Submission: Feedback on Gas Market Review Implementation

11 March 2026

To: Department of Climate Change, Energy, the Environment and Water
Re: Feedback on Gas Market Review Implementation

Thank you for the opportunity for the Institute for Energy Economics and Financial Analysis (IEEFA) to provide input to the detailed design and implementation of the Gas Market review reforms.

IEEFA is an independent energy finance think tank that examines issues related to energy markets, trends and policies. The Institute’s mission is to accelerate the transition to a diverse, sustainable and profitable energy economy.

As outlined in the submission, IEEFA:

• Supports the implementation of a reservation scheme that applies nationally, provided it imposes domestic supply obligations on LNG exporters from 2027 to address the risks of gas shortfalls. With shortfalls projected to occur as early as 2028 in eastern Australia, and 2029 in Western Australia, the scheme must deliver additive domestic gas supply from exporters to ensure domestic energy security.
  • The reservation scheme should include a mechanism to prevent artificial domestic oversupply by allowing producers to export “excess gas” when domestic markets are oversupplied.
• Agrees that existing LNG contracts should be protected, but this should be limited to firm supply commitments that must be satisfied under existing contracts. Any contracts with extension clauses that require LNG exporter approval should be treated as new LNG supply commitments, and should not be protected under the scheme.
• Recommends approvals be required for all LNG exports to ensure sufficient domestic gas supply and energy security. Detailed criteria for export approvals should be developed to guide exporters on their obligations, and to drive good conduct from exporters. In particular, those criteria should ensure that exporters are not prioritising lower-cost gas for exports while directing higher-cost gas to the domestic market, driving up domestic prices.
• Supports these reforms replacing existing gas market mechanisms. Where this is not feasible, existing mechanisms should be streamlined to reduce regulatory burden and uncertainty. 

Kind regards,

Josh Runciman, Lead Analyst, Australian Gas