Two different things get called clawback, and it is worth separating them.
The regulator’s side
The Clean Energy Regulator administers the certificate registry and can invalidate STCs that were created in error or on a basis that does not stand up: a product that was not approved, an installer who was not accredited, evidence that does not support the claim or an ineligible system. Invalidated certificates cannot be surrendered, so someone who holds them needs a replacement. The details of the CER’s powers and processes are in its published guidance, and we do not summarise them as legal advice.
The trader’s side
A trader that bought the certificates from you needs valid ones. If an invalidation or a failed audit happens, the contract decides what comes next. Typical options are:
- The installer supplies replacement STCs.
- The installer refunds the value paid.
- The trader deducts the value from later payments.
Some contracts limit recovery to a period after settlement, and some limit it to faults the installer caused. Others are silent, and silence is not a good place to be. Our guide to trader contract terms lists the clauses, and STC clawback covers the general case.
What causes battery clawbacks
- Model not on the CEC list on the installation date, or mismatched model suffix.
- Usable capacity overstated or tiers misapplied.
- The wrong date, which gives the wrong factor.
- Accreditation lapsed or not matching who attended.
- Photos and serials that do not support the claim.
- More than one battery claimed per property.
Because battery claims are large, one error is a large number. On a 28 kWh job at 152 STCs, that is roughly $5,800 to $6,100 at current prices.
What this means for installers
Control it at four points: product check at order, evidence at install, calculation at quote, and contract terms at signing. Keep the job file complete. A trader that checks photos, forms and serials before lodgement, as our compliance desk does, reduces the chance that a claim goes in with a fault, though responsibility for the install remains with the installer. Read our recovery terms before signing with anyone, ours included. See /start-trading/, the rate on /pricing/, the pillar page and the guide to how audits work.
A worked exposure example
Take a 13.5 kWh battery at 91 STCs, valued at about $3,460 to $3,640. If the installation date was wrong and the factor was overstated, certificates beyond the correct number could be invalid. The error may be only a few dozen certificates, but at these values a few dozen is a four-figure sum on a single job, repeated across every job that used the same mistake.