Australia’s building code is set to undergo substantial change, with significant amendments set to be proposed in the 2025 update of the National Construction Code (NCC 2025).

But the changes will be less disruptive compared with those that were introduced in the previous updating cycle of the Code in 2022.

During an interview with Sourceable, Gary Rake, Chief Executive Officer of the Australian Building Codes Board (ABCB), has outlined the main areas where significant change is set to be proposed in NCC 2025.

This comes as the ABCB prepares to release the Public Comment Draft for NCC 2025 on May 1.

According to Rake, proposed changes in NCC 2025 are significant but will not involve the same level of disruption for practitioners as was the case with those that were incorporated into the 2022 update of the Code (NCC 2022).

Those changes in NCC 2022 included new requirements for accessible housing, a significant upgrade to energy efficiency requirements in residential premises and a significant renumbering exercise to ensure a consistent structure throughout the Code’s three volumes.

“I think the first thing to recognise is that NCC 2022 was by all accounts the biggest single update to the National Construction Code since its inception,” Rake told Sourceable.

“There has been a lot (in NCC 2022) for industry and practitioners to get their heads around. This includes the big topics like energy efficiency, accessible housing or even the renumbering for a new consistent volume structure.

“For those practitioners who had come to memorise the particular provisions they used regularly, they had to learn a new system (with the renumbering).

“So what industry can expect to see for NCC 2025 is less complexity in the change. There are still a few sizable reforms, but they are not going to be as disruptive as the main big changes that came through in 2022.”

Rake’s comments come as the Public Comment Draft for NCC 2025 is set to be released on May 1.

The NCC is a three-volume set of documents which sets out Australia’s primary design and construction provisions and requirements for buildings. The Code sets out minimum requirements for levels of safety, health, amenity, accessibility and sustainability that new buildings are expected to deliver.

The Public Comment Draft will include the changes which are proposed to be incorporated into NCC 2025.

Also released at the same time as the Draft will be modelling that will estimate the economic impact of proposed changes in respect of four areas. These are commercial energy efficiency, waterproofing, condensation and provision of toilet and sanitary facilities (see below).

Context of Changes

Asked about the context of the latest update, Rake says that the ABCB has undertaken extensive consultation since December to hear from industry and stakeholders in order to relay these viewpoints back to Commonwealth and State building ministers.

A significant theme to come from this is that industry would like more support to help members and practitioners to understand Code changes and be able to adopt these with minimal disruption.

Toward that end, the ABCB has openly shared important changes which are expected in the Public Comment Draft.

Rake says that such a process has helped to promote open and constructive engagement.

In light of current housing challenges, meanwhile, ministers have asked the ABCB to be cautious about any proposed changes which could impact new housing delivery.

As a result, significant changes have been recommended only where these are considered to be necessary and are expected to deliver substantial benefits.

Six Main Areas of Change

As outlined below, significant proposed changes revolve around six areas.

Some of the more modest changes have arisen out of suggestions raised by industry practitioners, stakeholders and members of the public via submission of proposals for change. These include refinements for definitions along with new performance and deemed-to-satisfy provisions that will aid Code compliance.

Other proposed amendments have arisen out of work that the ABCB has been authorised to undertake by state, territory and Commonwealth building ministers in order to develop solutions to address significant areas of concern.

The six main areas of change will involve:

• Implementing the next stage of tighter energy efficiency requirements for commercial buildings and the common areas of Class 2 apartment buildings.
• Changes to reduce the incidence of water leaks and ingress into apartments and commercial buildings.
• Additional changes that build on previous code amendments to further reduce the risk of condensation in new buildings.
• Increasing the provision of toilets for women at single auditorium theatres and cinemas.
• Tighter fire safety requirements for carparks.
• Removing the potential to use expert judgement as a pathway through which compliance with the performance requirements of the Code can be assessed in respect of matters concerning structural or fire safety.

Arguably the most significant area of change surrounds commercial energy efficiency.

In NCC 2025, the ABCB proposes to implement the next stage of reform based on the Trajectory for Low Energy Buildings that was agreed to by Commonwealth and state and territory Governments in 2019.

Under that policy and subsequent decisions, it was envisaged that energy efficiency requirements would be progressively tightened in respect of both commercial and residential buildings in alternate cycles.

