Why are we reporting on frequent traders?

The Victorian Government committed to publishing a list of frequent traders of water in response to the 2019 and 2020 consultation on water market transparency. Through this consultation, it was clear that the community wanted more transparency in certain aspects of the water market, balanced with an appropriate level of individual and commercial privacy.

Under these same commitments a similar report, the Large Water Owners report, has been published yearly since 2019–20 including the names of companies that hold over 2% of high-reliability entitlements in the Goulburn and Murray systems.

From 1 July 2024, following an amendment to the Water Act 1989, the Minister for Water can now include names of individuals in public reports in specific circumstances.

Who qualifies as a frequent trader of water?

This report defines frequent traders as the owners of individual allocation accounts that have, during a water year, completed more than 20 allocation trades which are:

• approved
• priced (i.e. commercial)
• within, from, or to the Goulburn water system (zones 1A, 1B, and 3) and the Murray water system (zones 6, 6B, and 7).

This report lists the names of individuals and organisations that meet the above criteria.

• Where there are multiple owners of a single allocation account, all owners’ names are listed.
• No attempt is made to add up trading activity undertaken by a party over multiple ABAs.

The names of Frequent Traders in this report are grouped by the source water system of their allocation bank account (ABA).

• ABAs may be listed in any Victorian water system that can trade into the Goulburn or Murray, including the Loddon, Broken, or Campaspe.
• The name of an account holder will appear in the Frequent Trader list against each water system where they hold an ABA that meets the Frequent Trader criteria.
• If an account holder has more than one ABA in a water system that qualifies as a frequent trader account, the account holder’s name will appear in the list for that water system only once.
• For interstate trades into the Goulburn or Murray systems, only transactions within Victorian ABAs are counted for the purposes of this report (for example, a NSW seller trading more than 20 times into Victorian Murray ABAs will not appear in this list).

Key statistics:

This report is based on data as at 31 December 2024.

To date for the 2024–25 water year, there are 26 frequent traders:

• 4 named parties are individuals
• 22 named parties are organisations

  • 1 named party is an environmental water holder
  • 3 named parties are water corporations
  • 5 named parties are intermediaries/water brokers with access to the broker portal
  • 13 named parties are other companies.

Who are the frequent trader of water?

Qualifying to be on this list does not indicate any wrongdoing. Many parties rely on water allocation markets as part of their business model. The list simply provides transparency about account holders who have made more than twenty priced allocation trades in the Goulburn and Murray systems during the water year to date.
We acknowledge that in some cases trusts and intermediaries may hold and trade allocation water in their accounts on behalf of other parties.

In all Goulburn and Murray trading zones, non-frequent traders conduct the majority of commercial trades (about 70% of trades involve no frequent traders) and non-frequent traders are buying and selling the majority of water allocation volume.

An updated Water Market Trends report, planned for publication in the first quarter of 2025, will include additional information about the volume of water traded by frequent traders historically.

Parties that meet the criteria of a frequent trader are listed in table 1.

Table 1: Frequent Traders in 2024-25 as at 31 December 2024

Publishing this information

Part 5A of the Water Act 1989 sets out the purpose of the Victorian Water Register, including to make information about water markets publicly available. This information was published in accordance with section 84EA.