Building Compliance Checklist for NSW Developers: BCA & NCC Requirements

The Compliance Framework for NSW Building Projects

The National Construction Code (NCC) establishes the technical requirements for building work across Australia. The BCA forms part of the NCC and contains the building requirements relevant to the project.

For NSW developers, however, the BCA is only one part of the compliance picture. Depending on the development, the project may also involve:

• Development consent or a complying development certificate
• Construction certification
• Fire safety requirements
• Accessibility requirements
• Design compliance documentation
• Building inspections
• Occupation certification
• NSW-specific variations and requirements

The NCC sets minimum requirements for areas including structure, fire safety, access and egress, accessibility, health and amenity, and sustainability.

A good BCA compliance checklist therefore needs to consider the building’s design, intended use, classification and approval pathway rather than treating compliance as a final-stage document review.

Start With the Building Classification

Before checking individual technical requirements, confirm the building is correctly classified under the BCA.

The classification influences which requirements apply to the development. For example, BCA Volume One covers Class 2 to Class 9 buildings, while Volume Two covers certain Class 1 and non-habitable buildings.

The project team should establish:

• Building classification
• Proposed use and occupancy
• Number of storeys
• Floor area and relevant building dimensions
• Construction type
• Rise in storeys
• Fire compartmentation requirements
• Applicable BCA/NCC volume and provisions

Classification should be established early. Changes in use, layout, or building configuration can affect other compliance requirements, so getting the classification wrong at the start can create problems later.

BCA and NCC Design Compliance

Once you establish the building classification and applicable requirements, review the design against the relevant NCC provisions.

The NCC is performance-based. Compliance can be achieved through:

• Deemed-to-Satisfy provisions
• A Performance Solution
• A combination of both approaches

A design review should therefore consider whether the proposed solution meets the relevant Performance Requirements, not simply whether individual drawings appear to follow familiar prescriptive dimensions.

Key areas may include:

• Structure
• Fire safety
• Access and egress
• Accessibility
• Health and amenity
• Energy efficiency and sustainability

The exact requirements depend on the building classification, design and applicable NCC provisions.

Fire Safety Compliance

Fire safety deserves separate attention because deficiencies can have significant consequences for certification and building occupation.

The project team should identify the essential fire safety measures that apply to the building and ensure that their design, installation and documentation align with the applicable requirements.

Depending on the project, this may involve:

• Fire safety systems and equipment
• Fire resistance and compartmentation
• Egress and exit provisions
• Emergency warning systems
• Smoke control
• Fire hydrants and sprinklers
• Fire detection and alarm systems
• Fire Safety Schedule requirements
• Fire safety certification

NSW has also introduced reforms affecting the design, certification and maintenance of fire safety measures. From 13 February 2026, applicable maintenance of essential fire safety measures in Class 1b and Class 2 to Class 9 buildings must follow AS 1851-2012 where the maintenance activity is covered by the standard, unless a relevant performance solution applies.

For a development, the focus should not be limited to the final fire safety certificate. Fire safety requirements must be considered throughout design, construction, and handover.

Accessibility and Access Compliance

Review accessibility as part of the design process rather than as a final inspection item.

Depending on the building and proposed use, the review may consider:

• Accessible entrances
• Accessible paths of travel
• Doorways and circulation areas
• Ramps and stairs
• Lifts and vertical access
• Accessible sanitary facilities
• Parking and drop-off arrangements where applicable
• Signage and wayfinding
• Relevant DDA and Premises Standards considerations

The applicable requirements depend on the building and the work being undertaken.

For projects with complex access arrangements, early input from an access consultant can help identify issues before they become difficult to resolve through design changes.

Documentation and Design Compliance

A compliant building needs more than a compliant physical design. The required design documentation and declarations must also be available at the appropriate stages.

For regulated Class 2, 3 and 9c buildings, NSW certification requirements can include design compliance declarations and regulated designs before a certifier can issue a construction certificate or complying development certificate.

Developers should therefore check:

• Architectural drawings
• Specifications
• Structural documentation
• Fire safety documentation
• Access documentation
• Relevant engineering designs
• Performance Solution reports
• Design compliance declarations where applicable
• Supporting certificates and reports

The exact documentation requirements depend on the project and approval pathway.

Compliance Through Construction and Certification

Track compliance throughout the project’s approval and construction process.

Depending on the development, the process can include:

A Construction Certificate confirms that construction plans and specifications match the development consent and comply with the BCA.

During construction

Developers should establish a process for checking:

• Construction against approved drawings
• Changes made during construction
• Product substitutions
• Fire safety installations
• Waterproofing and other regulated building elements where applicable
• Structural work
• Access provisions
• Required inspections
• Required certificates and supporting evidence

Assess any proposed design change for potential compliance implications before implementing it.

The principal certifier also carries out mandatory inspections during construction and may request additional documentation demonstrating compliance. If the certifier identifies non-compliance, it can issue a written direction requiring the issue to be addressed.

Before occupation certification

The project team should confirm that outstanding compliance matters have been resolved.

• Approved plans reflect the building as constructed
• Required inspections have been completed
• Outstanding non-compliances have been addressed
• Required certificates and reports are available
• Fire safety measures are installed and appropriately documented
• Access provisions have been completed
• Required compliance declarations have been lodged
• Documentation required for occupation certification is complete

Building Compliance Checklist for NSW Developers

Use this checklist as a high-level project control tool. Adapt it to the building classification, approval pathway, and scope of work.

Planning and classification

• Confirm building classification
• Confirm proposed use and occupancy
• Identify applicable NCC/BCA requirements
• Confirm applicable NSW variations and requirements
• Establish the development approval pathway
• Identify specialist compliance requirements

Design

• Review architectural design against applicable BCA/NCC requirements
• Review fire safety provisions
• Review access and egress
• Review accessibility requirements
• Review health and amenity provisions
• Review energy efficiency requirements
• Identify Performance Solutions where required
• Coordinate specialist designs and reports

Documentation

• Confirm drawings and specifications are coordinated
• Obtain required engineering documentation
• Prepare relevant fire safety documentation
• Prepare access documentation where required
• Obtain Performance Solution reports where applicable
• Obtain design compliance declarations where applicable
• Maintain a record of compliance evidence

Construction

• Confirm construction follows approved documentation
• Complete required inspections
• Document approved design changes
• Check critical building elements during construction
• Verify fire safety installations
• Verify access provisions
• Address non-compliances promptly

Completion

• Complete final inspections
• Resolve outstanding compliance issues
• Obtain required certificates and reports
• Confirm required compliance declarations are lodged
• Confirm fire safety documentation is complete
• Confirm the building is ready for occupation certification

Where a BCA Consultant Can Help

A BCA consultant can independently review the building design against applicable BCA/NCC requirements and identify potential compliance issues before they affect certification or construction.

Depending on the project, this may include:

• BCA due diligence
• Design reviews
• BCA compliance reports
• Compliance audits
• Advice on Performance Solutions
• Review of existing building compliance
• Assistance with identifying issues before certification

Early review can be particularly useful where the project involves a complex building classification, unusual design, change of use, existing-building constraints or multiple specialist interfaces.

The role of a BCA consultant is not to replace the statutory role of the registered certifier. The certifier has specific legal responsibilities within the approval and certification process. Instead, independent BCA advice can help the project team identify and address potential compliance issues earlier.