Information on Commercial Lighting upgrades 

With commercial lighting implementations ending 31 March 2026, we remind Accredited Certificate Providers (ACPs) to ensure remaining upgrades comply with the Commercial Lighting Energy Savings Formula. Below we’ve listed some top tips to help you with your quality assurance and options we have to enforce compliance.

Due diligence and quality assurance

To ensure Commercial Lighting upgrades meet scheme requirements, ACPs should exercise caution and rigor in due diligence with installers and contractors. ACPs should use robust quality assurance and a cautious approach to certificate creation.

Top tips for assessing evidence

Check for duplicates: Ensure that the same baseline photographs are not used as evidence for more than one implementation site.

Check for signs of potential ‘staging’:  

  • Be wary of products that are not fit for purpose or seem over-engineered, such as 600W high-pressure sodium lights in a space not suited for such lighting.
  • Check if reflected ceiling plans and photographs show a high number of lights relative to the space.  
  • Look for installations where the condition of the baseline equipment is questionable, such as when new supporting infrastructure does not match the condition of the old lights. 

Make enquiries to establish the true baseline: 

  • Ask the customer if they undertook any previous lighting upgrades and what was installed. Advise the customer this can be checked by IPART.  
  • Conduct customer or online enquiries to locate pictures or videos of the premises that may show the true previous lighting.  
  • Check online resources to establish the age of the building (a new building is unlikely to have had old lights fitted).  
  • Conduct pre-implementation site visits.

If unsure about evidence, ask installers or contractors for satisfactory or supplementary evidence. When in doubt, take a cautious approach to certificate creation. We will take appropriate compliance action where we detect inaccurate or misleading evidence. 

We remind ACP's that they must provide auditors and IPART compliance officers reasonable access to sites for the purpose of conducting audits or investigating compliance with scheme requirements.

Compliance and enforcement 

We will identify non-compliance through audits, inspections, and investigations. Non-compliance, including inaccurate or misleading baseline evidence (e.g. geo-tagged photos of old lights), may result in: 

  • Orders to surrender certificates
  • Penalty notices
  • Amendments to accreditations
  • Cancellation of accreditations
  • Prosecutions. 

For more information, go to our Commercial Lighting Energy Saving Formula web page.

If you have any questions, please email ess.compliance@ipart.nsw.gov.au