Mid-scale solar STCs: eligibility, evidence and contract risk

From 1 October 2026, eligible mid-scale solar installations can qualify for small-scale technology certificates (STCs) under the Small-scale Renewable Energy Scheme (SRES). The Renewable Energy (Electricity) Amendment (Mid-scale Solar) Regulations 2026 expand eligibility, but the benefit depends on the installation’s relationship with other generation, its commissioning date and the evidence supporting the claim.

Eligibility has commenced, but applications have not opened. As at 2 October 2026, the Clean Energy Regulator (CER) expects applications to open in mid to late November. That is an expected opening window, not a guaranteed registration or payment date. Project budgets and contracts need to allow for that distinction.

The capacity test includes related generation

The new definition requires installation on or after 1 October 2026 and an aggregate rating greater than 100 kW and no more than 1,000 kW at installation. That aggregate includes the new device, related solar PV devices and related accredited power stations. The new device does not itself need to exceed 100 kW. The Regulations give an example of a new 60 kW device alongside a related 30 kW device and 700 kW accredited station: the combined rating is 790 kW.

Related-device rules examine electrical connections and commercial metering, with an alternative test involving at least three of four factors concerning location, export purpose, connection infrastructure and ground mounting. The separate related-power-station test concerns an accredited station that listed solar as an eligible energy source in its accreditation application and is on the same or adjoining sites in the same area. Separate metering does not remove that station from the capacity test. Check the actual electrical configuration before assuming a separate meter or contract establishes separate eligibility.

An extension can qualify even where the added capacity is below 100 kW, but STCs apply only to eligible new capacity. Existing capacity counts towards the relevant threshold without receiving a fresh entitlement. Project teams should establish the site’s installation and certificate history before pricing an expansion.

Commissioning determines the installation date

CER’s transitional guidance treats installation as the point when the system is first capable of producing and delivering electricity, evidenced by the testing and commissioning date on the electrical compliance certificate or equivalent. Procurement or construction may have started earlier. Delivery of equipment or execution of the installation contract does not establish the relevant date. The commissioning records must support the installation date claimed.

Five-year deeming does not fix the dollar benefit

Eligible mid-scale installations receive a fixed five-year deeming period for installations through to 2030. This differs from ordinary small-scale solar, whose deeming period reduces each year. It is a single upfront entitlement based on deemed generation, not five annual applications. STCs must be created within 12 months of installation; the expected November opening should not be treated as restarting that period.

The certificate count depends on eligible capacity, the location’s solar zone rating and the deeming period, with fractions rounded down. For illustration, CER’s mid-scale calculator estimates 1,727 STCs for a new 250 kW installation in postcode 2000: 250 × 1.382 × 5, rounded down. The calculator is a guide, not an eligibility determination.

The dollar benefit then depends on how certificates are sold or assigned. Open-market prices vary. The STC clearing house price is $40 excluding GST, but there is no guaranteed sale timeframe. A quoted installation discount may also reflect agent fees and commercial terms. Owners should compare the net benefit and payment conditions, rather than treating an estimated certificate count as a guaranteed cash rebate.

Prepare the evidence before installation

Mid-scale installations retain accredited installer, approved equipment and electrical safety requirements. The installer statement remains necessary. These exemptions do not dispense with design quality, planning requirements or network approval.

The person entitled to create STCs must give CER written evidence that applicable Commonwealth, state, territory and local planning and approval requirements have been met. The installer must hold that evidence and give the required statement. Project records should connect the approved design and any network approval to the particular installation being claimed. Approval evidence must not be materially false or misleading, including through omission.

CER’s specific mid-scale guidance requires photographs showing the accredited installer’s attendance at final installation and commissioning, including their face, installed equipment and testing evidence, with geotagging and timestamps. Where commissioning spans several days, photographs should be taken on the final day. Evidence recreated after completion may not be accepted.

Existing LRET assets and environmental attributes

Existing accredited Large-scale Renewable Energy Target (LRET) stations remain in that scheme; the amendment does not automatically migrate them into the SRES. A qualifying new installation may sit alongside an existing station, but the related-capacity test still applies. Separate metering is required where the existing station continues creating large-scale generation certificates (LGCs). The same generation capacity cannot support both STCs and LGCs.

CER also states that choosing STCs prevents creation of Renewable Electricity Guarantee of Origin (REGO) certificates during the deeming period. Creating a GO certificate first can also prevent a later STC claim under section 23A(1AA). Owners should check certificate ownership and any promises concerning environmental attributes in power purchase agreements before assigning STC rights.

Allocate the commercial risk expressly

An owner’s assignment of the right to create STCs must be in writing, and the creator must be registered. Installation and funding contracts should identify the assumed certificate count, who receives or assigns the entitlement, and who bears any reduction or rejection. They should also address registration delays, certificate price changes and responsibility for obtaining approvals and commissioning evidence. Commissioning, application, registration and payment are different events. If payment depends on “STC approval”, define that event and the consequences of delay.

This article is not intended to be legal advice. In all instances, please ensure that you consult a lawyer for advice specific to your circumstances, including potential eligibility.

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