From 1 March 2026 the Clean Energy Regulator (CER) requires accredited installers to take clear, geotagged and timestamped photos of the compliant labelling on every solar battery installation. Claims without usable photos can be delayed or rejected. A 13.5 kWh battery creates roughly 91 STCs at the 2026 factor, worth about $3,450 at $38, so one missing photo is an expensive omission.
This is a working checklist for crews and office staff. It reflects the regulator’s published position as we understand it at the time of writing. The rules have been refined since they started, so check the CER’s solar battery installers page before you rely on any list, including this one.
Why the rules exist
The reasons are safety and integrity. Emergency responders and electricians need to know a battery is on the premises and how to isolate it, so labelling at the meter box, switchboard and battery matters. The CER has also reported using AI-assisted image analysis to find missing labels and metadata problems, which is hard to talk around: a photo either carries a location and a time or it does not.
The regulator has also reported suspending a number of installers after early battery inspections. Whatever the exact count, the direction is clear. Battery evidence is now an audited area. For the audit process in general, see how STC audits work.
The evidence set
The CER describes the evidence as photographs of compliant labelling in several places: the outside of the meter box, the switchboard and its covers, shutdown instructions, and the front and sides of the battery. That sits on top of the usual evidence for a claim. Pulled into a working shot list:
| Where | What the photo must show | Common failure |
|---|---|---|
| Meter box exterior | Emergency battery label (the “ES” label) in place, and a wider shot for context | Label fitted after the crew has left, or photo shows only the label with no context |
| Switchboard | Board with cover on and cover off, labels legible | Dark, tilted or out-of-focus images |
| Shutdown instructions | Isolation and shutdown procedure, readable | Text too small to read at full size |
| Battery front | Whole unit, the rating plate and model | Rating plate hidden behind a cover |
| Battery sides | Side labels and clearances to walls or openings | Skipped because access is tight |
| Serial and capacity | Serial number and usable kWh evidence | Serial photographed before it was legible, or after the cover hid it |
| Connection | Cabling, protective devices, inverter link | Existing inverter missing from a retrofit set |
The labelling photos need to be geotagged and timestamped. Switch location services on in the camera app, and use an app that keeps the metadata when it uploads. Messaging apps often strip it. Photos forwarded from a phone through chat are a classic failure.
Where the evidence goes
Our reading of the CER guidance is that the photos must be taken for every installation and be available to the regulator, and trading partners will want them at lodgement because a claim that arrives with gaps costs time on both sides. Ask your trader how they handle it. At the Energy Merchants compliance desk, battery photo sets are checked before anything is lodged, so a missing label photo is flagged while the crew can still return. The battery submission guide lists the rest of the file.
Retrofits and existing solar
A battery added to an existing solar system is eligible, but the evidence set has to show both the new battery and how it ties into the existing installation. Add photos of the existing inverter, its label and the board. If a hybrid inverter replaces an older unit, separate solar evidence may apply under the small-scale rules, so check the inverter swap against the solar photo checklist.
A pre-departure routine
Put one person in charge of the folder on every job, and have them tick the following before the van leaves:
- Meter box label: close and wide, geotagged, timestamped.
- Switchboard: cover on and off, labels legible.
- Shutdown instructions: readable at full size.
- Battery: front, both sides, rating plate and serial.
- Usable capacity evidence matching the model on the approved list.
- Connection and inverter shots, including the existing inverter on retrofits.
- Metadata check: open one photo and confirm the location and time show.
- Upload from the site, not at the end of the week.
It takes about three minutes. Compare that to a return visit of an hour and a half, or a claim sitting in a queue for two weeks. A good trader will pay within 24 hours once the claim is clean, so the photo set is the only thing between your invoice and your bank account.
What the failures cost
Take 10 jobs a month at an average of 91 STCs and $38 per STC. That is about $34,600 of certificates monthly. If two of the ten jobs have a photo problem that adds 10 working days, you are carrying about $6,900 of work in progress for an extra two weeks. If one fails outright and has to be re-photographed on a revisit, add a labour cost and a customer who is unhappy to see you back. Multiply that across a year and the checklist pays for itself within the first month.
What the regulator is likely to ask for
If the CER selects your jobs for inspection or audit, expect requests for the original images with metadata, the installer’s records of the visit and the product evidence. The written statement and assignment form still need to be in order. For related paperwork, see the assignment form resource and what the CER needs for batteries in 2026. Rejections and what to do about them are covered in top STC claim rejection reasons.
Photos for audits you do not know are coming
The CER can look at a battery installation long after the claim is paid, and the evidence has to be there when it does. Store each job’s photos in a folder named by address and install date, in the original files with metadata, not in compressed copies from a chat app. Keep them with the assignment form, the invoice and the compliance documents so that one person can assemble the file in an hour.
Train every crew member on the same routine, including subcontractors. If a subcontractor installs the battery, the file still has to meet the standard, and the cost of a failure usually returns to the installer who certified the work. Add the photo checks to your quality sign-off, and review five jobs a month for legibility and metadata. For solar jobs, the matching set is in the solar photo requirements answer, and the question of who benefits from battery certificates is covered in who gets battery STCs.
Finally, remember that the label photos are about safety first. A neat set of images helps the next electrician or firefighter who arrives at the property, and that is the reason the rule exists.
What to do next
- Print the shot list above for every crew vehicle and tape it to the dash.
- Test your camera app and upload route for metadata on a trial job.
- Name one person per job to own the folder.
- Read the battery STCs page for the program overview and the tier structure.
- If you want a desk that checks the set before lodgement, see how it works and start trading.