Enabling investment and innovation
Open ConsultationOver-the-counter market
The over-the-counter market is a key part of hedge market developments. Hedge markets is an umbrella term for all the markets that industry participants use to manage risks.
Open consultation
Improving visibility of competition in the OTC contract market: consultation on updates to clause 2.16 notice
Submissions due by 1 September 2026
View consultationOverview
Amendments to the hedge disclosure obligations in subpart 5 of Part 13 of the Code take effect on 1 August 2026.
We announced these changes in April in our Code amendment Omnibus #6 – Decision paper. The amendments resolve operational issues identified following the 2024 updates to the hedge disclosure obligations and will improve the clarity and usability of the Code.
The amendments include:
- improving identification of power purchase agreements and firming arrangements
- introducing clearer timeframes and processes for novel contracts
- requiring participants to provide consistent information on demand response arrangements
- making technical and non-controversial amendments.
Timeline
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4 August - 1 September 2026
Consultation —Improving visibility of competition in the OTC contract market: consultation on updates to clause 2.16 noticeView consultation -
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23 March 2026
Decision —Standardised super-peak hedge contract clause 2.16 information notice
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21 November - 19 December 2025
Consultation —Standardised super-peak hedge contract: clause 2.16 information noticeView consultation -
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16 September 2025
Frequently Asked Questions —OTC bids and offers notice- frequently asked questions
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16 September 2025
Decision —Improving the visibility of competition in the OTC contract market
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17 - 31 July 2025
Consultation —Improving visibility of competition in the OTC contract market: additional consultationView consultation -
6 - 28 May 2025
Consultation —Improving visibility of competition in the OTC contract marketView consultation -
6 June 2024
Decision —Decision paper on improving Hedge Disclosure Obligations
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12 December 2023 - 6 February 2024
Consultation —Options to improve hedge disclosure obligationsView consultation -
19 October 2023
Code of conduct —For participants in the over-the-counter market
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11 July to 9 August 2023
Consultation —Improving hedge disclosure obligation requirementsView consultation -
13 December 2022
Correspondence —Outlines the findings of our information gathering exercise and our intended next steps
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31 October 2022
Correspondence —Requests participants to voluntarily provide off-market hedge information
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13 October 2022
Correspondence —Signals our intention to request information on off-market transactions for bilateral electricity hedge contracts
Project background
The over-the-counter (OTC) market is a type of off-market transaction in which multiple participants buy and sell financial contracts whose underlying asset is electricity.
We started work on the over-the-counter market in 2022 in response to restrictions placed on some New Zealand electricity market participants' ability to access the Australian Securities Exchange futures market.
In 2023, we facilitated an industry working group that created a voluntary Code of Conduct for participants in the OTC market. Signatories commit to a number of underlying principles and behaviours when participating in the OTC market.
Our aim is to improve the efficient operation of alternative markets. This will become increasingly important in managing the risks associated with New Zealand's transition to a low-emissions energy system.
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