Evidence and compliance
Frequently Asked Question
How do I comply with the new requirements?
You must operate and create certificates in line with legislative requirements. You collect and retain appropriate evidence. You prepare for and undertake audits and regularly report on your implementations. See our website for some things you need to know for operating successfully as an ACP.
What evidence will we need to keep for the new activities?
Our recent consultation included proposed evidence requirements and examples of records that could be used as evidence. Proposed evidence examples included geo-tagged photos of new equipment, tax invoices, strata /title records and other relevant documents to evidence requirements are met.
We recommend you review the Consultation Paper for more details about proposed evidence requirements for new battery activities. We will consider submissions and finalise evidence requirements and publish an updated PDRS method guide soon.
How do you determine what a small business site is?
““Small Business Site” is defined in clause 10 of the PDRS Rule. You can provide evidence such as an electricity bill that shows annual electricity consumption/usage is under 100 MWh per year (or an equivalent figure, like average daily usage), that allows for annual consumption to be calculated for the business site where the work took place.
Should we use the CEC battery list values, manufacturer data sheets or the 90% assumption when calculating capacity? And how does this apply to equipment and eligibility requirements?
The definition for usable battery capacity in Clause 10 of the PDRS Rule means usable battery capacity is calculated as 90% of the nominal battery capacity listed on the CEC approved battery list.
This definition applies for both equipment requirements and calculating peak demand capacity.
Is a finance agreement sufficient for minimum payment evidence?
Not necessarily. The evidence must demonstrate that the original nominator has made the required payment.
A deposit is generally the simplest form of evidence. Otherwise, repayments may need to be evidenced until the minimum payment threshold is reached.
What are the major compliance issues identified by the NSW Building Commission?
The most common issue is incorrect labelling. Other issues include incorrect backup system arrangements and RCD protection requirements. Labelling continues to be one of the most significant areas of non-compliance identified by regulators across Australia.
Are there any noise requirements for batteries?
The presenters were not aware of any specific noise requirements for batteries. It was noted that unusual or offensive noise could indicate a fault so should be discussed with the installer.
Any issues with the quality of the product or the work performed you should try to resolve with the installer first. If that doesn’t work, then the ACP details are on the nomination form that was signed.
If a battery is installed indoors, will bollards also be required?
It depends on the location. Installers must undertake a risk assessment. If there is a risk of mechanical damage, additional protection such as bollards may be required. Bollards are not mandatory in every indoor installation.
Is there a guideline document showing best-practice battery labelling?
Not currently. The NSW Building Commission is developing training material that will help address this. In the meantime, installers should refer to AS/NZS 5139, which clearly outlines labelling requirements.
Can you clarify battery duration?
Battery duration is not defined in the PDRS Rule. There are set capacity requirements built into the definitions.
Who can install batteries under the new activities?
Batteries installed under activities BESS1, BESS3 and BESS4 must be installed by an installer with Grid-Connected Battery Storage ‘Design and Install’ or ‘Install only’ accreditation by Solar Accreditation Australia (SAA).
ACPs need to provide the installer’s accreditation number with SAA when registering certificates. Battery activities BESS1, BESS3, BESS4 and BESS5 must also be conducted by persons holding the appropriate licences and in compliance with the relevant standards and legislation.
You can check the installer’s SAA accreditation status and trade licence.
How does the requirement for solar PV not less than 25% of battery apply? Does this mean the size of the solar photovoltaic and the size of the battery inverter?
No. It applies to the total rated DC capacity of new solar PV panels, not the battery inverter.
This requirement for BESS3, BESS4 and BESS5 intends that the new solar PV array has sufficient generating capacity to supply at least 25% of the battery’s usable storage capacity. For example, a 100kWh battery system requires a minimum 25 kW solar PV array connected at the site.
The Usable Battery Capacity must also not be more than 6 times the Battery Inverter Output for activities BESS3, BESS4 and BESS5.
Common questions and answers published 7 August 2026