If you’re generating leads in Victoria’s energy upgrade space – whether it’s heat pumps, air conditioning, solar, or hot water systems – the Victorian Energy Upgrades (VEU) program is your bread and butter. But let’s be honest: compliance can feel like navigating a bureaucratic maze blindfolded.
The good news? VEU compliance doesn’t have to be painful. Once you understand the rules, staying on the right side of the Essential Services Commission (ESC) is actually pretty straightforward. This guide breaks down everything you need to know in plain English – no legal jargon, no fluff.
What Is the VEU Program? (The 30-Second Version)
The VEU program helps Victorian households and businesses upgrade to energy-efficient appliances by offering substantial discounts. When an accredited provider installs an eligible product, they create Victorian Energy Efficiency Certificates (VEECs), which they sell to energy retailers who have mandatory reduction targets.
The numbers tell the story:
- Over 2.4 million Victorian households have benefitted since 2009¹
- The program will save 37 million tonnes of greenhouse gas emissions between 2022 and 2027²
- That’s equivalent to taking more than 11 million cars off the road for a year²
- The program has been extended to the year 2045³
2026 targets: The program is targeting 4.4 million VEECs in 2026, with around 6 million VEECs expected to be created to maintain a healthy certificate surplus.⁴
If you’re generating leads for products like heat pump hot water systems, reverse-cycle air conditioners, or ceiling insulation, you’re operating in a market worth hundreds of millions in rebates annually.
The Big Compliance Rules You Absolutely Cannot Break
1. The Telemarketing and Doorknocking Ban (Yes, It’s Serious)
The Rule: Since 1 May 2024, cold-call telemarketing has been banned. Since 1 August 2024, doorknocking has been banned. No exceptions, no ‘but we’re different’.⁵
What This Means:
- You cannot phone or visit residential or business premises to market VEU products unless you have express prior consent
- You cannot buy contact lists from third parties if those contacts were generated through telemarketing or doorknocking
- You cannot outsource to overseas call centres that cold-call on your behalf
- Your contractors, agents, and employees are all bound by the same rules
What IS Allowed:
- Consumers filling out an online form requesting information (that’s consent)
- People visiting your stall at a shopping centre and asking to be contacted
- Responding to inbound enquiries within 3 months of the request
- Following up with existing customers (for product defects or warranty issues only, not marketing)
Real Consequences: In May 2025, Astra Green Solutions was fined $69,231 for acquiring consumer contact details through unsolicited overseas marketing calls. The ESC surrendered 28 of their VEECs (worth approximately $3,000) and sent a very clear message: breaches will be punished.⁶
The Good News: Since the bans took effect, telemarketing complaints have dropped 24% and doorknocking complaints have plummeted 75%.⁷ The market is cleaner, and compliant businesses have a competitive advantage.
2. Accreditation Requirements (Your Licence to Operate)
The Rule: Only businesses accredited by the Essential Services Commission can create VEECs. Your accreditation expires every 12 months and must be renewed.⁸
Key Requirements:
- Pass the ‘fit and proper person’ test annually
- Pass the ‘competent and capable’ test annually
- Renew accreditation at least 90 days before expiry (or face a $13,814 late fee)⁹
- If your accreditation lapses, you’re out – no VEECs, no rebates, no business
What You Need:
- Licensed electricians or plumbers for relevant activities (no additional VEU-specific training required)
- Proper documentation systems to prove compliance
- Understanding of the specific VEEC creation rules for each activity type
Pro Tip: Applications submitted less than 90 days before expiry incur a massive late fee. Set reminders at 120 days before your accreditation expires. Treat this date like your wedding anniversary – you do NOT want to forget it.
3. Documentation and Record-Keeping (The Audit-Proof Approach)
The Rule: You must maintain proper records that prove:
- Express consent was obtained (for any marketing contact)
- The product was eligible and approved by the ESC
- The installation was completed correctly
- The VEEC assignment form was properly executed
- All consumer rights information was provided
What the ESC Audits: The commission conducts regular compliance audits and can request evidence of:
- Consumer consent records (written records showing who consented, when, and to what)
- Invoice and proof of purchase listing brand and model
- Installation photos and compliance certificates
- Signed VEEC assignment forms
- Consumer rights factsheets provided to customers
Audit Frequency: There’s a current backlog of accreditation applications, but don’t let that fool you – the ESC is actively monitoring compliance through expanded tools including consumer surveys, audits, and complaint investigations.¹⁰
Best Practice: Treat every job as if it will be audited tomorrow. Digital systems that automatically capture photos, signatures, and documentation are worth their weight in gold.
