If you run a solar install business, you have already seen the headlines. In April 2025 the first ever “super complaint” was lodged with the ACCC, and it was aimed squarely at unsolicited door-to-door solar sales (ABC News, 2025). Every write-up covered the same ground: who filed it, what they said, and a bit of general context about dodgy doorknockers.
What none of them told you is what happens next. A complaint landing is not the end of the story. It is the start of a process that can run for months or years and end in anything from a quiet warning letter to civil penalty proceedings in the Federal Court. If you sell at the door, or you use reps who do, the practical question is not “what did the news say”, it is “what should I be doing right now so I am not the example the regulator makes”.
That is what this article is about. I have spent 17-plus years around the business side of this trade, and I have watched compliance get treated as an afterthought right up until it becomes the only thing that matters. Let me walk you through how ACCC enforcement actually works, what the realistic outcomes are, and the checklist I would be running through if my name was on the door.
What a super complaint actually is
First, clear up the language, because “super complaint” sounds dramatic and the reality is more procedural. It is not one angry customer. It is a formal complaint made under the ACCC’s designated complaints function, a mechanism that lets certain approved consumer and small business groups put an issue in front of the regulator and force a public response within a set timeframe.
In this case the Consumer Action Law Centre used that function to escalate unsolicited door-to-door solar sales as a systemic problem, not a one-off (CHOICE, 2025). The difference matters. An individual complaint about one bad sale might get logged and sit in a queue. A designated complaint obliges the ACCC to publicly assess the issue and say what it intends to do about it. It puts the whole sales channel under the spotlight, not one seller.
So when people ask me whether this is “just news”, my answer is no. It is a formal signal that the regulator has been asked, on the record, to look hard at how solar gets sold at the door. That is the kind of thing that shapes enforcement priorities for years.
What the ACCC does after a complaint lands
Once an issue is on the ACCC’s radar, the process generally moves through a few stages, and it is worth understanding each one because your exposure is different at each step.
Assessment. The regulator weighs up whether the conduct is widespread, how much consumer harm is involved, and whether it fits their enforcement priorities. Vulnerable consumers, misleading conduct, and systemic breaches all push an issue up the list.
Information gathering. The ACCC has real investigation powers. It can issue compulsory notices requiring a business to hand over documents, data and answers. This is the point where your paperwork stops being an internal housekeeping matter and becomes evidence. If a regulator asks you to prove a customer gave informed consent, or that a cooling-off disclosure was made, “we always do that” is not an answer. A signed, timestamped record is.
Decision on action. Based on what they find, the ACCC decides whether to act and how hard. That decision turns heavily on the quality of the evidence, whether the conduct was deliberate or careless, and whether the business cooperated.
Timelines here are not quick. Assessment can take weeks, a genuine investigation can run for many months, and litigation on top of that stretches into years. That long runway cuts both ways. It gives a sloppy operator time to keep digging a hole, and it gives a switched-on operator time to get their house in order before anyone comes knocking.
The realistic range of enforcement outcomes
This is where the news coverage goes quiet, so let me lay out what the ACCC can actually do when it finds non-compliant conduct. Outcomes generally sit on a ladder from light to severe.
Educational and warning letters. For lower-level or first-time issues, the regulator may simply write to the business setting out its concerns and expectations. Cheap to receive, and a clear signal to fix things before it escalates.
Infringement notices. For certain breaches the ACCC can issue an infringement notice, which comes with a financial penalty. Paying it is not an admission of liability, but it is a real cost and a clear marker that you were on the wrong side of the rules.
Court-enforceable undertakings. The business formally promises to change its conduct, and that promise is enforceable in court. Break it and you are straight back in front of a judge. These often come bundled with compliance programs, staff training requirements and refunds to affected customers.
Civil penalty proceedings. At the top of the ladder, the ACCC takes the business to the Federal Court seeking penalties. Under the Australian Consumer Law the maximum penalties for corporations are steep, and the numbers have been rising over the years as parliament sharpens the deterrent. This is the outcome that ends businesses, not just quarters.
Which rung you land on is not random. It tracks the seriousness of the conduct and, crucially, whether you can show you tried to do the right thing. A clean audit trail and a genuine compliance program are the difference between an educational letter and a court date.
The rules at the centre of it: unsolicited consumer agreements
The legal heart of this whole issue is the unsolicited consumer agreement regime under the Australian Consumer Law. When you sell at someone’s door without them inviting you, a specific set of obligations kicks in, and they are stricter than a normal sale (ACCC, n.d.-b).
In broad terms, unsolicited door-to-door sales carry a 10 business day cooling-off period, restrictions on the hours reps can call, an obligation for reps to clearly identify themselves and their purpose up front, a requirement to leave if asked, and rules about giving the customer a compliant written agreement (ACCC, n.d.-c). During the cooling-off period there are also limits on supplying goods and taking payment for higher-value agreements.
None of this is exotic. It is the baseline every doorknocking solar seller is meant to meet. The reason the super complaint exists is that, across the channel, too many sellers were not meeting it. The ACCC’s own solar guidance page is the plain-English reference I would point every new rep at before they knock on a single door (ACCC, n.d.-a).
