In its correspondence, AWBA highlighted the compressed implementation timeframe for the WMDS and the resource burden it will place on water market intermediaries. Members have expressed their view that the costs associated with meeting the draft data standards are substantial, while the benefits—particularly improvements to market transparency—remain unclear and difficult to demonstrate.

The Association acknowledged the complex and detailed work underway between the Bureau of Meteorology (BOM), Irrigation Infrastructure Operators (IIOs), and other stakeholders in developing and refining the WMDS. AWBA noted that harmonising trade forms across states and regions would be a sensible and long-overdue goal, reducing administrative inefficiencies for participants operating across multiple jurisdictions.

However, AWBA emphasised that timely access to accurate trade data remains one of the most pressing issues for water market participants. The proposed standards would require only live-matching electronic exchanges to report real-time data to the BOM. AWBA forecast that this would capture as little as 5–10% of all transactional data, given that many intermediaries do not use live-matching platforms or may choose to disable the functionality to avoid additional regulatory obligations.

The Association also raised concerns about how pricing information will be displayed by BOM. Variations in fees and charges across southern connected valleys may lead to price signals that do not accurately reflect true market conditions, reducing clarity for market participants rather than improving it.

“As it stands, the current exposure draft of the Water Market Data Standards is likely to reduce transparency,” AWBA warned. “If intermediaries are incentivised to remove live-matching functionality, many participants will be forced to return to phone-based trading, consuming valuable time and potentially increasing market volatility.”

On behalf of its members, AWBA has urged the Department of Climate Change, Energy, the Environment and Water (DCCEEW) and the BOM to delay implementation of the WMDS for all water market intermediaries until at least 1 July 2027. This would provide agencies with the time needed to resolve outstanding issues and develop a comprehensive, workable solution that includes all intermediaries.

“Any requirements that cannot demonstrate a clear and obvious improvement to market transparency should be removed,” AWBA stated. “A well-designed, inclusive system will achieve far better outcomes for the industry and for all water market participants.”

AWBA will continue to engage with government and stakeholders to ensure the final framework supports a transparent, efficient, and well-functioning water market.