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Registered agent responsibilities, expected capabilities and standards of practice

05 May 2021

As a registered agent, you must comply with legal obligations under the Small-scale Renewable Energy Scheme, including:

In addition to legal obligations, registered agents are expected to have certain capabilities that make them fit and proper to participate in the scheme.

Fit and proper person (FPP) assessments are a key control to protect the integrity of the schemes administered by the Clean Energy Regulator. They include an assessment of whether the relevant person (or its officers) have the necessary skills, capability and competency, business practices and good character that would reasonably be expected of a participant in our schemes.

For registered agents in the Small-scale Renewable Energy Scheme, the below information clarifies what capabilities and practices we consider essential to remain ‘fit’ to participate in the scheme. We may request information from prospective and existing participants regarding these capabilities and practices. Registered agents create a large volume of small-scale technology certificates and their suitability to participate in the scheme is of particular interest to the agency.

Expected capabilities and standards of practice for registered agents

Documented procedures and records

Registered agents must have:

  1. Documented procedures to prevent the improper creation of small-scale technology certificates (STCs) which include steps to actively verify that:
    • the stated solar photovoltaic panels are valid and relevant system components are on the Clean Energy Council’s (CEC) approved products list
    • systems are only installed by accredited installers and in accordance with current CEC install and supervise guidelines for accredited installers
    • the installation meets Australian standards
    • the installation occurred at the listed address
    • duplicate claims are never made for panels or system components, or for the same address.
  2. A record keeping system to collect, secure and store (for at least five years) documents that assure the credibility of, and support each creation of STCs.
  3. A documented procedure to report to the Clean Energy Regulator, within 72 hours, any improper STC creation
  4. The ability to provide these procedures and records, on request, to us.

Best practice standards

Registered agents are also expected to apply best practice standards to protect themselves and their customers, including through:

  1. Maintaining up-to-date knowledge and ensuring business practices meet their responsibilities under relevant legislation, including (but not limited to):
    • Renewable Energy (Electricity) Act 2000, and associated regulations
    • guidance and policies of the Clean Energy Regulator, including email alerts and updates
    • taxation law and GST treatment of STCs
    • Australian Securities & Investments Commission requirements around Australian Financial Services licenses and business practices
    • Australian and state and territory consumer protection laws relevant to your business.
  2. Providing​ customers and installers with clear information about the scheme, particularly the eligibility requirements for the creation of certificates, and guiding them through the process of assigning the right to create certificates.
  3. Identifying their business risk and exposure to third party fraud and applying due diligence in checking the background and capabilities of business partners, contractors and clients.
  4. Maintaining a training and monitoring system that ensures all staff follow procedures to ensure proper creation of STCs.

SRES Smart

Before becoming a registered agent, all new applicants must complete SRES Smart, an online program with a series of modules, knowledge checks and a self-assessment tool to show they understand the expected capabilities and standards of practice necessary to participate in the scheme. Existing registered agents are also encouraged to complete SRES Smart to check and lower risks to their business of accidental non-compliance and being targeted by third parties conducting fraudulent activities.

Existing registered agents who do not complete SRES Smart will be examined more closely under the agency’s compliance processes. Applications to create STCs may be subject to increased assessment checks which may delay application processing times.

New or existing users under a registered agent account requesting new STC creation permissions must complete SRES Smart. Existing users with STC creation permissions can continue to do so. However, if those permissions are deactivated, SRES Smart will need to be completed before they can be reactivated.

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