1. AS 1851-2012 is now mandatory for applicable NSW buildings

From 13 February 2026, the Environmental Planning and Assessment (Development Certification and Fire Safety) Regulation 2021 requires applicable essential fire safety measures in Class 1b and Class 2 to Class 9 buildings to be inspected, tested and serviced in accordance with AS 1851-2012 where the maintenance activity is covered by that Standard. A building-specific performance solution may set a different maintenance requirement.

This is not limited to new buildings. The reform applies to both new and existing buildings in NSW. For existing buildings, the NSW Government guidance says the service intervals start from the 13 February 2026 implementation date rather than forcing owners to retrospectively complete every historical long-duration service interval.

2. The Fire Safety Schedule is the starting point

The Fire Safety Schedule identifies the essential and critical fire safety measures for the building and the minimum standard of performance for those measures. Owners should use the current schedule to establish which assets are in scope and what performance standard applies.

NSW introduced a standard Fire Safety Schedule template from 1 August 2023, and an updated government template was released on 28 July 2025 as part of the continuing reforms.

3. Record keeping is no longer something to treat as an afterthought

Building Commission NSW states that owners must keep AS 1851-2012 maintenance records for at least 7 years and make those records available for inspection. Its current guidance also notes that a hard-copy logbook is required to remain on site, even where a contractor also provides electronic reporting.

For owners and facility managers, this makes the service history important in its own right: asset identification, test results, photographs where appropriate, defects, quotations, rectification and close-out should form one traceable record.

4. Baseline data matters, particularly in older buildings

Many existing buildings do not have complete design documentation or baseline data. The NSW Government guidance recognises this and says missing baseline information will commonly be recorded as a non-conformance or non-critical defect rather than automatically being treated as a critical defect.

The practical objective is to identify what information exists, record what is missing and progressively establish a defensible reference point for future inspection and testing.

5. AS 1851 servicing and the AFSS are related, but they are not the same process

An Annual Fire Safety Statement is issued by or on behalf of the building owner and confirms that each essential fire safety measure listed in the statement has been assessed by an accredited practitioner (fire safety) as capable of performing to the required standard. The statement must be provided to the local council and Fire and Rescue NSW.

Building Commission NSW specifically notes that AS 1851-2012 servicing is distinct from the AFSS assessment process. There is no blanket rule that every AS 1851 inspection and test item must be completed immediately before an AFSS can be lodged. However, an accredited practitioner may use servicing outcomes, defects and maintenance records when forming their assessment.

6. Defects need to be visible, prioritised and managed

The reform is not simply about producing more inspection reports. Owners remain responsible for maintaining their fire safety measures, engaging competent people and addressing defects appropriately. The strongest service model is therefore one that makes defects visible, distinguishes urgency and risk, tracks rectification and records the close-out.

7. A further certification reform is scheduled

NSW has also announced a further reform for newly installed fire safety measures. From 13 February 2027, or 18 months after an accreditation scheme is approved, whichever occurs first, building owners will be required to use accredited persons to certify newly installed fire safety measures before issuing the relevant fire safety certificate.

What owners should do now

  • Locate and review the current Fire Safety Schedule.
  • Confirm which listed measures fall within AS 1851-2012 routine service requirements.
  • Check whether baseline data and previous service records are available.
  • Establish a programmed inspection and testing schedule.
  • Keep the required site logbook and retain service records for at least 7 years.
  • Track defects through quotation, rectification and close-out rather than leaving them in disconnected reports.
  • Coordinate the service history with the accredited practitioner responsible for the AFSS assessment.

Official NSW fire safety resources

For building-specific advice, owners should refer to the applicable Fire Safety Schedule and speak with their council, accredited practitioner and relevant specialist contractors. The following NSW Government and Fire and Rescue NSW resources provide the current regulatory guidance:

Building Commission NSWReforms to building fire safety regulationOfficial reform timeline and commencement dates ↗ Building Commission NSWAS 1851-2012 fire safety requirementsOverview of the mandatory maintenance requirements ↗ Building Commission NSWResponsibilities of building ownersBuilding classes, records, baseline data and owner obligations ↗ Building Commission NSWGood practice guide for implementing AS 1851-2012Technical implementation guidance published in 2026 ↗ NSW PlanningFire safety certificationAFSS, supplementary statements and Fire Safety Schedules ↗ Fire and Rescue NSWLodge a fire safety statementAFSS and supplementary statement lodgement information ↗ NSW LegislationDevelopment Certification and Fire Safety Regulation 2021Current legislation ↗

Important: This article is general information only and is not legal, certification or building-specific advice. Requirements can vary according to the building's Fire Safety Schedule, approved performance solutions, original design documentation and other statutory obligations.