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STC compliance, audits, clawbacks and fraud

What are a registered agent's obligations, audits and suspension risks?

Short answer

A registered agent creates STCs for system owners and must meet the fit and proper person test, hold valid authority, keep records and cooperate with Clean Energy Regulator audits. Breaches can lead to suspension, as with the former Greenbot platform.

Written and checked by the Energy Merchants desk · Reviewed 3 October 2026 · For installers

A registered agent is a person or business registered with the Clean Energy Regulator (CER) to create and manage STCs on behalf of the owners of small generation units. If you assign your STCs to a trader, that trader or its platform usually acts as your agent.

What agents owe

  • Valid authority. The owner’s signed assignment form or other proof that the agent may act. See the STC assignment form guide.
  • Accurate creation. Details, serials and evidence in the claim must match the installation.
  • Record keeping. Retain documents for the period the scheme requires.
  • Cooperation. Respond to CER requests for information during audits and validation.
  • Fit and proper conduct. The CER can consider the agent’s compliance history and that of the people running it.
  • Honest dealing with owners. Pass on value as agreed, handle disputes properly.

Fit and proper person

The test applies to registered persons and those with control over them. It looks at matters such as past breaches, fraud or dishonesty, insolvency and whether the business is likely to comply. The CER reported suspending 21 companies from the scheme in the April to June 2026 quarter for failing it. See CER compliance priorities.

Agent audits

The CER can audit registered agents’ processes and the claims they create. It looks at whether authority was held, whether the evidence supports each claim and whether the agent’s own checks are working. Findings can lead to rectification, conditions, suspension or cancellation of registration.

What suspension looks like

When an agent is suspended, it cannot create certificates through its registration. Customers’ pending claims can stall. Greenbot was permanently suspended as a registered agent in 2024, and its clients moved mainly to other platforms. Read what happened for householders in the Greenbot collapse and customer STCs.

From the desk: Ask any agent whether it is registered, who controls it and how long it has been trading. A published, checkable answer is a basic trust test.

What this means for installers

Your choice of agent is a choice of regulatory exposure. If the agent fails, your cash flow suffers even if you did everything right. Look for a long trading history, clear terms and a compliance check before lodgement. The checking a certificate trader checklist lists the questions.

Energy Merchants is backed by REC Traders, trading since 2004. See how it works, or read the pillar page on STC trading. To weigh self-registering against using an agent, read is it worth self-registering.

Questions to put to your agent

Ask how long the business has been registered, who controls it, whether it has been audited and how it handles a suspended or failed claim. Ask what happens to your pending certificates if it stops trading. A confident agent answers each of these directly. Hesitation is information, and it costs nothing to ask before you assign a single job.

Follow-up questions

People also ask

What is the fit and proper person test?
The Clean Energy Regulator assesses whether a registered person and those who control it are suitable, looking at things like compliance history, honesty and financial standing.
What happens to my STCs if my agent is suspended?
Certificates already registered remain in the registry, but pending claims may stall. Contact the agent and the Clean Energy Regulator, and arrange a new agent for future claims.

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