Federal STC claims are audited by the Clean Energy Regulator (CER). NSW ESCs and PRCs sit under the NSW scheme and its regulator, and an audit looks different. The exact audit schedule, sample sizes and evidence rules are set in the ESS Rule and in the scheme’s compliance guidance and are updated from time to time, so use the NSW Energy Sustainability Schemes site as the authority. What follows is how the process works in practice.
Who is audited
The Accredited Certificate Provider (ACP) is the party with obligations under the scheme. It must be able to show that each certificate it created was for an eligible activity, done as required. The regulator reviews ACPs and can sample the certificates behind them. That sample reaches your jobs, which is why an ACP will chase you for documents long after the install.
What auditors look for
- Activity eligibility: the job fits the activity definition, including baseline and customer type.
- Product eligibility: the exact model is on the required list or meets the standard on the install date.
- Installation evidence: dated photos of the old equipment, the new equipment and the label, plus serials.
- Customer consent: a signed form, with the correct parties and dates.
- Licences and accreditation: the installer was licensed and, where required, trained at the time.
- Consistency: dates, addresses and quantities match across the invoice, the photos and the registry entry.
The outcome of a failed audit
If evidence does not support a certificate, it can be cancelled, and the ACP loses the value. Under most ACP agreements that loss is passed back to the installer. A pattern of failures can also affect the ACP’s accreditation. That is why established providers run their own pre-checks and why you should know the cost of a reversal before signing.
Keeping a clean file
- Use a single job folder with the contract, consent, invoice, photos and product data.
- Take photos at the time, with a consistent set for every job.
- Check dates and addresses against each document.
- Keep records for the full period required by the Rule and the ACP’s agreement; ask the ACP for the number of years.
- Respond to ACP evidence requests fast.
How it compares with STC audits
The principle is the same as in how STC audits work: the evidence decides, and the person closest to the job holds the proof. The STC pillar is STC trading, and the photo standard in STC photo requirements is a useful model for NSW jobs too, although the NSW activity may specify its own.
What this means for installers
Treat audit readiness as part of the job, not an after-sales task. Ask your ACP for its evidence checklist per activity, and ask how it handles a failed audit. See NSW ACP fees and payment timing for the contract points.
For how the NSW certificates compare with STCs and VEECs, see STC vs VEEC vs ESC. The wider list of certificate topics is on topics.