STC clawbacks are rarely a surprise to the system and often a shock to the cash flow. The mechanics come down to who holds the certificates when the regulator acts, and what the contract says.
What CER does
When an audit or inspection finds that a claim does not meet the rules, the STCs created for it can be marked invalid in the REC Registry, even after they have been sold. Invalid certificates cannot be surrendered by a liable entity, so the loss lands somewhere in the chain. The Clean Energy Regulator deals with the registered person that created the certificates, which is the registered agent or the installer’s own registered account, not with the buyer of the certificates.
Where the loss lands
| Situation | Who is first exposed |
|---|---|
| You are a registered person and sold certificates yourself | You |
| A trader or agent created the certificates for you | The agent, who then looks to the contract |
| STCs were already sold on | The agent, who must make good the position |
Between you and your trader, the contract decides. Most include a clause allowing the trader to recover the value of invalidated STCs from the installer, through a deduction from future payments or a direct invoice. Read it before you need it; the contract terms checklist lists what to look for.
Revoked years later
Installers often ask how far back this reaches. The honest answer is that there is no point at which a paid claim becomes untouchable. The regulator can audit older claims, particularly where fraud is suspected. Keep job files, photos, signed forms and serial numbers for as long as you can, and certainly for several years. We suggest seven as a working minimum.
Recourse against the trader
If you are the one who has been wronged, for example the trader mishandled a claim, did not lodge on time or paid you less than agreed, your recourse is in the contract and consumer law. A trader who simply passes through a CER outcome that arose from your install is on firm ground. For disputes about the trader’s own conduct, see STC trader owes money.
If your own installation is the problem
If the cause is your work, the loss is yours. If the cause is an administrative mistake by the agent, ask for the facts and the evidence. If the cause is a subcontractor, check your subcontract terms. See who is responsible for a failed STC audit and the general explainer what is an STC clawback.
What this means for installers
- Read the recovery clause before you sign with a trader.
- Keep an audit-ready file on every job.
- Use a trader that pre-checks claims. Our compliance desk does, and it catches problems before lodgement, though no checker removes the risk entirely.
- Do not spend STC proceeds you may have to return without a buffer.
See also the STC trading overview, how it works and how STC audits work.