Earn More from C&I Solar - What Activity 47 Means for You

Published: October 27, 2025.

Earn More from C&I Solar - What Activity 47 Means for You

Activity 47 is a new activity under the Victorian Energy Upgrades (VEU) program called 'Deemed C&I Solar PV.' It enables VEEC (Victorian Energy Efficiency Certificate) creation for commercial and industrial solar PV installations between 30 kW and 200 kW, which were previously ineligible for VEECs but can now generate upfront deemed certificates, significantly improving project economics.


I'm pleased to share that Northmore Gordon is the first Accredited Person (AP) under the Victorian Energy Upgrades (VEU) program to support Activity 47 - Deemed C&I Solar PV.

This new activity allows VEECs to be created for a much broader range of commercial solar systems in Victoria, opening new revenue opportunities for a wide range of partners - from installers, EPCs, PPA and lease providers to energy retailers, equipment suppliers, and developers.

Our accreditation is effective from 9 October 2025. If you're delivering commercial solar solutions and want to understand whether your past or future projects qualify, now's the time to get in touch.

What is Activity 47?

Activity 47 enables VEEC creation for C&I solar PV installations between 30 kW and 200 kW. These projects were previously ineligible for VEECs but can now generate upfront deemed certificates, significantly improving project economics.

At Northmore Gordon, we also support VEEC creation for larger systems using existing VEU-approved methods:

  • 30-200 kW systems:
    - Eligible for Deemed VEECs (Activity 47A/47B)
    - <100 kW systems can also claim STCs
  • 200-400 kW systems:
    - Eligible for Streamlined M&V (SMM4)
    - Lower evidence burden, faster processing
  • 400 kW-10,000 kW+ systems:
    - Suitable for Advanced M&V (PBA method)
    - Ideal for complex, high-value installations

We are accredited for all VEEC pathways, so no matter the system size, we can support certificate creation and maximise the return.

Who Should Be Paying Attention?

If you're involved in any part of the commercial solar value chain - including:

  • Installers, EPCs or PPA providers
  • Energy retailers or distributors
  • Consultants or aggregators
  • OEMs and equipment suppliers
  • Financiers and lease providers
  • Project developers or property portfolio managers

- this is your opportunity to unlock additional revenue and create more compelling business cases for your clients.

How We Help

My team and I can guide you through:

  • Determining project eligibility under Activity 47 and other VEEC pathways
  • Selecting the right method: Deemed, SMM4 or Advanced M&V
  • Registering VEECs for compliant projects
  • Managing evidence and meeting ESC compliance expectations
  • Stacking VEECs with STCs or LGCs to maximise value

We make the process straightforward and compliant, and we'll tailor our support depending on your role in the project.

Important Compliance Reminder

VEU rules strictly prohibit telemarketing and door knocking. Every VEEC claim must show how the customer lead was generated. If you're unsure about your current approach, we can help review your process to ensure it aligns with the ESC's requirements.

Let's Talk

If you're working on, financing, supplying or selling commercial solar systems in Victoria, it's worth reviewing whether your current or planned projects could qualify for VEECs - either under Activity 47 or via M&V pathways.

Email me directly at m.ghajar@northmoregordon.com or call 1300 878 500. We'll help you understand your options and how to get started.

Scheme and certificate context

Before using a certificate or grant figure, confirm the current scheme method, eligible activity, effective date, evidence requirements, price date and registration or application process.

What is Activity 47 under the Victorian Energy Upgrades program?

Activity 47 is a new activity under the Victorian Energy Upgrades (VEU) program called 'Deemed C&I Solar PV.' It enables VEEC (Victorian Energy Efficiency Certificate) creation for commercial and industrial solar PV installations between 30 kW and 200 kW, which were previously ineligible for VEECs but can now generate upfront deemed certificates, significantly improving project economics.

Is Northmore Gordon the first company accredited to support Activity 47?

Yes, we are the first Accredited Person (AP) under the Victorian Energy Upgrades (VEU) program to support Activity 47 – Deemed C&I Solar PV. Their accreditation is effective from 9 October 2025.

What size range of commercial solar systems qualifies for Activity 47 Deemed VEECs?

Systems between 30 kW and 200 kW are eligible for Deemed VEECs under Activity 47A/47B. Additionally, systems under 100 kW can also claim Small-scale Technology Certificates (STCs), creating a dual-pathway opportunity. This dual-certificate approach expands the economic incentive available to smaller commercial installations.

What VEEC pathways are available for larger commercial solar systems above 200 kW?

For 200–400 kW systems, Streamlined M&V (SMM4) is available, offering a lower evidence burden and faster processing. For systems from 400 kW up to 10,000 kW or more, Advanced M&V (Project Based Activities method) is suitable, ideal for complex, high-value installations. Each pathway balances evidence requirements against project scale and certificate value.

Why should commercial solar installers and EPCs understand the difference between VEEC certificates, STCs, and LGCs?

VEEC certificates, STCs, and LGCs should not be treated as interchangeable incentives because they have different eligibility, creation, and use rules. A 50 kW system may qualify for both Deemed VEECs and STCs, but combining them requires separate eligibility checks and proper documentation of which attributes are retired or sold. We help clients separate these instruments and avoid double-counting or ownership conflicts.

What role does Northmore Gordon play in helping businesses comply with VEU lead-generation rules?

VEU rules strictly prohibit telemarketing and door knocking for customer lead generation. Every VEEC claim must show how the customer lead was generated, and we can review a business's lead generation process to ensure it aligns with the Essential Services Commission's requirements. This compliance check protects installers and EPCs from certificate rejection and reputational risk.

How should commercial solar projects prepare evidence before committing to a certificate pathway?

Begin with a project brief describing the site location, system size, intended installation date, ownership arrangements, and available baseline energy data. Document whether the customer lead generation complies with VEU rules. Our six-stage delivery approach—Assess, Build the Case, Capture Value, Deliver, Procure, and Perform—helps coordinate measurement planning, certificate eligibility and evidence responsibilities before equipment selection or installation.

What investment case considerations should solar installers and financiers prepare when promoting Activity 47 projects?

Before relying on VEEC proceeds in an investment case, establish the governing activity and document version, main eligibility assumptions, calculation basis, evidence responsibilities, and commercial treatment of certificates. Show certificate price and quantity assumptions separately. Confirm whether quoted figures are indicative gross value or actual customer payment after agreed charges. We help build transparent investment cases that distinguish project merit from unconfirmed funding.

Who benefits from Activity 47 and the broader VEEC pathways for commercial solar?

A wide range of partners can benefit, including installers, EPCs, PPA and lease providers, energy retailers and distributors, equipment suppliers (OEMs), consultants or aggregators, financiers, and project developers or property portfolio managers. Each stakeholder in the commercial solar value chain can use VEEC certificates to improve project economics or support customer value propositions aligned with their business model.

What is the practical consequence of choosing between Deemed M&V, Streamlined M&V, and Advanced M&V for solar projects?

Deemed pathways (Activity 47) offer quick upfront certificates for smaller systems but accept standard assumptions. Streamlined M&V requires more site-specific evidence but processes faster than Advanced M&V. Advanced M&V requires detailed baseline and monitoring but justifies higher certificate quantities for large installations. The choice is a technical and procedural assessment, not simply the route showing the largest estimated certificate quantity. We help match the method to project scale and evidence availability.

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