Guys - just fyi here is what is on the Clean Energy Regulators...

Guys - just fyi here is what is on the Clean Energy Regulators site - note the highlights pretty strong language
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The Clean Energy Regulator expects liable entities to honour their renewable energy obligations

06 February 2017

We are fast approaching the 14 February 2017 deadline, when all liable entities must meet their Renewable Energy Target obligations for 2016. We want to take this opportunity to confirm the requirements that liable entities must meet to comply with the law.

Liable entities have an important role to play in achieving the 2020 Renewable Energy Target and we expect electricity retailers to comply with their obligations by fully acquitting their liability through the surrender of large-scale generation certificates and small-scale technology certificates.

The intentional failure to surrender certificates will be viewed as a failure to comply with the spirit of the law and an undermining of the objectives and integrity of the scheme. The Regulator will investigate all cases of intentional failure and if necessary has the power to conduct audits. Paying a shortfall charge does not support new generation to meet the 2020 target. Shortfall charges are paid into consolidated revenue rather than boosting a growing Australian industry.

Liable entities are reminded that on or before 14 February 2017 they must:

• lodge their energy acquisition statement, and
• surrender certificates through the REC registry, or
• where a decision has been made to pay a shortfall charge to acquit all or part of the liability, lodge the shortfall statement and ensure that the shortfall charge payment has been received into the Commonwealth’s bank account.

There are serious consequences for entities that fail to meet these obligations, including significant additional financial penalty charges and interest charges. Failure to lodge statements on time is also a criminal offence that may attract criminal penalties. Where a debt is incurred, the Regulator will pursue that debt in accordance with the law, up to and including applications to wind up companies in appropriate cases. Further information is available on the shortfall charges page. We strongly recommend liable entities seek professional, independent advice on their specific circumstances if they do not understand the requirements or believe that they may have difficulty fulfilling their obligations.

We take shortfall of any amount very seriously, particularly large-scale generation shortfall of 10 per cent or more. We understand from brokers that there are sufficient certificates available in the market and that orders from very small to very large can be serviced.

We will be publishing the name of each liable entity that has a shortfall, and any other relevant information on our website.

If a liable entity thinks that they may be unable to meet their obligations they should contact us immediately.

Overall, the electricity sector has taken a responsible approach to meeting its obligations under the Renewable Energy Target. The vast majority of liable entities have complied with the objectives of the Renewable Energy (Electricity) Act 2000 and fulfilled their obligations.