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STC compliance, audits, clawbacks and fraud

Who is responsible for STC compliance: installer, subcontractor or retailer?

Short answer

The accredited installer is responsible for the installation and their declaration, the retailer for the sale and the retailer written statement, and the claimant for the certificates created. A subcontract does not move the installer's own accountability.

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

Responsibility under the Small-scale Renewable Energy Scheme is split across several people, and each carries their own part. The contract between them decides who pays for a failure. The law decides who is accountable.

Who owns what

Party Accountable for
Accredited installer (including subcontractors) The installation meeting the standards, being on site as required, and the installer declaration
Solar retailer The sale, accurate statements to the customer, and the retailer written statement for each system
Owner or their registered agent (the claimant) The accuracy of the certificate creation and the evidence supporting it
Trader Their own checks and what they accept, plus the terms of purchase

Subcontracting

When a retailer engages a subcontract installer, the retailer still holds the customer relationship and the sale. The subcontractor still holds the installer accreditation and the installer declaration. If the job was not done as declared, both can be pursued, and the regulator tends to look at the whole chain. See subcontractor rates for how the commercial side is usually set up.

Practical points when you subcontract:

  • Check accreditation numbers before the job, not after. See checking an accreditation number.
  • Agree in writing who supplies photos and by when.
  • Do not allow a person who was not on site to be named as the installer.

False claims

An installer who signs off work they did not carry out or supervise, or who supplies photos that were not taken at the job, can be liable for a false or misleading declaration. Consequences range from loss of accreditation to enforcement action, depending on the facts. Read installer attendance requirements.

Who pays when a claim fails

Separate from liability is money. If STCs are invalidated after payment, the trader may recover from the seller under the contract. See STC clawback and who is responsible for a failed STC audit.

From the desk: The sentence "my boss told me to sign" will not help you in front of a regulator. The signature carries your accreditation.

What this means for installers

If you work as a subcontractor, keep your own evidence copies of every job. If you are a retailer, only engage installers whose records you have checked. In both cases, choose a trader whose terms are clear about recourse, using the choosing a certificate trader checklist.

For how retailers fit in, read retailer responsibilities and written statements. Pillar: STC trading. Our compliance pre-check reviews every claim before lodgement.

A short checklist for subcontract arrangements

Before the first job, confirm accreditation, insurance and the right to work on the system type. In the agreement, state who supplies photos, who signs declarations, who is paid on a failed claim and who rectifies defects. After each job, collect the evidence copies and keep them. When these four items are written down, most disagreements never reach a regulator.

Follow-up questions

People also ask

Can an installer be liable for false STC claims?
Yes. Making false or misleading statements, or signing off work you did not do, can lead to loss of accreditation and penalties under the legislation.
Does subcontracting transfer my accreditation duties?
No. If your accreditation number is on the job, you answer for it, whoever pays you.

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