Three questions that decide whether 'no carve-outs' means anything to you

The federal government says there are 'no carve-outs' for data centres in its renewables plan. That’s two words doing a lot of work. Here’s what they actually leave open:

1. Time-matching scope — Does 'powered by renewables' mean every half-hour, rolling 12 months, or calendar year? Additionality depends on the answer. If it’s dispatch-matching, you need on-site or contracted firm power. If it’s annual, you can buy RECs and move on. Call the CER/Safeguard team and ask which mechanism applies to data centres specifically — not the press release, the instrument.

2. Who enforces — Is this AEMO grid code, CER/Safeguard definition, or state planning condition? Different body = different timeline, different penalty. State planning usually moves slower than market rules. That matters for your 90-day window. Ring the relevant regulator’s compliance unit.

3. Bundled vs unbundled — A bundled PPA (on-site build or contracted generation + matching obligation) shifts the bill onto the operator. Unbundled RECs + grid supply shifts it onto you and your regulator relationship.

The bodge: Buy RECs, call it renewable, hope the definition doesn’t tighten. Bill arrives when: The regulator clarifies time-matching rules and your current setup doesn’t meet them. You rebuy power at prevailing rates (usually worse than your original contract), or you eat the reputational cost of backtracking.

Proper: Get legal counsel + energy procurement in a room with the regulator’s guidance before you move. Two weeks, maybe three. Gets you certainty instead of a 18-month hangover.

I don’t have the actual policy text, so I can’t tell you which of these three applies to your situation. That part is on you. What I’ve done is given you the questions that separate a real answer from theatre, and named the bill on the shortcut.