1B: Regulating the standardised super-peak hedge contract
Consultation
We are seeking feedback on our proposed approach to regulating the standardised super-peak flexibility product, an electricity hedge contract for morning and evening trading periods (the super-peak product).
The super-peak product provides buyers with protection against high prices during periods of peak demand in the morning and evening. It was co-designed by industry experts as an initiative of the Energy Competition Task Force, to improve competition in the market for shaped hedges. The product has traded on a voluntary basis since January 2025, through a fortnightly brokered event on the over-the-counter (OTC) market.
Introduction of the super-peak product, supported by voluntary trading, has improved the availability and pricing of super-peak hedges on the OTC market. While these improvements are encouraging, the market is not yet sufficiently deep or liquid.
If liquidity does not improve to a sufficient level, the Authority intends to consider regulating super-peak product trading to ensure a reliable supply of contracts at efficient prices.
We have considered two options for regulating super-peak product trading on an enduring basis. These options are:
- market making on the Australian Securities Exchange (ASX)
- market making on the OTC market.
Market making OTC is the Authority’s preferred regulatory option, if required, to improve super-peak hedge contract access and price discovery.
The paper also sets out the Authority’s plan for urgent action if there is a sudden material reduction in the supply of shaped hedges. If urgent action is required, our preferred approach is a temporary obligation on gentailers to offer and sell a minimum volume of hedges OTC to maintain the market while an enduring solution is considered.
We welcome your feedback on these proposals by 5pm, Tuesday 30 September.
Webinar
We will hold a one-hour webinar at 11am, Wednesday 10 September to talk through our issues and options paper and answer questions. Register for the webinar
Make a submission
Our preference is to receive submissions in Microsoft Word in the format shown in Appendix E to taskforce@ea.govt.nz with the subject line ‘Regulating trade in standardised super-peak hedge contracts’ by 5pm, Tuesday 30 September 2025.
If you cannot send your submission electronically, please contact taskforce@ea.govt.nz or call 04 460 8860 to discuss alternative arrangements.
We will publish all submissions. 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 version that we can publish (if we agree not to publish your full submission).
All submissions, including any parts that the Authority does not publish, can be requested under the Official Information Act 1982.