As a result, substantial upgrades in respect of commercial buildings were included in the 2019 update of the Code whilst upgrades to residential energy efficiency were incorporated into NCC 2022.

In NCC 2025, it is the commercial sector’s turn again.

In the current update, the ABCB has opted for a bold approach and proposes that all new commercial buildings constructed under NCC 2025 will be ready to accommodate a net zero future and full electrification.

Options to use other energy sources such as gas will still be available. However, emissions from these will need to be offset through onsite generation.

Specific measures will include:

• changes to thermal performance requirements to ensure that adequate modelling of heat gain and loss through glass walls, ceilings and other external surfaces has been undertaken
• requirements for the uptake of on-site energy generation such as solar panels; and
• provisions to ensure that there is the ability to replace any gas appliances which need to be used with electric appliances at the end of their useful life.

On the last point, Rake says these provisions are about future-proofing commercial buildings to ensure that they are ready to accommodate a net zero and all-electric future.

In cases where a gas heating system is used, for example, it will be necessary to allow sufficient space in the plant room to enable installation of an electric heating system in the future once the gas system reaches the end of its useful life.

According to Rake, benefits of these measures will be substantial.

Modelling which is set to be released with the Public Comment Draft indicates that changes in this area are likely to deliver gross benefits of $17 billion for the Australian economy.

At the same time, the changes will deliver commercial buildings which are constructed in a manner which is consistent with meeting Australia’s domestic and international climate-related targets and objectives.

Moreover, Rake says that the new provisions will enable the commercial building sector to take one large step forward in terms of net-zero preparedness.

This will deliver certainty and will avoid the ongoing disruption which can be associated with delivering changes over multiple stages.

(Under the proposed changes, all new commercial buildings constructed under NCC 2025 will need to be ready for a net zero and all-electric future.)

Next, the Public Comment Draft will propose changes to waterproofing requirements that will reduce the incidences of water leakage which flows from the outside into buildings.

In particular, the changes focus on apartment complexes. They aim to address leaks which occur from horizontal surfaces such as flat roofs, balconies and podiums.

Under the proposed new requirements, a fall in substrate will be required for surfaces consisting of concrete or cement sheeting to ensure that water drains away from inside areas.

The aim is to ensure that water which falls onto areas such as balconies is collected, redirected away from the building and drained.

The magnitude of the fall will be relatively modest and will equate to a fall of about one in 100 (approximately 1 cm per meter).

As a result, the fall will be unnoticeable to building occupants and will not create any hazards associated with slips, trips or falls on balconies.

For many systems which have a floating paved surface, the fall will occur within the substrate whilst the pavers will sit virtually level on top.

According to Rake, this measure will help to reduce the likelihood and extent of damage which may occur even when other waterproofing protections such as membranes fail. It will ensure that water is not able to sit for long enough to create problems.

Rake says that the benefits of this change should not be underestimated.

Granted, the reform will add approximately $900 per dwelling to the up-front cost of delivering new apartments.

However, it will avoid water leaks which on average have a cost of between $2,000 and $11,000 to rectify.

This is significant as Rake says that water leaks generally occur in between 20 and 40 percent of apartments nationwide.

(to avoid leaks from balconies, podiums or flat roofs, a fall in substrate will be required for surfaces consisting of concrete or cement sheeting to ensure that water drains away from inside areas)

Next, the Public Comment Draft will include some relatively modest amendments to provisions regarding the prevention of condensation.

This represents a response to industry concerns about the need to avoid creating condensation as the airtightness and thermal performance of buildings continues to improve.

Specific provisions which are proposed vary according to climate zones. This is important as condensation most commonly occurs on the outside of buildings during warmer and more humid months in warmer climate zones but is more likely to occur on the inside of buildings during cooler times of the year in cooler climate zones.

Changes will be relatively modest and will be able to be implemented with only a small additional cost.

However, Rake says they will make an important difference particularly in cooler climates – where the key benefit be a reduction in the risk of mould and resultant health risks.

Next, the Public Comment Draft will contain two changes in respect of provision of toilets and sanitary facilities for women.

One area of change aims to reduce the incidence of women needing to wait in queues for long periods to use the bathroom in entertainment venues which have a single auditorium.

Specifically, the changes will increase the ratio of female toilets which need to be provided relative to male toilets from 1.25 to one to 1.8 to one.

