and Resources (DISR), jointly with the Department of Climate Change, Energy, the Environment and Water (DCCEEW), and the release of the related Consultation Paper calling for stakeholder feedback.

Together, these developments signal a clear direction from government that natural gas will continue to play a strategic role in Australia's energy mix and transition to net zero.

Strategic direction under the Future Gas Strategy

The Future Gas Strategy sets out a national plan for the production and use of gas through to 2050, providing greater policy certainty for long-term decision-making. Its central aim is to support the decarbonisation of the Australian economy while safeguarding domestic energy security and maintaining the nation's reputation as a reliable trade and investment partner.

Underpinned by six guiding principles, the Strategy emphasises:

  • the continued need for reliable and affordable domestic gas supply (Principles 2 and 4); and
  • the importance of ongoing investment in new gas sources to ensure future availability (Principle 3).

The Future Gas Strategy recognises that natural gas will continue to play a critical role through the transition, particularly where alternatives are not yet commercially viable, and confirms that significant investment will be required to support both domestic and export consumption. Demand is expected to remain relatively consistent until at least 2035, largely due to long-term contracts. It is crucial that these long-term arrangements evolve with the regulatory landscape, including the external impact of international regulatory pressures, to avoid being 'left behind' on the path to net zero.

Regulatory reform through the Gas Market Review

Building on the Future Gas Strategy, the Government has announced a comprehensive Gas Market Review (the Review), led jointly by the DISR and the DCCEEW. This federal-level review is focused on assessing the effectiveness of current gas market regulation and identifying options for reform. While the review does not extend to WA's Domestic Gas Policy or explicitly recognise its role, it acknowledges that any new federal reforms will need to co-exist with established state and territory reservation policies.

The Review will examine the operation and effectiveness of several existing mechanisms, including:

  • Australian Domestic Gas Security Mechanism (ADGSM): introduced in 2017, the ADGSM is a government intervention to ensure there are sufficient levels of natural gas to meet the needs of Australian energy users. Although it has never been activated, the Government again decided not to trigger it for the October to December 2025 quarter.
  • Gas Market Code (Code): a mandatory industry code prescribed under Part IVBB of the Competition and Consumer Act 2010 (Cth), to ensure the supply of wholesale gas to the domestic market is carried out at reasonable prices and on reasonable terms.
  • Heads of Agreement with east coast LNG exporters (HoA): last entered into in September 2022, a voluntary mechanism under which LNG exporters agreed to offer uncontracted gas to the market on 'competitive market terms' and 'with reasonable notice' before offering it to the international market.

The scope of the Review will also focus on:

  • Domestic gas supply: evaluating the merits of alternative federal initiatives to improve the security of domestic supply in the medium to long-term. There is a strong focus on proposing reforms to recognise contributions to the domestic market to ensure there is sufficient natural gas supply and exert downward pressure on domestic gas prices.
  • Reasonable gas prices: assessing whether Australia's wholesale and retailer domestic gas prices reflect market fundamentals and comparing regulated 'reasonable pricing provisions' with market-based pricing.
  • Market transparency: striking a balance between information asymmetries between gas producers and buyers over price and supply information against managing reporting and compliance burdens.
  • Market conduct and good faith rules: the consideration of conduct and associated rules to minimise bargaining power imbalances.
  • Competition in both the gas supplier and user markets: considering the findings of the Australian Competition & Consumer Commission's (ACCC) December 2024 Gas Inquiry Report (ACCC Gas Inquiry) and how competition can affect bargaining power, supply and pricing outcomes.
  • Quality and reliability of Australia's international trade reputation: reviewing how these regulatory mechanisms impact the competitiveness of Australia's LNG export industry.
  • Role of market bodies: evaluating the roles of AEMO, the ACCC and the Australian Energy Regulator's (AER) role in governance, information collection, reporting and implementation of the mechanisms.

The Review is likely to shape how Australia's gas market will be regulated in the years to come. It also signals a shift towards greater regulatory scrutiny, with potential implications for compliance obligations, pricing models and investment decisions.

Input from stakeholders to inform future reform

To support the implementation of the Future Gas Strategy, the Government has released a Consultation Paper (the Paper) seeking feedback from industry and other stakeholders on how existing gas market regulations could be improved to ensure a reliable and affordable long-term gas supply.

The consultation process aims to engage a range of stakeholder groups from major gas producers and consumers to those with environmental concerns about gas and its long-term role in Australia's energy transition.

A key question raised by the Review is how increased governance can be introduced without compromising Australia's international trade reputation or deterring future investment. In addition to responding to the proposals outlined in the Paper, stakeholders are encouraged to suggest further reforms.

Submissions close at 5pm on Friday 15 August 2025.

In order to guide the Review, the Paper sets out a series of policy themes, proposed on a sliding scale from 'Minimal change' to 'Incremental change' through to 'Fundamental Reform'.

The key question raised by the proposed reforms is how greater regulatory control will be implemented without damaging Australia's trade reputation. These policy themes are summarised below:

Theme Current observations from government Potential options to change gas market regulatory framework

Supply, security and trade across all instruments

  • WA GSOO projects supply shortages from 2030, with risks emerging as early as 2028 due to industrial restarts and new industrial projects being brought online.
  • East Coast GSOO forecasts a shift in the consumption profile, with reduced residential/commercial use and increased gas-powered generation. Domestic demand is forecast to continue to 2044.  