4. Code of Conduct Requirements
The Rule: Since 1 July 2022, all accredited persons and scheme participants must comply with the VEU Code of Conduct.¹¹
Minimum Standards Include:
- Providing consumers with a statement of their rights and obligations before entering a contract
- Offering the VEET scheme consumer factsheet during lead generation or marketing
- Ensuring all marketing materials are truthful and not misleading
- Respecting consumer choices and not using high-pressure sales tactics
- Providing clear information about products, prices, and rebates
The ESC’s Enforcement Powers: The commission has strengthened enforcement powers that now extend beyond accredited providers to include oversight of installers. They can:
- Issue penalty notices
- Institute civil litigation
- Initiate criminal prosecution proceedings
- Suspend or revoke accreditations
- Order the surrender of non-compliant VEECs
What Changed in 2025–2026? (The Updates You Need to Know)
Program Extension to 2045
In May 2025, Victoria’s Parliament passed the Victorian Energy Efficiency Target Amendment (Energy Upgrades for the Future) Bill 2025, extending the program from 2030 to 2045. This gives businesses long-term confidence to invest in VEU capabilities.³
What This Means for Lead Generators:
- The market isn’t going anywhere for the next two decades
- You can build sustainable business models around VEU lead generation
- Training staff and developing systems makes sense as a long-term investment
Interim Targets for 2026–2027
Instead of the usual five-year target period, the government set interim two-year targets while conducting a strategic review:
- 2026: 4.4 million VEECs⁴
- 2027: Target to be confirmed (but similar to 2026)
- Long-term targets from 2028 onwards will be set after the strategic review concludes
Why the Adjustment? The targets were recalibrated after the telemarketing and doorknocking bans reduced lead generation volumes. The government acknowledged that compliance improvements would impact short-term activity while the industry adapted to the new rules.
New Ceiling Insulation Discounts (Early 2026)
Early 2026 marked the debut of insulation in the VEU program, targeting the 60% of Victorian homes that are under-insulated.¹²
The Opportunity:
- 200,000 homes with no insulation are the initial target
- Most participants receive 70–90% discounts
- Low-income or priority households may qualify for $0 upfront cost
- Can cut heating and cooling bills by up to 30%
Compliance Note: Insulation must meet ESC-approved product standards. Check the VEU Register of Approved Products before generating leads.
VEEC Creation Fee Increase
From 1 January 2026, the VEEC creation fee increased to $4.35 per certificate.¹³ This is a minor cost increase but factor it into your margin calculations.
Removal of 31 January Deadline
Previously, VEECs had to be created by 31 January for the previous calendar year. This deadline has been removed, giving energy retailers more time to acquire certificates and reducing demand pressure.¹⁴
Impact: This helps stabilise VEEC prices by spreading demand across the year rather than creating a January rush.
How to Stay Compliant Without Losing Your Mind
1. Build Compliance Into Your Lead Generation
Don’t:
- Buy aged data from questionable sources
- Use overseas call centres that can’t prove consent
- Copy contact details from public directories and start calling
Do:
- Generate leads through organic search (SEO)
- Run compliant social media campaigns with clear opt-ins
- Use landing pages that require explicit consent checkboxes
- Partner with comparison sites that generate inbound enquiries
- Attend community events and collect consent forms at stalls
The Golden Rule: If you can’t prove express prior consent with written records, don’t make contact. It’s that simple.
2. Work With the Right Accredited Providers
If you’re generating leads rather than doing installations yourself, ensure your accredited provider partners understand compliance.
Questions to Ask:
- How do you handle documentation and record-keeping?
- What’s your audit history with the ESC?
- How do you ensure installers are properly licensed?
- What systems do you have for consent verification?
