What the regulator says fails a claim
On its page about creating STCs, the regulator says it audits certificates before it registers them. It may fail them if:
- the information provided is incorrect, invalid or duplicated
- the documents are incomplete
- the system is not eligible, is not classed as complete, or does not meet Solar Accreditation Australia's designer and installer guidelines.
Its other pages add detail on the evidence:
- Installer photos. It may fail a claim if the evidence does not show the installer on site for setup, mid-installation and testing and commissioning. Photos must carry date, time and location data that match the paperwork, and it says you may not go back after the install to take them.
- Battery labelling photos. It says missing critical labelling photos will delay or reject a battery claim.
- Mid-scale systems. It may reject an application that lacks evidence the accredited installer attended on the testing and commissioning date.
- The 12-month limit. Certificates must be created within 12 months of the installation date.
To be plain: the regulator does not publish a list of the form mistakes it sees most. What it publishes are the grounds above, the documents a claim needs, and its compliance priorities for 2026-27. Those include true written statements from installers and retailers, and agents checking all compliance documents before they submit a claim.
What we check in practice
This list is ours, not the regulator's. We built it from the grounds above and from what the regulator tells agents and retailers to check. The assignment form guide goes through the form itself.
- The agent named on the assignment form is the agent the job is going to, and its legal name matches its REC Registry account.
- The owner, or a person entitled to act for the owner, has signed and dated the form, with a witness.
- The address, install date and serial numbers are the same on the form, the electrical safety certificate and the photos.
- The panel and inverter models are on the Clean Energy Council's approved list and were installed before their listed expiry.
- No one has claimed for the same system, and for a battery, no earlier battery claim exists at the premises.
What happens after a failure
| Question | What the regulator says |
|---|---|
| Are the certificates valid? | No. A certificate is not valid until it is registered, and a failed claim is not registered. Agents must subscribe to failure notices to receive them. |
| Can the agent try again? | Sometimes, if the notice allows it, the errors are fixed, the system is eligible and the install is less than 12 months old. The agent must correct every detail in the failure reason. |
| What if the agent does not re-create? | It must tell the retailer and the owner in writing, with its reason and the failure reason. The owner can then assign the right to a new agent, who must be told the failure reason in writing. |
| Can the regulator ask for more? | If documents are incomplete, it says it may fail the claim, issue a warning, ask for certificates to be surrendered, suspend the participant, review fit and proper status, or bring civil or criminal charges. |
| Who recovers the money? | No one at the regulator. It says it pays no money to owners or agents, does not get involved in disputes between them, and cannot recover bad debts. If an agent goes into administration, it points you to the administrators. |
Registration does not settle it: the Act says to disregard it when deciding if a person was entitled to create a certificate.
Who carries the risk
The contract decides. The regulator tells retailers and installers who engage an agent to set three things before the job: who bears the risk if the certificates are not approved, clear payment terms including price and timing, and a fair way to resolve disputes. It says that once you assign the right to create STCs, your recourse for payment is through your contract with the agent, and it is not a party to that contract.
Contracts can split the risk in different ways. A trader may pay only once a claim is approved, or pay earlier and have the right to take money back if it fails. Ask which one you are signing. What to check in any trader covers the rest.
Using a trader does not remove the risk. A contract can move who pays. It cannot make the regulator approve a claim, and the statements in it are still yours. Our position on failed claims is set out in our written trading terms, which you get before your first job.
How long the regulator can look back
Approval is not the end. The regulator says it can ask for the documents behind a claim for up to 5 years from the date the certificates were created, and you must provide them even if the claim was approved. Registered agents must keep evidence for every STC they create for at least 5 years, and retailers must keep their required records for at least 5 years.
The Act adds that the regulator may at any time, before or after registration, ask the person who created a certificate for a written statement about it. We found no other stated limit, so keep your records for at least 5 years.
Penalties for false statements
The statements on a claim are legal statements. The sample form's written statements carry a warning that penalties apply for false or misleading information.
- Improper creation. Section 24 of the Act makes it an offence to create a certificate you are not entitled to create. Each certificate can carry its own penalty. Section 24A adds a civil penalty for the same conduct.
- False information. Section 24B is a civil penalty for giving another person information that is false or misleading in a material way, where they rely on it and create certificates they were not entitled to create.
- Retailers. The regulator may declare a retailer ineligible to make written statements after 3 or more false or misleading statements in a 3-year period. The systems it sells then cannot earn STCs.
- Installers and agents. It says it can remove installers and retailers who make false statements, and suspend registered agents who are not fit and proper.
It acts on this. On 10 September 2026 it reported that an installer had been convicted and fined $10,000 for false statutory declarations that he attended installs on site. A registered agent relied on them to create STCs. It also said that since July 2025 it has suspended and removed 5 registered persons and 2 accredited installers.
Checklist before you submit
The regulator's own list for before you create STCs, with the points above added:
- The system is eligible, and you are the owner or hold the right to create the certificates.
- You have the right REC Registry account type, and the legal name on the assignment form matches it.
- Nobody has already created certificates for the system. For a battery, no earlier claim exists at the premises.
- Every document is complete and signed by the people it needs: installer, designer, retailer and owner where required.
- The deeming period and the STC count are right for the zone, date and size.
- The photos show serial numbers on the product, the installer on site, and critical labelling for batteries, with date and location data that match the paperwork.
- The claim goes in within 12 months of the install.
- The contract with your agent says who bears the risk and how you are paid.
How panel validation and photos reduce delays
The regulator says validation usually takes 4 to 6 weeks and takes longer if documents are incomplete or incorrect, or if it finds a compliance issue. It also says uploading the required documents when you submit helps reduce processing time.
Solar Panel Validation is one way to supply some of that evidence. An app scans panel serial numbers on site and produces a signed data package for the agent. The regulator says it can process those claims faster, but not if it finds other compliance risks. It does not list validation among the documents required to create STCs. Solar Panel Validation, in full.
Complete photos help in the same way: clear, geotagged and timestamped photos that match the paperwork answer questions the regulator would otherwise ask.
Sources
Checked on 5 November 2026. Rules and market prices change. General information only, not tax, legal or financial advice: check your own position with your accountant.
- Create STCs: documents, audit and fees (Clean Energy Regulator, updated 2 November 2026)
- Solar PV and solar battery retailers (Clean Energy Regulator, updated 29 October 2026)
- Solar installers and designers (Clean Energy Regulator, updated 30 October 2026)
- Commercial protections for installers and retailers (Clean Energy Regulator, updated 12 November 2024)
- Registered agents (Clean Energy Regulator, updated 29 October 2026)
- Sample STC assignment form and compulsory written statements, version 2.0 (Clean Energy Regulator, 14 February 2024)
- Renewable Energy (Electricity) Act 2000, sections 24 to 24B and 26 (compilation No. 34, 1 January 2026)
- Solar installer convicted over false statutory declarations (Clean Energy Regulator, 10 September 2026)
- Compliance and enforcement priorities 2026-27 (Clean Energy Regulator, updated 26 October 2026)
- Solar Panel Validation initiative (Clean Energy Regulator, updated 30 October 2026)