Most solar businesses use subcontractors at some point, for peak installs, remote areas or a specific trade. The question here is narrower than “can I use subbies?” It is about the evidence. If a subcontractor shoots the photos, does the claim still stand up?
The short version
Yes, provided the evidence shows what it is meant to show. The Regulator cares about three things: the work was done properly, it was done or directly supervised by an accredited installer, and the evidence is genuine. It does not care whose phone captured the images.
Where subcontracting goes wrong
- The accredited person was not on site. The subbie did the job under someone else’s number. Photos with the subbie’s timestamps and no sign of the accredited installer undercut the attendance claim.
- Photos from a different job. A subbie reuses photos, or uploads a set from last week’s site.
- Metadata gaps. Location off, images sent through a messaging app, files edited. See geotag and metadata rules.
- No standard. One subbie shoots 15 images, another 60, and half have unreadable labels.
Making it work
- Put it in the contract. The photo checklist, original files only, location on, delivery within 24 hours of completion.
- Name the accredited installer for each job and confirm that person is on site. The Regulator’s attendance rules do not bend for subcontractors; see attendance requirements.
- Use a shared app or folder where the subbie uploads straight to your job record, not by message.
- Review before you pay. Check photos against the photo checklist before releasing payment.
- Hold the statement yourself. The accredited installer signs the written statement.
From the desk: pay on a clean photo set, not on a finished roof. It is the one lever that changes subcontractor behaviour, and it costs you nothing.
Remote and fast-moving jobs
Subcontracted work often runs in remote areas or in tight blocks, where one crew does several roofs in a day. That is exactly when photo sets blur together. Ask for a job-number card or whiteboard in the first frame of each site, so the sequence is obvious, and for the site address to be confirmed by location data. A set that starts at the right address and ends at the right address, with plausible times between, is hard to challenge.
Who carries the risk
If a claim fails or an audit finds a problem, it is the registered agent or the business that created the certificates, and the accredited installer, who answer to the Regulator, not the subcontractor. See who is responsible for a failed STC audit. The commercial side of subcontracting, including rates, is in subcontractor rates.
What this means for installers
Treat subcontractor evidence like your own staff’s, only audited more closely. Keep copies of the original files and the subcontract with the job record. A trader’s compliance desk can review photo sets before lodgement, which is useful when the work was done by people you do not see every day. See how it works, STC trading and the audit guide.