Retailers sit between the customer and the installer. The scheme gives them specific duties, and the Clean Energy Regulator (CER) has been enforcing them.
The written statement
When you sell a solar PV system or a battery, you must complete a written statement for that system. It covers the sale and the system details, and the representative who signs must match the name and role recorded in the claim. Without it the system is not eligible. The step-by-step is in the installer written statement guide.
What makes it risky is the truth requirement. The statement is a declaration. If it says the system was installed, it must have been. If it says the customer received required information, they must have.
Other retailer responsibilities
- Accurate marketing. No misleading claims about government rebates, savings or what the STC discount is.
- Approved products and accredited installers. The retailer must engage accredited people and supply approved equipment.
- Records. Keep the contract, statement, correspondence and evidence.
- Cooperation. Respond to CER requests and audits.
- Licensing. State rules on sales and electrical licences also apply. See solar sales licences.
See also solar retailer requirements.
Penalties for false statements
At the time of writing, the CER’s 2026 compliance updates describe suspensions from the scheme, an action to ban a retailer who falsely declared installations complete, and warnings. Beyond administrative action, the legislation provides for civil penalties and, for serious or deliberate conduct, criminal offences. The amounts and thresholds are set in the Act and regulations, so refer to the CER’s guidance for current figures.
Where this bites installers
Retailers who sign statements early to speed up claims push risk onto the installers and traders downstream. A claim may be failed, or certificates later invalidated, and the person holding the payment may be asked to give it back. See STC clawback and who is responsible.
What this means for installers
If you work for a retailer, ask to see the written statement before you lodge or trade the certificates. If you are the retailer, build the statement into the job checklist, not the paperwork pile at month end.
The STC assignment form and photo requirements sit alongside it. Pillar: STC trading. See also the CER’s 2026 priorities for why completion statements are under the microscope.
Practical retailer controls
A retailer can reduce risk with simple controls: a statement template that cannot be signed until the installation date field is filled, a rule that no claim is lodged without a photo set review, and a monthly sample check of completed jobs against their statements. These take little time and show a regulator that the business takes the duty seriously.