- Have you ever had VEECs surrendered for non-compliance?
Red Flags:
- Providers who brush off compliance questions
- Those offering to ‘handle the paperwork’ without proper systems
- Anyone suggesting ways to ‘get around’ the telemarketing ban
- Providers with recent ESC enforcement actions against them
3. Use Technology to Your Advantage
Compliance-Friendly Tools:
- CRM systems that timestamp and store consent records
- Form builders with mandatory consent checkboxes
- Email automation that includes unsubscribe options
- Phone systems that log inbound vs. outbound calls
- Photo documentation apps for installers
The ROI: Yes, proper systems cost money upfront. But one ESC fine, one surrendered batch of VEECs, or one suspended accreditation will cost you far more.
4. Train Everyone (Yes, Everyone)
The ESC makes clear: it’s not just the accredited provider who needs to understand compliance – it’s every employee, contractor, and agent involved in the process.
Who Needs Training:
- Sales staff generating leads
- Marketing teams running campaigns
- Third-party contractors doing lead generation
- Installers completing jobs
- Administrative staff handling paperwork
What They Need to Know:
- The telemarketing and doorknocking bans
- How to obtain and document express consent
- Consumer rights that must be communicated
- Proper VEEC assignment form procedures
- What constitutes non-compliance and the consequences
5. Stay Updated
The VEU program is under strategic review through 2026–2027. Things will change.
Where to Monitor:
- Essential Services Commission’s VEU Updates page
- Monthly VEU Bulletins for accredited persons
- Department of Energy, Environment and Climate Action (DEECA) announcements
- Engage Victoria consultation pages
Set Alerts: Subscribe to the ESC’s VEU newsletter and set Google Alerts for ‘Victorian Energy Upgrades compliance’ and ‘VEU program changes’.
Common Compliance Myths Busted
Myth #1: ‘The telemarketing ban only applies to residential customers’
False. The ban applies to both residential AND business premises. You cannot cold-call or doorknock businesses either without express prior consent.⁵
Myth #2: ‘If we’re calling about products, not explicitly VEU, we’re exempt’
False. If the end result is marketing energy-efficient products that could be eligible for VEU rebates, you’re covered by the ban. The ESC isn’t interested in creative interpretations – if it looks like VEU marketing, it’s VEU marketing.
Myth #3: ‘Express consent means they didn’t say no’
False. Express consent means active, documented agreement. Silence is not consent. Failure to opt-out is not consent. You need written records showing the person agreed to be contacted.
Myth #4: ‘Small businesses don’t get audited’
False. The ESC audits businesses of all sizes. They receive and investigate complaints regardless of your company’s size. In fact, smaller operators often have weaker compliance systems, making them easier targets.
Myth #5: ‘We can contact our past customers anytime’
Mostly False. You can only contact previous customers for product defects, warranty issues, or safety recalls. Marketing new products or services to past customers requires express prior consent obtained specifically for that purpose.
Myth #6: ‘Overseas call centres are outside ESC jurisdiction’
Very False. If you contract with or receive leads from overseas call centres conducting telemarketing, YOU are responsible for compliance. The ESC will come after the accredited Australian business, not the overseas vendor. Astra Green learnt this lesson the expensive way.⁶
What Happens If You Get It Wrong?
The ESC has a range of enforcement actions, escalating based on severity:
Level 1: Warnings and Education
- First-time minor infractions
- Immediate correction required
- Educational guidance provided
Level 2: Penalty Notices
- Fines ranging from thousands to tens of thousands of dollars
- Astra Green’s $69,231 fine is a reference point⁶
- Public announcement of the penalty
Level 3: VEEC Surrender Orders
- Non-compliant certificates must be surrendered
- Immediate financial loss from returned certificates
- Damage to reputation in the industry
Level 4: Accreditation Suspension or Revocation
- Temporary or permanent loss of ability to create VEECs
- Business effectively shut down from VEU market
- Difficult and expensive to regain accreditation
Level 5: Civil Litigation or Criminal Prosecution
- Reserved for serious, intentional breaches
- Significant financial penalties
- Potential criminal records for individuals involved
The ESC’s Approach: They prefer education and compliance over punishment, but they will not hesitate to take strong enforcement action when businesses ignore warnings or engage in intentional non-compliance.
