Electricity Authority lodges formal complaint over alleged Code breaches

The Electricity Authority Te Mana Hiko (Authority) has lodged a formal complaint with the Rulings Panel alleging that Contact Energy Limited (Contact) breached the Electricity Industry Participation Code 2010 (Code).

The Code sets out the duties and responsibilities for all participants in New Zealand's electricity industry. The Authority enforces compliance with the Code to support improved industry practice and ensure New Zealand’s electricity system operates reliably, fairly, and in the long‑term interests of consumers.

The complaint alleges that, from 4 March 2022 until on or about 30 September 2025, Contact failed to:

• maintain an up-to-date distributed unmetered load (DUML) database for Christchurch City Council – Orion
• take all practicable steps to ensure submission information was complete and accurate.

The Authority lodged this complaint because:

• Contact was the trader responsible for the Christchurch City Council streetlight DUML database between April 2017 and September 2025
• Contact failed to address DUML accuracy issues identified across several audit reports. The errors resulted in an overcharge to Christchurch City Council and a consequential corruption of the residual profile shape, affecting other industry participants
• The investigator assessed the market impact as high, with an over-submission of 4.94GWh of electricity between March 2022 to September 2025
• Contact accepted that it breached the Code.

The Rulings Panel is an independent body that determines breaches of the Code and may make appropriate remedial orders under section 54 of the Electricity Industry Act 2010.

If the Rulings Panel upholds the complaint, it may make remedial orders against an industry participant. This includes pecuniary penalties, compliance orders, compensation orders, and private or public warnings or reprimands.

Under the Electricity Industry (Enforcement) Regulations 2010, which were in force in March 2022 when the accuracy issues were first identified, the maximum total liability for an asset owner found to be in breach of Part 15 of the Code is $200,000. This includes both pecuniary penalties and compensation orders.

Full details of the complaint are set out in the following investigation notice.