As the next 5-10 years are critical in terms of gas supply security, the following options are proposed:

  • Minimal change: instil regulatory certainty in the ADGSM by (for example) giving greater weight to exporters' existing supply profile and discourage withdrawal of gas from the domestic market to meet LNG export contracts. Renegotiate the HoA in the short term to retain commitment that gas must first be made available to the domestic market. Consolidate and streamlining regulations by moving the above commitment from the HoA to the Code.
  • Incremental change: include a domestic supply requirement through basic (existing) export licensing arrangements and facilitating stronger inter-operational links between AEMO's advice. Impose quantitative thresholds and conditions for future decisions for exemptions on domestic supply. While these changes are being implemented, it is proposed a short extension of the HoA is renegotiated.
  • Fundamental reform: establish a national framework to ensure sufficient domestic gas supply and incentivise investment certainty.  

Contracting and bargaining under the Code and HoA

  • ACCC's December 2024 Report highlights ongoing bargaining imbalances for commercial and industrial users securing long-term Gas Supply Agreements (GSAs) with producers at reasonable terms and prices.
  • Buyers have also stated concerns around the silent nature of the expression of interest (EOI) processes, where the Code required producers to publish expected EOIs on their website and the amount of uncontracted gas available over a 24-month period, but does not mandate that gas must be offered through EOI processes.  
  • Minimal change: consolidate regulations by transferring the existing HoA EOI obligations to the Code, and explicitly exempt buyer-initiated gas supply EOIs from the Code.
  • Incremental change: require contracted gas to be made available by the Gas Bulletin Board (GBB) or AEMO markets rather than producers' Consolidate and streamline procedural obligations for entering into GSAs under the Code, which could include incorporating requirements or initial and final offer within EOI provisions. Require producers to provide price guidance and feedback on EOI outcomes to all unsuccessful bidders.
  • Fundamental reform: standardise key terms under a GSA template or guidance on drafting of non-price term clauses indicating 'buyer or seller' friendly reference points.  

Gas market transparency

  • Stakeholders report the Code's requirement to publish uncontracted gas and supply EOIs is inflexible, prescriptive and lacks transparency. There is also duplication with these obligations and those that exist under the HoA.  
  • Minimal change: increase the timeliness of gas price reporting to real time (as opposed to each quarter with a 3-6 month data lag once the ACCC Gas Inquiry is published). Update the ACCC Inquiry terms of reference to clarify roles and responsibilities for gas market transparency.
  • Incremental change: establish a role for an Energy Market Body to act as a 'central repository ' for collecting all gas market information to inform reporting requirements for the AER, AEMO and ACCC. Establish the AEMO GBB as a 'one stop shop' for gas market information, short-term and long-term price benchmarks and other relevant metrics to inform contract negotiations. Establish a role for AEMO to actively facilitate and improve gas market transparency.
  • Fundamental reform: promote domestic gas supply and availability through transparency to support a new framework to secure domestic gas supply commitments. 

Wholesale gas prices under the Gas Market Code

  • While recent measures, including price caps and competitive domestic pricing requirements for LNG exporters, have driven down costs from extreme highs observed during market instability, current pricing remains above long-term historical norms. 
  • Minimal change: renegotiation of the HoA to affirm that domestic customers will not pay more for LNG exporters' gas than international customers. Request that the ACCC review the existing $12/GJ reasonable price under the Code.
  • Incremental change: amend the Code's reasonable pricing settings from a static price to a variable price, linked to a relevant index to reflect market flux. Shifting the HoA principle that domestic gas customers will not pay more for LNG exporters' gas than international customers to the Code.
  • Fundamental reform: replace a new framework within the Code to secure domestic gas supply commitments, with a transition period to producers who prefer to retain existing conditional ministerial exemptions under the Code.  

Efficient wholesale markets

  • Australia's wholesale gas market is dominated by bilateral contracts (such as GSAs), with limited 'on-screen' trading via AEMO.  
  • Minimal change: improvements to the way gas is offered to the market, such as structured timing which could be achieved through the Code's EOI, by incorporating these requirements into GSA provisions.
  • Incremental change: establish a 'voluntary market making scheme' which would include obligations on relevant entities to offer specific products, trade at designated times or volumes, or maintain bid-offer spreads within defined limits. Participation incentives would then be integrated into the Code exemption framework. Refinements to AEMO-operated markets, such as expanding their physical scope or creating a virtual hub, could further aggregate trades and improve liquidity. Reduce barriers to participation with reforms to AEMO prudential requirements.
  • Fundamental reform: establish a 'mandatory market making scheme' with the same obligations proposed under the incremental change. Comprehensive changes to AEMO-operated markets or the introduction of new markets or new market functions to pool liquidity within trading zones. Standardise rules and structures (such as registration processes and credit requirements) to increase trade efficiency and reduce participation costs.  

Actions you can take now

  • Assess the potential impact on your organisation: review the reform options proposed in the Consultation Paper and consider how they could affect your operations, investment plans, long-term supply arrangements or exposure to regulatory risk.
  • Review the Consultation Paper in detail: visit DCCEEW's website to review the full Consultation Paper. It outlines the Government's thinking on future gas regulation and the potential pathways being considered, which could have significant implications for the broader energy and industrial landscape.
  • Make a submission: actively participating in the consultation process is critical to ensuring your organisation's interests and concerns are heard. Submissions will help shape the final policy direction and influence how the gas market is regulated in the years to come.

If you have any questions, please reach out to any of the contacts listed below.