VEU compliance comes down to one question: can you prove it? The Essential Services Commission (ESC) does not take your word that a heat pump was installed, that the customer agreed, or that the product matched the claim. It wants evidence, in a form that can be checked against the certificates you created. Installers who treat evidence as part of the job rarely have a problem. Those who treat it as paperwork for later usually meet the ESC at the worst moment.
This article sets out what compliance asks of installers and accredited persons, based on the ESC’s published requirements at the time of writing. Rules and guides are updated, so treat the ESC’s current Obligations and Program Guide for Accredited Persons as the final word. If you are not yet accredited, start with how to become a VEU accredited person.
Three layers of compliance
It helps to think of compliance in three layers, because failures usually happen at the boundary between them.
Layer one: the law. Electrical, gas, building and workplace safety rules apply to the work itself. The ESC requires that prescribed activities be undertaken in accordance with the relevant Victorian legislation, so a job that breaches electrical safety law is a VEU problem too.
Layer two: the program rules. These are the VEU-specific requirements: eligible products on the approved lists, correct activity definitions, the right baseline, and the right number of certificates for the activity.
Layer three: the conduct rules. The ESC’s code of conduct covers how you deal with customers. It includes honest selling, no misleading claims, clear consent and fair handling of complaints. The accreditation forms now ask applicants to show they understand and can comply with it.
The evidence file for each job
A good job file holds:
| Item | Purpose |
|---|---|
| Customer consent and details | Shows the customer agreed and the premises are eligible |
| Product details and serials | Proves the product was on the approved list and matches the claim |
| Dated photos | Proves the work happened, where and when |
| Installer licence and details | Proves a suitably qualified person did it |
| Safety and compliance documents | Proves the work met the relevant legislation |
| VEEC calculation | Shows how many certificates were created and why |
| Invoice and payment records | Proves the transaction |
Keep originals. Where the ESC asks for material, you want to produce it in minutes, not days.
Where installers go wrong
From the problems that tend to appear in energy-efficiency schemes generally:
- Wrong product. A model that is similar to an eligible one, but is not on the list
- Missing or unreadable serial numbers. Common when photos are taken from a distance
- Baseline mistakes. Claiming a replacement when the old unit was already inefficient, or vice versa, where the activity rules treat them differently
- Consent gaps. The customer was not given the right information, or the paperwork was signed after the work
- Unqualified labour. A task done by someone without the licence the activity requires
- Double claiming. Creating a VEEC and another certificate for the same benefit where the rules do not allow it. See VEECs and STCs on the same job for the legitimate combinations and the answer on heat pump VEECs in Victoria.
A worked example of audit exposure
Say an accredited person creates 300 VEECs in a month across 25 jobs, and the market price is about $90. That is $27,000 of certificates. An ESC audit samples five jobs and finds that two have a missing serial photo.
If the ESC decides certificates for those two jobs cannot be supported, that is perhaps 24 VEECs, about $2,160, to put right. But the larger cost is the follow-up: the ESC may widen its sample to every job done by that crew, and a buyer may hold back payment on the whole batch. A $2,160 problem becomes a $27,000 cash flow problem, plus time. That is why evidence at the point of work is worth far more than evidence reconstructed later.
From the desk: Do your own mini-audit every month. Pull five random jobs, and check each against the evidence table above as an auditor would. Log what you find and what you fixed. If the ESC ever asks how you manage compliance, a dated record of monthly self-audits is more persuasive than a policy document.
Managing subcontractors and crews
If you use subcontractors, you stay responsible for what the program sees. Put the essentials in your subcontractor agreement: required licences, the photo set, how evidence is handed over, and what happens if a job fails an audit because of their work. Check licences at the start of each engagement and again when they renew. And train crew members on the code of conduct, because conversations at the door are where most conduct issues begin.
Responding to an audit
When the ESC contacts you:
- Acknowledge promptly and note the response deadline
- Pull the full file for each job requested, and check it before sending
- Send a complete, indexed response, not a partial one
- Keep a copy of exactly what you sent
- If you find a problem, say so and explain what you have done about it
An audit is an assessment of your system as much as of a job. A clear, timely response and an honest account of any error will help you far more than a defensive one. The principles are close to those of the CER on the federal side, which we describe in how STC audits work.
Compliance and your buyer
Your certificate buyer is exposed to your evidence. A buyer who pays you for VEECs that are later invalidated may recover the money from you under your contract. Ask about clawback and who bears the cost, as covered in our trader checklist. A buyer that checks your claims before they are lodged is also helping you comply, which is worth something.
Customer-facing conduct
Conduct problems rarely show up in a photo set. They show up in complaints. The ESC expects accredited persons and their installers to be straight about what a customer is getting and what the certificates mean. Avoid claims such as “free” upgrades when a customer is contributing, avoid pressure tactics at the door, and make sure every customer receives the documents the program requires before work starts. Record how complaints are handled, including the date, what was said and what you did. A handful of well-handled complaints is normal. A pattern of ignored ones is what draws attention, and it is the part of compliance that is cheapest to get right and most expensive to get wrong.
What to do next
- Download the ESC’s current Obligations and Program Guide and read the sections on records and conduct
- Build the evidence table above into a checklist for each activity you deliver
- Start a monthly five-job self-audit
- Review how you sell VEECs on the VEEC trading page and check the resources hub for photo and document checklists