The Bottom Line for Lead Generators
VEU compliance in 2026 comes down to three core principles:
- Generate leads the right way – Organic search, social media with opt-ins, comparison sites, and inbound enquiries are your friends. Cold outreach is dead.
- Document everything – If you can’t prove compliance with written records, assume you’re non-compliant. Digital systems save time and money.
- Partner with quality accredited providers – Your business reputation depends on theirs. Choose partners with strong compliance track records.
The VEU market represents a massive opportunity through 2045. With 4.4 million VEEC targets in 2026 and new products like ceiling insulation launching, demand for quality leads has never been higher.
But the ESC is serious about protecting consumers and maintaining program integrity. The businesses that thrive will be those that build compliance into their DNA rather than treating it as an afterthought.
The telemarketing and doorknocking bans eliminated a lot of the dodgy operators. If you’re generating high-quality, compliant leads, you’re now competing in a cleaner market against fewer competitors. That’s good news for everyone – except the rule-breakers.
Stay compliant, stay competitive, and you’ll build a sustainable business in Victoria’s energy efficiency market for decades to come.
Need help generating VEU-compliant leads? Comparison Connect specialises in intent-driven lead generation through SEO, AEO, and GEO channels – no telemarketing, no doorknocking, just prospects actively seeking energy upgrades. Talk to an agent to learn how we generate qualified VEU leads that convert.
Quick Reference: Key VEU Compliance Resources
Essential Services Commission (ESC):
- VEU Program Homepage: esc.vic.gov.au/victorian-energy-upgrades-program
- Accredited Persons Resources: esc.vic.gov.au/accredited-persons
- VEU Registry (Find Accredited Providers): veu-registry.vic.gov.au
- Report Compliance Issues: 03 9032 1310 or veu@esc.vic.gov.au
Department of Energy, Environment and Climate Action (DEECA):
- VEU Program Information: energy.vic.gov.au/victorian-energy-upgrades
- Industry News and Updates: energy.vic.gov.au/veu-industry-latest-news
Key Dates to Remember:
- 1 January 2026: VEEC creation fee increased to $4.35 per certificate
- Early 2026: New ceiling insulation rebates launched
- 2026–2027: Interim program targets while strategic review is conducted
- 2028 onwards: New long-term targets to be announced after strategic review
- 2045: Current program end date (extended from 2030)
Accreditation Renewal:
Applications submitted on time maintain accreditation until decision is made
Renew at least 90 days before expiry or pay $13,814 late fee
Accreditations expire 12 months after grant date
Sources & Fact-Check References
- Victorian Government – Victorian Energy Upgrades Program Overview (accessed February 2026)
- Victorian Government – VEU Program Environmental Benefits (accessed February 2026)
- Victorian Energy Efficiency Target Amendment (Energy Upgrades for the Future) Bill 2025 – Passed May 2025
- Essential Services Commission – VEU 2026 Interim Targets Announcement (accessed February 2026)
- Essential Services Commission – Telemarketing and Doorknocking Ban Implementation (1 May 2024 and 1 August 2024)
- Essential Services Commission – Astra Green Solutions Penalty Notice (May 2025)
- Essential Services Commission – VEU Compliance Report 2024–2025 (accessed February 2026)
- Essential Services Commission – Accreditation Requirements for VEU Participants (accessed February 2026)
- Essential Services Commission – Accreditation Fees Schedule (accessed February 2026)
- Essential Services Commission – VEU Audit and Compliance Framework (accessed February 2026)
- Essential Services Commission – VEU Code of Conduct (effective 1 July 2022)
- Victorian Government – Ceiling Insulation Rebates Launch Announcement (Early 2026)
- Essential Services Commission – VEEC Creation Fee Schedule (effective 1 January 2026)
- Essential Services Commission – VEEC Creation Timeline Changes (accessed February 2026)
All facts, figures, dates, and regulatory requirements in this article have been verified against official Victorian Government and Essential Services Commission sources as of February 2026. Regulations may change – always verify current requirements at esc.vic.gov.au before taking action.