In August 2026, Queensland Treasury released a public consultation draft Code of Conduct for Renewable Energy Developers (the Code) and draft Industry Guidance on the Code of Conduct (the Industry Guidance), setting expectations for how wind, solar and battery project developers engage with communities, manage impacts and deliver community benefits across the life of a project.[1]
Time is running out to have your say on the draft Code and Industry Guidance with submissions closing at 11:55pm (AEST) on 31 October 2026.
What is the Code?
The Code is made under the Electricity Act 1994 (Qld) (the Act). It creates no standalone obligations but rather assists the Regulator in deciding whether the “social licence criteria” is satisfied when assessing:
- a generation authority application (for grant or transfer) for a wind, solar, battery or hybrid project with a capacity of 30MW or greater; or
- a generation authority holder’s annual report with respect to operations during the previous financial year,
by describing conduct that ordinarily indicates the criteria are satisfied.[2]
It complements, rather than replaces, Social Impact Assessments and Community Benefit Agreements required under the Planning Act 2016 (Qld)[3] and delivers on a commitment in the Queensland Energy Roadmap 2025 to progress a code for renewable energy developers to guide responsible behaviour.[4]
The “social licence criteria”
The Regulator’s assessment centres on the three social licence criteria which are specified in the Act[5]:
- Community and stakeholder engagement – genuine, two-way engagement with the affected community throughout the entire lifecycle of the project; notice alone is insufficient.[6]
- Mitigating or addressing impacts on the affected community – efforts to avoid or mitigate (if avoidance is not feasible) social impacts identified, or otherwise agreeing a monitored impact management plan.[7]
- Delivery of benefits to the affected community – delivering real, ongoing community benefits that align to the project’s size and duration.[8]
Applicants must address these criteria in a new “Social Licence Suitability Report” before lodging an application for, amendment or transfer of, a generation authority.[9] Coexistence Queensland, an independent statutory body, may advise the Regulator on compliance but does not make decisions.[10]
The “affected community” ordinarily includes landholders within the geographical area of the project, local governments covering that area, Indigenous Australians with a connection to Country near the project and any other person or group materially affected by the project.[11]
The Code encourages those who are involved in the development, construction or operation of a generating plant to keep records (e.g. engagement logs, complaints records, impact registers) to support annual reporting and demonstrate ongoing compliance.[12]
Submissions can be made via an online questionnaire or written submission through the Queensland Treasury’s engagement platform and close on 31 October 2026.
The Hamilton Locke team advises across the energy project life cycle – from project development, grid connection, financing, and construction, including the buying and selling of development and operating projects. For more information, please contact Matt Baumgurtel.
[1] Queensland Treasury, ‘Draft Code of Conduct for Renewable Energy Developers’ (consultation page) <https://engagement.treasury.qld.gov.au/code-of-conduct-for-renewable-energy-developers>.
[2] Queensland Treasury, Code of Conduct for Renewable Energy Developers (Qld) (consultation draft, August 2026) 3 (‘Code of Conduct’).
[3] Ibid 3.
[4] Queensland Government, Queensland Energy Roadmap 2025 (August 2025) 11, 53.
[5] Electricity Act 1994 (Qld), s 180(9).
[6] Code of Conduct n 3 [5].
[7] Ibid.
[8] Ibid.
[9] Industry Guidance on the Code of Conduct (Qld) (consultation draft, August 2026) 6 (‘Industry Guidance’).
[10] Code of Conduct n 3 [4]; Industry Guidance n 9 [4].
[11] Code of Conduct n 3 [4].
[12] Code of Conduct n 3 [6]. Industry Guidance n 9 [11].
