Heat pump STCs are created from evidence, and evidence can be reviewed after the money has moved. Installers hear three words around this: audit, clawback and fraud. They are related but not the same.
Audits
The Clean Energy Regulator (CER) can review claims after certificates are created. Reviews look at whether the model was on the register on the install date, whether the installation was by a suitably licensed person, whether the assignment is genuine and whether the evidence matches the claim. Our how STC audits work guide describes the process in general, and CER audit of a solar installer shows what a request looks like in practice. The CER’s current compliance priorities are set out on its website.
Clawbacks
If certificates are found to be invalid, they can be cancelled or have to be replaced. In practice, the trader that bought them may ask the installer to make good, depending on the contract. The wording matters. Clauses on invalid certificates, set-off against future payments and who carries the cost differ between traders. See who is responsible for a failed STC audit and STC clawback.
Fraud
Fraud is different from error. It means knowingly making false claims, such as:
- Claiming for a system that was never installed
- Forging an owner’s signature on the assignment form
- Using photos from another job
- Entering a serial that does not match the unit
- Calling a new installation a replacement to raise the count
Penalties can include fines, loss of registration and prosecution. See STC fraud and penalties for the parallel on batteries.
From the desk: the cheapest protection is a consistent evidence folder per job: signed form, compliance certificate, photos, serial and invoice. When a request arrives two years later, you will be able to answer in an hour.
How to reduce your exposure
- Check the model on the register on the install date.
- Never backfill forms or photos.
- Match serials between photo, invoice and claim.
- Record the installation type honestly, with old-unit evidence.
- Keep records for at least as long as the regulator requires. Check the current period.
- Use a trader that reviews claims before lodgement.
- Read the contract’s invalid-certificate clause.
What this means for installers
You cannot remove audit risk, but you can make it boring. A clean pack is a short audit. A compliance desk that pre-checks claims, as ours does, cannot promise a claim will never be questioned, but it catches the common mistakes before they cost you. See how it works, pricing, top rejection reasons and the hot water STC pillar.
If you receive a request
Do not ignore it, and do not alter records. Respond within the stated time, supply what you hold, and tell your trader early. If something is missing, say so plainly. Explaining a gap honestly goes better than a late or inconsistent answer.