Submissions - 2025

Date Title & Summary Topic Area Sent to
28-Feb-2025

NEM Settings Review Initial Consultation

AFMA's submission highlighted that the review should look to restore the decisive role of the market in NEM investment and that sucessfully managing the retirement of coal units is critical to allowing the energy market to navigate the energy transition. 

Regulation NEM Settings Review Panel
21-Feb-2025

Positioning Australia’s financial reporting system for the future

AFMA's submssion did not support the proposalson the basis that they have not been adequately developed with the aid of industry consultation and are not acceptable in their current form.

Regulation Treasury
20-Feb-2025

Pre-hedging Consultation Questions Responses

AFMA provided responses to IOSCO's consultation questions. While AFMA was in agreement on some elements, AFMA made a series of drafting recommendations, fundamentally not agreeing with the definition of pre-hedging.

Regulation IOSCO
07-Feb-2025

Review into Small and Medium-sized Banks

AFMA’s submission highlighted challenges and opportunities regarding the evolution of Australia as a financial services centre and both the role and importance of foreign banks in Australia. 

Regulation CFR and ACCC
07-Feb-2025

Victorian Industrial Renewable Gas Guarantee

AFMA's submission supported the proposed market-based certificate scheme and that the costs of the scheme should be borne by all users. 

Regulation DEECA
31-Jan-2025

PEMM Act Review

AFMA's submission set out that the concerns the PEMM Act was intended to address are better dealt with by other regulation and that the provisions have been ineffective and should be repealed. AFMA recommended that theACCC’s Electricity Pricing Inquiry should conclude as scheduled in 2025.

Regulation Department of Climate Change, Energy, the Environment and Water
31-Jan-2025

AFMA 2025/26 Pre-Budget Submission

AFMA's submission highlighted that foreign banks are a crucial element of the Australian economy that need to be more appropriately considered in policy formation. In addition, the submission noted that Australia’s financial centre competitiveness has been in continuous decline since the Royal Commission/pandemic and AFMA belives Australia should prioritise initiatives to boost Australia’s attractiveness as a place to do business. 

Regulation Treasury
16-Jan-2025

Setting new targets for the Victorian Energy Upgrades program

AFMA's submission stated that there is currently inadequate VEEC supply to meet demand and that targets should be aligned with realistic expectations of the volume of VEECs expected to be created. 

Regulation Victorian Department of Energy, Environment, and Climate Action
16-Jan-2025

Enhanced beneficial ownership disclosure for listed entities

AFMA's submission stated that the changes that are proposed are too complex in their implications and that the proposed amendments to the current regime extend beyond FATF recommendations relating to beneficial ownership and beyond listed company disclosure requirements in other jurisdictions.

Regulation Treasury
09-Jan-2025

Scam Prevention Framework Bill 2024

AFMA submitted that the ADIs that should be subject to the Mandatory Code are only those that are authorised by APRA to provide services to retail customers, as opposed to all ADIs. The Impact Statement that accompanies the Explanatory Memorandum should not undermine the Minister’s authority to designate regulated sectors/services by assuming that foreign bank branches are within regulatory scope.  

Regulation Senate Standing Committees on Economics