Energy rating disclosure at sale and lease: what's coming

For a solo assessor, mandatory disclosure is an interesting policy story. For Viv running across multiple state schemes, or Nate managing an enterprise network, it's a capacity-planning question — because if it lands, it doesn't land gradually. Here's exactly where disclosure policy actually stands today, and what the direction of travel means for demand and coverage.

Where mandatory disclosure actually exists today

Right now, there is exactly one jurisdiction with real mandatory disclosure: the ACT. Its Energy Efficiency Rating (EER) scheme has operated since March 1999 — the longest-running scheme of its kind in the country. Under the Civil Law (Sale of Residential Property) Act 2003 (ACT), sellers must provide an EER, prepared by a licensed building assessor, and it must appear in all advertising material for the property, not just the contract. The EER uses its own scale — 0–6 for existing dwellings, 0–10 for new dwellings — which is a genuinely different scheme to the national NatHERS-based Home Energy Rating certificate covered elsewhere on this site, worth keeping straight if you operate across both.

Everywhere else in Australia, disclosure at sale or lease is voluntary. That's the entire landscape today: one long-running mandatory scheme, and voluntary practice everywhere else.

The national policy sitting behind it

The reason "voluntary today" doesn't mean "voluntary indefinitely" is the Home Energy Ratings Disclosure Framework, developed nationally through the energy ministers' process. Version 1 was released in July 2024, covering single dwellings; Version 2 extended it to apartments and apartment buildings. The Framework itself doesn't mandate anything — it sets out the policy parameters and market-readiness guidance a jurisdiction would use if it chose to implement disclosure, rather than forcing any state or territory's hand.

What makes this more than a paper exercise: the accompanying cost-benefit analysis found a considerable net benefit to implementing mandatory disclosure at point of sale or lease. The economic case has already been made publicly — what's pending is which jurisdictions act on it, and when.

NSW is the jurisdiction actually moving

NSW ran a live trial through the second half of 2025, in partnership with the Australian Government, working with a select group of real estate agencies to test how NatHERS-style ratings fit into an actual sale, purchase and lease process — including what training agents need and what information buyers and tenants actually find useful. From mid-2026, NSW moves into a voluntary disclosure phase that incorporates what the trial found. Mandatory disclosure is flagged as the eventual goal once the voluntary phase has been reviewed and the market judged ready — but there's no confirmed mandatory start date yet. Watch this specific trial closely: it's the most advanced signal of how and when any jurisdiction actually flips the switch.

What mandatory disclosure would mean for demand and capacity

This is where the ACT's 25-plus years of running history is genuinely instructive, and why this matters differently for an enterprise operation than for a single practitioner. Under voluntary disclosure, assessment demand is discretionary — a homeowner choosing to get a rating out of curiosity or ahead of a planned upgrade. Under mandatory disclosure, every residential sale (and, depending on scope, every lease) in that jurisdiction needs a rating attached before it can be marketed. That's a structural shift from optional to universal demand, and it typically doesn't ramp in gradually — it arrives as a step-change on whatever date a mandate takes effect, the same way it did in the ACT in 1999.

For a network spanning multiple assessors or multiple jurisdictions, that means capacity planning now matters more than it would for demand that grows steadily: enough accredited assessors, in the right locations, ready before a mandate lands rather than scrambling after it does. Geographic coverage becomes the binding constraint, not marketing — you can't service a sudden state-wide requirement with assessors clustered in one metro area.

Our take

Nothing here is imminent — the Framework sets terms, it doesn't compel action, and NSW's own timeline explicitly defers a mandatory decision until after the voluntary phase is reviewed. But the direction of travel is unambiguous: a national policy framework exists, the cost-benefit case for mandating disclosure has already been published, and one state is actively piloting the transition. For an enterprise operation, the smart move is building geographic and headcount capacity ahead of a mandate, not after one is announced.

Frequently asked questions

Is energy rating disclosure mandatory anywhere in Australia right now?

Yes — only in the ACT, under its Energy Efficiency Rating scheme running since March 1999, via the Civil Law (Sale of Residential Property) Act 2003 (ACT). Source: Renew.

What is the Home Energy Ratings Disclosure Framework?

A national policy framework developed through the energy ministers' process, setting the parameters for how a jurisdiction would implement energy rating disclosure if it chose to — Version 1 (single dwellings) released July 2024, Version 2 extending it to apartments. Source: energy.gov.au.

Does the Framework make disclosure mandatory?

No — it sets policy parameters and guidance for jurisdictions that choose to implement disclosure; a cost-benefit analysis found a considerable net benefit to mandating it, but adoption remains a jurisdiction-by-jurisdiction decision. Source: Renew.

What is NSW actually doing on disclosure?

NSW ran a live trial with select real estate agencies through the second half of 2025, moving into a voluntary disclosure phase from mid-2026 that incorporates the trial's findings, with mandatory disclosure flagged as a future step once that phase is reviewed. Source: SolarQuotes.

Is the ACT's EER the same scheme as the national NatHERS Home Energy Rating certificate?

No — they're separate schemes with different scales; the ACT's EER runs 0–6 for existing dwellings and 0–10 for new dwellings, distinct from the national NatHERS existing-homes certificate's star-rating-and-score format. Source: Renew.

Talk to us about network coverage

If you're planning assessor capacity ahead of where disclosure policy is heading, MyCool Home routes homeowner demand to accredited partners across the network today — and that infrastructure is exactly what scales if disclosure requirements expand. Talk to us about coverage in your region.