On 11 December 2025, the Queensland Government announced the making of the Planning (Battery Storage Facilities) and Other Legislation Amendment Regulation 2025 (Amendment Regulation), delivering much-needed clarity on how stand-alone battery storage facilities will be assessed and approved in the wake of Queensland’s recent planning reforms for both wind and solar renewable energy projects.
From today, all “material change of use for battery storage facilities (other than small-scale facilities)” will be required to undertake impact assessment and public consultation as part of the development approval process, and any approvals issued may be the subject of third-party merits appeals to the Planning & Environment Court.
In this alert, we unpack the key elements of the new reforms and what they mean for industry moving forward.
How we got here?
The Amendment Regulation is the final step in the Crisafulli Government’s commitment to deliver on its 2024 election promise to ensure that renewable energy projects in Queensland are impact assessable, with approval processes consistent with those applying to other major land uses such as mining and agriculture, and to guarantee that local governments and host communities are thoroughly consulted.
To implement this agenda, the Crisafulli Government has:
- revised the Draft Renewables Regulatory Framework in December 2024;
- introduced legislative amendments in January 2025 to move all wind farms in Queensland to be assessed by the State Assessment Referral Agency (SARA) and subject to impact assessment (see our previous alert here);
- enacted further legislative amendments in May 2025 requiring all solar farms in Queensland to be assessed by SARA, and making all solar farms over 1 MW subject to impact assessment. These reforms also introduced mandatory Social Impact Assessments (SIA) and Community Benefit Agreements (CBA) for all wind farms and for solar farms over 1 MW (see our previous alert here); and
- released the Queensland Energy Roadmap 2025 in October 2025, outlining a 5-year plan to deliver affordable, reliable and sustainable energy in Queensland (see our previous alert here).
What has changed?
Up until 12 December 2025, all stand-alone battery storage facility projects in Queensland were assessed by each relevant local government under that local government’s planning scheme.
This decentralised approach meant projects were assessed under individual planning schemes (many of which were not designed for large-scale battery projects). Consequently, battery storage facilities could be classified as either ‘code assessable’ or ‘impact assessable’ depending on the local government area, leading to inconsistent and varied approval processes across the State.
The Amendment Regulation itself is short and simple, aligning with recent reforms for solar and wind projects that industry is already navigating. Its key changes will substantially reshape the approval pathway for battery storage facility developments in Queensland.
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CHANGE
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OVERVIEW
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State to oversee “battery storage facility” development assessment |
Responsibility for assessing all ‘assessable’ battery storage facility development applications will shift from local governments to SARA, which already oversees assessments for wind and solar farms. This change is supported by the introduction of State Code 27: Battery Storage Facilities under the State Development Assessment Provisions (SDAP), providing consistent statewide assessment benchmarks. |
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Mandatory SIA and CBA for a “battery storage facility (50 MW or more)” |
Proponents of a battery storage facility (50MW or more) must now prepare a SIA and establish a legally binding CBA with the relevant local government or stakeholder, before lodging the relevant development application. Several local governments (including North Burnett Regional Council, Western Downs Regional Council, Isaac Regional Council, and Gladstone Regional Council) have already published CBA policies for wind and solar projects. It remains to be seen whether these policies will be updated to reflect the new battery storage facility assessment requirements. |
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Impact assessment and public consultation for all “battery storage facility” development (excluding development for a “small-scale battery storage facility”) |
Following the earlier reforms that made all wind and solar farms impact assessable (from 3 February 2025 and 1 May 2025 respectively), all “battery energy storage facility” development (other than “small-scale battery storage facilities”) will now require impact assessment (which is rigorous, lengthy and subject to third party appeal rights). The Amendment Regulation amends the Planning Regulation 2017 (Qld) to classify development for a “small-scale battery storage facility” as accepted development. A “small-scale battery storage facility” includes:
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Transitional provisions and retrospective application of SIA and CBA requirements |
The new SIA and CBA obligations will apply retrospectively to all battery storage facilities (50MW or more) currently under assessment as of today, 12 December 2025. This follows transitional arrangements recently applied to wind and solar farm reforms. Any pre-existing application (including any ‘other’ change applications) meeting the 50 MW threshold that does not include a compliant SIA and CBA will be treated as ‘not properly made’, and the assessment process will be paused until the required documents are provided. Pre-existing applications below the 50 MW threshold will not require an SIA or CBA and will proceed unchanged, continuing to be assessed by local governments in accordance with their planning schemes. In limited cases, the chief executive under the Planning Act 2016 (Qld) may determine that an SIA and CBA are not required if social impacts are unlikely. As assessment manager, SARA may also impose additional conditions on approvals to mitigate social impacts where no CBA exists or where impacts have changed since the SIA was prepared. Appeal rights for these conditions are limited to the applicant only, not third parties. |
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Changes to assessment of battery storage facilities in Priority Development Areas (PDAs) |
The Amendment Regulation makes a material change of use for a ‘battery storage facility’ within a PDA ‘accepted development’, meaning no approval would be required (i.e. it may now be easier to carry out a battery storage facility project if located within a PDA). |
What these changes mean?
Much of the new process will be familiar to industry, which has spent the past ~8 months working through similar reforms introduced for wind and solar projects, including the shift to impact assessment and the introduction of SIA and CBA requirements.
The extension of impact assessment to battery storage facility projects will have significant implications for industry, local government and host communities.
- For communities and local governments: The reforms provide a stronger voice in determining where and how battery storage facilities are developed. CBAs offer opportunities for local benefits, while the enhanced assessment framework strengthens protections relating to safety, environmental impacts, amenity and land use.
- For developers and investors: While the reforms offer greater clarity and consistency, the introduction of mandatory SIAs, CBAs and State-led assessment adds further steps and complexity before applications can be lodged. This is likely to increase upfront costs, lengthen project timelines and require more intensive engagement with host communities and local governments.
What happens next?
The new framework takes effect as of today, 12 December 2025, with commencement of the Amendment Regulation. We anticipate the Queensland Government will shortly release a suite of factsheets and guidelines to support the reforms.
Renewable energy proponents should now:
- review the new State Code 27 (SDAP) requirements to ensure applications can meet these new standards prior to submission (which may involve undertaking additional assessment and consultation than has already occurred or was planned to occur); and
- factor social impact obligations and community benefit negotiations into project timelines, and plan for the potential delays associated with mandatory SIAs, CBAs and third-party appeal rights.
If you would like further advice or assistance in responding to these reforms, please get in touch.
