Receiving a petroleum licence is not the end of the regulatory process. Licence holders must maintain accurate records, comply with licence conditions and submit required information after licensing. Business changes can also affect the licence position and should be assessed before they are implemented.
The Department of Mineral and Petroleum Resources publishes DMPR-30 for wholesale licence annual information and DMPR-33 for retail licence annual information. Manufacturing licence holders use the applicable manufacturing submission form. The correct form and current fee should always be verified on the official licensing resources page.
Why annual information matters
Annual information helps maintain the regulatory record connected to the licence and the business operating under it. A licence holder should not assume that a valid certificate removes the need for continuing reporting.
The annual preparation process should confirm:
- The licence category and reference number
- The legal entity holding the licence
- Current ownership and directors
- Current contact and registered-office details
- Business or trading information required for the period
- Applicable supporting documents and proof of payment
- Changes that occurred since the previous submission
Wholesale annual information
Licensed wholesalers are expected to submit annual business information using the official wholesale form. The submission should be prepared from reliable internal records rather than reconstructed at the last moment.
Useful records include:
- Sales and purchase summaries
- Product and volume records
- Customer and supplier records
- Transport and delivery documentation
- Updated company and ownership information
- Previous annual submissions
- Departmental correspondence
A business that does not maintain organised transaction and compliance records may struggle to complete annual submissions consistently.
Retail annual information
Retail licence holders must submit the applicable annual retail information. The submission should align with the licensed retailer, the licensed site and the operating business.
Where the site owner, property arrangement, retailer, operator or business entity has changed, the change should be assessed rather than simply reflected informally in the next annual submission.
Business changes are not all treated the same
A change of telephone number is not equivalent to a change in the legal entity holding the licence. Similarly, a share sale, business sale, lease change, property transfer and majority ownership change may have different regulatory consequences.
Changes requiring careful assessment may include:
- Change of licence-holder entity
- Sale of the operating business
- Change in majority ownership or control
- Change of directors or members
- Change of registered address or contact details
- Change of site ownership or lease arrangements
- Change in the nature of the petroleum activity
- Change in operating premises
- Business restructuring, merger or transfer
The correct response may be a notification, amendment, supporting submission or new application, depending on the facts and the applicable legal process.
Assess changes before signing the transaction
Petroleum businesses are often bought or restructured through commercial agreements before the licensing consequences have been properly analysed. This can create a gap between the contractual transaction and the regulated operating position.
Before finalising a transaction, establish:
- Who currently holds each relevant licence
- Which assets, shares, property rights or contracts are being transferred
- Whether the licensed activity will continue unchanged
- Whether the operating entity or control will change
- What regulatory steps must occur before or after implementation
- Which conditions should be included in the sale or restructuring agreement
Requests for further information
The Department may request documents or clarification in relation to an application, submission or licence record. A response should address the request directly, use consistent evidence and preserve a complete record of what was supplied.
A controlled response file should include:
- The original request
- A response checklist
- Revised or additional documents
- A covering explanation
- Proof of submission
- Follow-up correspondence
Create an annual compliance calendar
Licence holders should maintain a recurring compliance calendar rather than relying on memory. The calendar can include annual information, licence fees, insurance renewals, company-record updates, agreement renewals and operational reviews.
Assign responsibility to a named person and retain evidence of each completed action.
UFuel compliance support
UFuel assists with annual information submissions, licence-record reviews, ownership and entity-change assessments, and responses to requests for further information. Review the annual submissions and licence changes pathway or request assistance.