Level playing field proposed Code amendments
Consultation
Following our first Level playing field consultation, we are seeking feedback on proposed Code changes necessary to introduce mandatory non-discrimination obligations.
The proposed amendments to the Code would impose principles-based non-discrimination obligations that the four large gentailers – Genesis, Contact, Meridian and Mercury – would have to follow.
This would prevent the gentailers from giving preferential treatment to their retail arms for hedge contracts. Instead, they would have to make these contracts available to all industry participants on effectively the same terms as they use when trading internally. This would ‘level the playing field’ so independent retailers and generators can better compete with the gentailers.
The non-discrimination obligations form part of a package of pro-competition interventions to boost competition, build confidence in the electricity market, and ultimately give New Zealanders better access to affordable electricity.
Note, in response to requests for additional time, we have extended the closing date for submissions by one week to 5pm, Tuesday 2 December 2025.
Q & A
We received questions from some stakeholders about this consultation.
Workshop
We are inviting industry to register for an in-person workshop in Wellington on 9 December 2025. The workshop will focus on guidance for undertaking retail price consistency assessments. To attend please RSVP by 5pm, Friday 28 November to levelplayingfield@ea.govt.nz
Webinar
We hosted a webinar on Friday 17 October to answer questions about the Level playing field measures consultation paper and the Code amendments we are proposing. You can watch it below and view the presentation slides.
Make a submission
Our preference is to receive submissions in the format shown in Appendix C. Submissions should be emailed to levelplayingfield@ea.govt.nz by 5pm, Tuesday 2 December.
If you cannot send your submission electronically, please contact us at levelplayingfield@ea.govt.nz or 04 460 8860 to discuss alternative arrangements. We intend to publish all submissions we receive. If you consider that we should not publish any part of your submission, please:
- indicate which part should not be published and explain why, and
- provide a public version of your submission that the Authority can publish (if we agree not to publish your full submission).
All feedback, including any parts that the Authority does not proactively publish, can be requested under the Official Information Act 1982.