Your practical compliance checklist
Here is the part the news never gives you: what to actually do. If I were tightening up a door-to-door solar operation this quarter, this is the list I would work through.
Respect do-not-knock signage, every time. A clear “do not knock” sticker is a request not to be approached, and ignoring it is exactly the kind of conduct that draws complaints and regulatory attention. Brief your reps that a sticker means walk away, no exceptions, no “just a quick chat”.
Disclose the cooling-off rights properly. The customer must be told, in the agreement, about their 10 business day cooling-off period and how to use it. This cannot be buried or skipped. I have written more on getting this right in our piece on capturing consent and cooling-off disclosure, and it pairs with our broader guide on door-to-door solar sales compliance.
Document consent at the point of sale. Not later, not “we’ll write it up back at the office”. At the door. Who agreed, to what, when, and that they were given the required disclosures. If you cannot prove it happened, from the regulator’s point of view it did not happen.
Train your reps and keep records of the training. A rep who does not understand the rules is a liability with your logo on their shirt. Run structured training on what they can and cannot say, and keep dated records that you did it. When the ACCC asks whether you took reasonable steps, that training log is part of your answer.
Keep a clean audit trail end to end. Consent, disclosures, the signed agreement, any cancellation requests and how you handled them. This is the evidence that turns a potential penalty into a “no further action”.
Why compliance is a competitive edge, not just a cost
Here is the part I want every operator reading this to sit with. When a whole sales channel goes under the microscope, the compliant businesses get tarred with the same brush as the cowboys, at least until they can prove otherwise. Customers get warier, referral partners get nervous, and the regulator paints with a broad first coat.
The operators who come out ahead are the ones who can hand over a clean file on any job, on any day, without a scramble. That is not just legal cover. It is a sales asset. In a market where doorknocking has a bad name, being visibly, provably above board is a reason for a customer to trust you over the next mob.
This is exactly the gap I am building CurrentFlow to close. The idea is to capture consent, cooling-off disclosures and the full sales record at the point of sale, so a solar business has a defensible compliance trail if the ACCC or a state fair trading body ever comes asking. It is the tool I wished I had every time I watched a good business get caught out not by bad intent, but by bad record-keeping.
The super complaint is a warning shot for the whole channel. The businesses that treat it as a prompt to tighten their process, rather than a headline to scroll past, are the ones that will still be selling solar when the dust settles.
References
ABC News. (2025, April 8). Unsolicited rooftop solar sales subject to first ACCC ‘super complaint’. https://www.abc.net.au/news/2025-04-08/solar-door-to-door-accc-complaint/105094468
Australian Competition and Consumer Commission. (n.d.-a). Solar panel systems and home batteries. https://www.accc.gov.au/business/specific-products-and-activities/solar-panel-systems-and-home-batteries
Australian Competition and Consumer Commission. (n.d.-b). Telemarketing and door-to-door sales. https://www.accc.gov.au/consumers/buying-products-and-services/telemarketing-and-door-to-door-sales
Australian Competition and Consumer Commission. (n.d.-c). Contracts. https://www.accc.gov.au/consumers/buying-products-and-services/contracts
CHOICE. (2025). Door-to-door solar sales targeted in ‘super complaint’. https://www.choice.com.au/shopping/consumer-rights-and-advice/your-rights/articles/calc-designated-accc-complaint
FAQ
What is an ACCC super complaint?
It is a complaint made under the ACCC’s designated complaints function, which lets approved consumer and small business groups formally raise a systemic issue and force a public response within a set timeframe. The 2025 complaint about unsolicited door-to-door solar sales was lodged by the Consumer Action Law Centre (CHOICE, 2025). It is different from an individual consumer complaint because it puts a whole practice under review, not a single sale.
What penalties can the ACCC impose on non-compliant solar sellers?
The outcomes range from educational and warning letters, through infringement notices with financial penalties, to court-enforceable undertakings, and at the top end civil penalty proceedings in the Federal Court. Which one applies depends on how serious the conduct was, whether it was deliberate, and whether the business can show it took reasonable compliance steps (ACCC, n.d.-b).
How long is the cooling-off period for a door-to-door solar sale?
For unsolicited consumer agreements under the Australian Consumer Law, the cooling-off period is generally 10 business days, and the customer must be told about it in the agreement (ACCC, n.d.-c). There are also restrictions on supplying goods and taking payment during that window for higher-value agreements.
Does a “do not knock” sticker legally stop a solar rep?
Ignoring a clear “do not knock” sign is treated as the kind of unsolicited approach the rules are designed to prevent, and it is exactly the conduct that draws complaints and regulatory attention (ACCC, n.d.-b). The safe and correct practice is to train every rep to walk away from a sticker, no exceptions.
How can a compliant solar business protect itself if the ACCC investigates?
Keep a clean, timestamped audit trail for every door-to-door sale: the customer’s consent, the cooling-off disclosure, the signed agreement, and how any cancellation was handled. Train your reps and keep dated records of that training. When a regulator asks you to prove you did the right thing, documentation is the difference between a “no further action” and a penalty.