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Decarbonisation: The Missing Middle for Commercial & Industrial

Written by Huon Hoogesteger | Nov 3, 2026, 6:03:50 AM

For every 100 systems that Smart Commercial Energy has installed over 100kW, we've installed x16 100kW systems. Not because these customers actually need only 100kW. But it's that the incentives made going larger and uninteresting, basically.

 

Why is this important? Because 70% of Australia's electricity is consumed in businesses, and that is what we call the missing middle. Smart Commercial Energy has been the market leader in this sector for the last 15 years, and we've specialised in building solar power systems and batteries for the missing middle.

 

What is "the missing middle"?

The missing middle is the farm. It's the local manufacturer. It's the warehouse. It's the shopping centre. It's the aged care facility. It's the area, basically, that government has ignored. The area where electrical rules are complex. The type of project that we have to do for that client is more complex. It requires heavier engineering.

The incentives have traditionally been very low, and decision making is much more pragmatic than in domestic but has more risk. We're talking about much bigger values, where someone loses their job if they make the wrong decision.

Households and small businesses, on the other hand, have had incentive after incentive, from RECs in 2007 through to STCs to the Cheaper Home Batteries Program. And at utility-scale projects have had LGCs and tax benefits.

I think I've been through about 13, maybe 15, changes in rebates over my renewable life so far. And after 20 years of doing, it gets pretty tiresome, as we call it in the industry, the solar coaster.

But nothing highlights the missing middle better than flying into Melbourne yesterday, looking out the window and seeing untapped roof space. Australia has 22GW of solar on houses and 5.6GW on businesses. The roofs that run our economy are the ones we forgot. And we've talked about solar farms, but really, the real big missing middle is that 70% of Australia's energy production is not being made on those rooftops.

The missing middle was a phrase, actually, I would like to say that Lauren and I coined at some point in time, maybe last year. And it's nice to hear that Chris Bowen actually picked up the language. And just recently, just today, I believe the Liberal Party in Victoria has started to use the phrases that we've been using and starting to say that the best opportunity for a renewable future in Australia is the commercial rooftop.

 

What's the size of the prize?

We should be filling all the commercial rooftops before taking up precious farmland. Urban, commercial and industrial rooftops could alone, by many different estimates, get to about 40GW or more. Some estimates are up to about 80GW, 85.6GW, once rural and regional and agricultural buildings are taken in and included.

Now, Australia's daytime peak this year was 35GW, occurred around early February. That means that all of Australia's energy could be produced at that moment by rooftop solar. Now, to put that in context, untapped commercial and industrial solar represents the generational capacity of ten of Australia's biggest coal fired power stations.

Solar car parks are huge, too. We've been installing a lot. These car parks are awesome. Not only are they beautiful and elegant and provide amenity, but they also have a return on investment unlike a normal car shade structure.

France now requires its large car parks to be at least half covered: article 40 of the APER law requires operators of outdoor car parks over 1,500 m² to cover half their surface with solar canopies, and a recent amendment lets owners use shade trees, solar canopies, or a mix of both.

That's a pretty progressive policy. If we could inspire our car park owners to do similar things, they would not only get a great return on investment but provide something way more comfortable to use. One of our favourite food shopping centres also attributes a 2% increase to their annual revenue due to having shades over their car spaces. So that's quite a quite a big lever to pull.

 

It's not the cost

How is it possible that solar and battery systems keep getting cheaper and cleverer, yet the market has flatlined?

C&I installations have run at about 600 MW a year, far behind the roughly 2,500 MW a year in residential. The Smart Energy Council's Unlocking the Missing Middle report finds that the primary causes are policy and regulatory rather than technological. Its findings line up with five barriers:

  1. Capital: 67.9% of respondents cite capital constraints, and customers compare solar against alternative uses of capital, such as production line upgrades, where solar frequently loses.
  2. Capability: complexity of technology is the second-biggest barrier to customer decision-making, at 44.6%. Owners assume they'll need to hire an energy expert to manage it.
  3. Confidence: only 21.4% of respondents describe themselves as very confident in the business case, with nearly one-third uncertain or lacking confidence. Many owners also carry baggage from their residential solar experience that has to be unlearned. Our own data shows the cost of that hesitation: Smart Commercial Energy systems up to 100kW take a median of about three months to sign, while systems over 100kW take around six.
  4. Connection: 71% of survey respondents cited the length of DNSP approval times as a leading connection challenge, and in one case an original connection estimate of $250,000 reached $1.6 million. Smart has its own example: a project quoted around $380K and nine months for connection, which then fell over. There is some progress. The new AS/NZS 4777.1:2024 standard removes the network protection requirement for systems under 200kW, down from the old 30 kVA trigger. That's a saving of about $15,000 on a 200kW system, although DNSPs often have a higher level of requirements than the standard.
  5. Landlords: 45% of respondents report that split incentives between tenants and landlords often or almost always create barriers to investment. In one cold storage dispute, legal costs exceeded $12,000 before any panel was installed. Very little has been done to bring commercial landlords on side, in contrast to the engagement poured into utility scale.

When the grid can't deliver

For some businesses this isn't about emissions or savings; it's about whether they can operate at all.

Agright's Meriki chicken farm near Goolgowi is the proof. The grid connection was going to take a couple of years; a solar and battery system could be built quicker. The order was placed in late June 2023, and by March 2024 the farm was running on solar and battery power. It has now run for two and a half years on 3.98 MW of tracking solar and 4.4MWh of battery storage.

In WA, a simple 100 kW system approval took Smart Commercial Energy two years.

We have just released our Smart Plan, a 28 cent PPA covering 100% of a site's energy for 20 years with no grid connection needed.

 

What the STC reform unlocks

The reform is now law. SRES eligibility for solar PV has expanded from 100kW to 1MW for systems installed from 1 October 2026, and systems between 100kW and 1MW get a fixed 5-year deeming period.

It could cut the upfront cost of commercial solar by around 20%, and the government also intends to work with regulators to improve network approval processes.

It fixes a real distortion. Customers need 200 to 400kW systems but install 100kW systems to access STCs, because LGCs at $3 to $4/MWh aren't worth the administrative burden. Smart’s data shows exactly that: nearly one in four commercial solar systems installed since 2021 were sized at 95 to 100 kW, and for every system just above 100kW, Smart installed x16 100kW sized systems*.

The momentum is already there.

Commercial battery attachment rates have tripled, but that is still too small. The share of Smart's commercial solar projects that include a battery has more than tripled, from 3.5% between 2021 and 2024 to 11.7% since 2025.

Half of Smart’s commercial projects since 2021 have been for existing customers, which shows that once businesses try it, they come back.

 

What’s next?

If you own a roof, come and see us.

Our data says a business takes twice as long to say yes once a system goes over 100 kilowatts. That’s the problem worth solving. If you’re sitting on a decision, come and talk to us. We’d like to make it three months, not six.

 

Originally delivered at All Energy 2026 as part of the 'Decarbonisation: The Missing Middle for Commercial & Industrial '  panel.

 

*Based on 613 commercial solar projects installed by Smart Commercial Energy between January 2021 and October 2026.