The effect of this will be to increase the number of toilets which are provided for women and to reduce queuing time for women before shows, during intermissions and after performances.

As things stand, research shows that women can be forced to wait up to fourteen minutes during peak times at cinemas which meet current NCC requirements.

No changes will be made in respect of provision of toilets for men and the provision of male toilets will not be affected or reduced in any way as a result of this change.

The second change in this area will apply to all commercial buildings.

Under existing requirements, toilets are required to have facilities for the disposal of sanitary items.

Under NCC 2025, the Public Comment Draft will propose that facilities will also be required for the dispensing of sanitary items.

This will be important from the viewpoint of public health, hygiene and facility management.

In the same way as bathrooms are required to provide handwashing facilities and toilet paper, facilities will also need to be provided for the dispensing of sanitary items.

Fifth, the Public Comment Draft will include proposed amendments in terms of fire safety for structured carparks.

These will involve an increased fire resistance level, sprinkler protection in all car parks which cater for 40 or more vehicles and sprinkler protection for any car stackers which stack two vehicles vertically within the one car parking space.

The changes will apply to structured carparks. These include basement carparks which are part of office buildings, shopping centres and apartment complexes as well as open-air structured carparks such as those which might be seen in airports or in multi-level carparks at train stations.

Interestingly, the need to tighten requirements in this area is being driven by changes in the size and flammability of vehicles as well as evolving ways in which carparks are being used.

This is not directly related to electric vehicles, but rather to the increasing popularity of larger vehicles such as larger utes and SUVs.

Irrespective of whether they are fuelled by liquids or batteries, vehicles nowadays are being constructed with greater volumes of plastic and are thus becoming increasingly more flammable.

At the same time, carparks are increasingly incorporating bicycle storage, change rooms and shower facilities.

This means that people are spending more time within car parks at the same time as the fuel load within these carparks is increasing.

The changes will also remove concessions and exemptions which have previously been afforded to open deck carparks.

Instead, the new Draft is adopting the position that all car parking structures need to be carefully managed with fire safety in mind.

This is particularly the case following recent fires which have occurred in open-deck carparks at airports in the US and UK.

(new fire safety requirements will apply to structured carparks)

Finally, the Public Comment Draft will propose the removal of the ability to use ‘expert judgement’ as a means of assessing whether or not performance solutions meet the relevant NCC performance requirements in relation to matters which concern either structural or fire safety within buildings.

Under the current situation, the Code allows for four methods to be used in order to assess whether or not a proposed performance solution satisfies relevant Code requirements.

In NCC 2025, however, the Public Comment draft will include proposed changes that will remove the ability to use expert judgement in respect of matters which concern either structural integrity or fire safety.

This has occurred as concern has grown over recent years that ‘expert judgement’ is not a sufficiently robust method to verify Code compliance.

This change will not prevent experts from developing performance solutions. However, for matters such as structural and fire safety, the ABCB believes that compliance should be demonstrated through clear methods, evidence and/or documentation.

What Building Practitioners Should Do Now

Asked how practitioners should go about providing feedback and preparing themselves for the changes, Rake encourages four actions.

These are:

• going to the ABCB web site and registering for seminars or webinars to be held through May and June to hear about the proposed changes
• viewing the proposed changes which will be available from the ABCB web site on May 1 (these will be available in an easy summarised form so as to enable practitioners to see the areas which are changing)
• providing comments on potential for improved drafting – particularly in respect of proposed changes which may be unclear or confusing or may have the potential to be misread (consultation is open from May 1 until July 1); and
• focusing any feedback on existing proposed changes rather than proposing new or further changes.

On the last point, Rake says the opportunity to propose new changes occurred earlier on in the NCC updating cycle and has now passed in respect of the 2025 update.

Accordingly, any feedback should focus on those changes which have already been proposed and have been included in the Draft.

Enjoying Sourceable articles? Subscribe for Free and receive daily updates of all articles which are published on our site

Want to grow your sales, reach more new clients and expand your client base across Australia’s design and construction sector?

Advertise on Sourceable and have your business seen by the thousands of architects, engineers, builders/construction contractors, subcontractors/trade contractors, property developers and building industry suppliers who read our stories across the civil, commercial and residential construction sector