Alberta’s New Electricity Framework and Rules: What Market Participants Need to Know Right Now

Overview

Alberta’s transition to a restructured electricity market (REM) is accelerating with the goal of completing implementation by early 2028. Following approval by regulation of the final ISO REM Rules, the Alberta Electric System Operator (AESO) is entering the implementation phase of the REM framework.

This update highlights:

• AESO ‘s Market Participant Readiness session on March 24, 2025 (register here); and
• Enactment of the Restructured Energy Market ISO Rules Regulation.

AESO REM Implementation and Market Readiness Kick-off Session

On Tuesday, March 24, 2026, the AESO is hosting a webinar with the purpose of sharing the work required to prepare the AESO and Market Participant organizations, systems and people for successful implementation of REM.

This session follows AESO President and CEO, Aaron Engen’s March 17, 2026 remarks at the 2026 IPPSA Conference emphasizing that AESO is in the implementation phase of Alberta’s new electricity framework. The soft launch and early system roll-out will occur in 2027 (early Q3). This will include market participants building their system platforms and integrating with AESO systems. The completion of the full transition to REM is planned for early 2028.

The new core system platforms will enhance reliability, improve price signals and support efficient grid operations. This includes:

• a Market Management System for bids and offers, market clearing, price formation, LMP’s and SCED;
• an Energy Settlement System for financial payments and charges; and
• an Operating Reserve Procurement Platform as a reliability tool.

The current Energy Trading System will be retired.

Ministerial Enactment of the REM ISO Rules

On March 10, 2026, the Minister of Affordability and Utilities, Nathan Neudorf, issued Ministerial Order 035/2026 enacting the Restructured Energy Market ISO Rules Regulation (Regulation) under the Electric Utilities Act (EUA). The Regulation adopts by reference the final REM ISO Rules, recently published by the AESO.

The enactment of the REM ISO Rules through regulation is atypical. Usually, ISO rules are reviewed and approved by the Alberta Utilities Commission (AUC) in the first instance, and then are subject to ongoing AUC oversight through statutory complaint procedures. However, the Regulation specifically exempts the REM ISO Rules from complaint to the AUC, and it is the Minister (as opposed to the AUC) who must review and approve any subsequent changes to them.

The enactment of the REM ISO Rules through the Regulation is an important step forward in the implementation of REM. However, and importantly, most of the individual provisions in the REM ISO Rules are not yet in effect. Section 9(1) of the Regulation expressly contemplates a phased coming into force of the REM ISO Rules. Individual rules will come into force on dates to be fixed by the AESO, with at least 30 days advanced notice being posted on the AESO website.

Because the REM ISO Rules do not become effective immediately upon enactment, it is important to review your material contracts, particularly change of law provisions, notice requirements, and offtake agreements. Contractual triggers—such as those related to changes in law or the need to provide notice—may be activated either at the time the rules are enacted or only when they come into force. As a result, careful consideration of how your contracts define and respond to regulatory changes is essential to ensure compliance and to avoid unintended consequences.

We’re Here to Help

McCarthy Tétrault has a leading multidisciplinary Energy team. We are especially well-equipped to provide clients with a full suite of advice and support to assist them in the implementation of the REM framework and interpretation of the Rules. Please contact the authors or any member of our Energy group to learn more – we would be happy to assist you.