NSW Building Commission Delays AS1851-2012 Implementation: What You Need to Know
NSW is one of the only States to not reference AS1851-2012 in its Building Regulations. The EP&A act had originally mandated the use of AS1851 from February 13, 2025 but this has now been deferred to February 13, 2026. This raises many questions from Facility Managers and building owners. Despite the delay, the current version remains best practice, and compliance is still essential to ensure safety and avoid legal or financial risks. This article clears up the confusion, highlights what you need to know about the delay, and offers practical steps to maintain compliance.
TL:DR – Key Takeaways
- AS 1851-2012 Remains Best Practice Despite the Delay: Following AS 1851-2012 is critical for meeting your legal obligations.
- Ignoring Compliance Can Lead to Penalties and Liability: Don’t let the delay put your buildings at risk
- Accurate Record Keeping is Essential: Document all maintenance and ensure the management of records to avoid risk and liability.
What is AS 1851-2012?
AS 1851-2012 is a key Australian Standard that outlines the required procedures for inspecting, testing, and maintaining fire protection systems and equipment. It is used by contractors, facility managers, and regulators as the benchmark for ensuring that fire systems remain functional and reliable.
For Facility Managers (FMs), AS 1851-2012 (AS 1851), covers essential systems such as:
- Fire sprinkler systems
- Fire detection and alarm systems
- Fire hydrants and hose reels
- Portable fire extinguishers
- Emergency lighting and exit signs
Compliance with AS 1851 is not just about ticking boxes—it directly impacts the safety of your building and its occupants. Additionally, many insurers and regulatory bodies require compliance as a condition of coverage or certification. Failure to comply can lead to significant fines, legal consequences, and even loss of insurance coverage.
Why the Update Has Been Delayed
According to industry experts, the delay in updating AS 1851 is largely due to push back from the industry regarding increased accountability and fines. The revised standard was initially set to be enforced on 13 February, 2025, with and 18-month transition period, but concerns over compliance costs, enforcement and confusion led to its postponement until 2026.
While the delay gives businesses extra time to adjust, it does not remove the legal responsibility to maintain fire systems. FMs and building owners should continue adhering to the 2012 version, as it remains the primary reference in Australia for safety measures maintenance.
NSW Exemption: A Critical Compliance Gap
Unlike other states and territories, NSW has not adopted AS 1851 into regulation. This raises a key question: If you’re NOT following AS 1851, what standard are you following?
Regulations still require fire systems to be maintained, but without a clear framework like AS 1851, proving compliance becomes much more difficult. Facility Managers in NSW must consider:
- How do you verify that maintenance is being done correctly?
- What evidence do you have to prove compliance in case of an audit or fire incident?
Best practice is still to follow AS 1851—even in NSW, because if something goes wrong, the standard can serve as a legal backstop and provide evidence to prove due diligence.
Who Is Responsible? Facility Managers vs. Building Owners
Building owners are ultimately responsible for compliance, while FMs are operationally responsible for ensuring fire systems are maintained. However, the standard also increases contractor accountability requiring proper documentation and reporting.
If something goes wrong—such as a fire, injury, or system failure—the records are your first line of defence. Without proper documentation, proving compliance becomes nearly impossible.
Record Keeping: A Non-Negotiable Requirement
One of the core principles of AS 1851 is accurate and comprehensive documentation. Fire protection audits and investigations rely heavily on these records to verify compliance and ensure maintenance is performed consistently and correcly.
For FMs, keeping thorough records is a safeguard against legal action or insurance disputes. Here’s how to get it right:
- Log every service and inspection — capture dates, technician details, findings, and corrective actions.
- Use digital record keeping — this reduces the risk of lost documentation and improves accessibility.
- Regularly audit your records — ensure there are no gaps or inconsistencies.
Verified’s compliance tools can help streamline this process, providing real-time tracking and automated reporting to ensure maintenance records are always audit-ready.
Next Steps for Facility Managers
- Stay the course with AS 1851 — the current standard remains best practice.
- Conduct an internal audit of your maintenance processes and documentation.
- Engage with industry bodies like Fire Protection Association Australia (FPA) and Standards Australia to stay informed on the latest changes.
- Adopt best of breed compliance solutions — digital tools can help maintain accurate records and prove compliance.
When the adoption of AS 1851 in NSW is mandated, businesses that have already established strong compliance practices will be in the best position to adapt quickly. So, for now, maintaining compliance with AS 1851 is your best strategy for mitigating risk and ensuring safety.
Remember, the delay in the regulatory reference to AS 1851 is not a reason to pause compliance efforts—it’s an opportunity to strengthen them.
When using AS 1851 ensure you and your providers are using the latest version – AS 1851-2012 Amendment 1.
Verified will continue monitoring the situation and provide updates as new information becomes available. Stay connected with your fire safety contractors and industry associations to ensure you’re always up to date. If you have any questions about compliance, record-keeping, or how to prepare for the changes ahead, call us on 1300 133 950 or send an email today. We’re always happy to share insights and help you ensure your fire safety obligations are met.