Stop the Strata Compliance Domino Effect
Compliance obligations for bodies corporate and strata managers are tightening fast across Australia. This post translates new building and fire safety requirements—and the operational risks between committees, strata, building and property managers—into practical steps you can deploy this month.
1) The Situation: New Obligations + Emerging Operational Risk
This is a mix of new compliance obligations and an emerging operational risk. Regulators are lifting the bar: annual fire safety statements (AFSS) in NSW under the EP&A Regulation, occupier’s statements in QLD under the Building Fire Safety Regulation, and essential safety measures (ESM) maintenance in VIC. Insurers increasingly demand evidence of AS 1851 servicing. The risk is no longer just technical non-compliance—it’s operational ambiguity about who does what, when, and with what proof.
2) Why It Matters: The Chain Reaction When Roles Are Unclear
Consider a common moment: the committee assumes the strata manager is arranging AFSS; the strata manager expects the building manager to handle AS 1851 testing. The statement is missed. Then the dominoes fall:
- Council issues a fire safety notice and rectification deadline.
- Insurer flags heightened risk; premiums rise at renewal or coverage narrows.
- Tenant fit-out approvals stall, delaying lease commencements and cash flow.
- Committee members face personal exposure for decisions or omissions.
- Reputational damage with owners, lenders, and tenants.
In short: evolving rules + unclear delegation + no evidence trail = material operational risk.
3) First Fix: Map Every Safety-Critical Asset to Law, Frequency, and a Responsible Person
Build your obligations matrix in one sitting
- List safety-critical assets: sprinklers, hydrants, hose reels, alarms/EVAC, smoke control, emergency/exit lighting, fire doors, passive fire systems, lifts, essential services (VIC ESM), WHS risks, asbestos registers, pools, gas, pressure vessels.
- Link each asset to its legal basis: EP&A Reg (NSW AFSS), QLD Building Fire Safety Reg (occupier’s statement), VIC Building Regs (ESM), AS 1851 servicing, WHS obligations.
- Specify inspection/testing frequency and due date(s).
- Assign a single responsible person (by role, not name) and a backup.
- Decide the evidence required: certificates, service dockets, photos, commissioning reports.
Minute this matrix at the next committee meeting and circulate to all managers and contractors.
4) Clarify Roles and Delegations—On Paper
Who does what (and what they don’t)
- Committee/Owners Corporation: ultimate duty to maintain common property and ensure compliance; approves expenditure; accepts AFSS/occupier statements.
- Strata/Body Corporate Manager: facilitates compliance and record-keeping; provides advice; executes approved actions; not the default “responsible person” unless formally delegated.
- Building/Facilities Manager: oversees day-to-day operations and contractor coordination; can be delegated testing/rectification tasks.
- Property Manager/Letting Agent: not a decision-maker for common property compliance, but must report issues to tenants and coordinate fit-out conditions.
Action
- Confirm delegations in management and letting agreements; name the responsible roles for AFSS/AS 1851/ESM.
- Adopt a standing resolution: “No compliance task without a documented owner, due date, and evidence requirement.”
- Update the induction pack for contractors and remote staff to reflect responsibilities and escalation paths.
5) Create a Single Source of Truth (SSOT) Register
Ambiguity dies when the evidence lives in one place everyone can access.
What your SSOT should hold
- Certificates: AFSS (NSW), occupier’s statements (QLD), ESM annual reports (VIC).
- AS 1851 service reports and defect logs by asset.
- Contracts, scopes, and maintenance schedules.
- Risk registers: WHS hazards, asbestos reports, hot works permits, incident logs.
- Meeting minutes confirming delegations and approvals.
“Document your business or get out.”
For distributed and remote teams, clear procedures enable consistent execution. Remote workers follow instructions; systems prevent surprises. No SSOT, no assurance.
6) Run an Operational Cadence That Prevents Misses
The minimal viable rhythm
- 12-month calendar with all testing frequencies (monthly/quarterly/6-month/annual).
- Automated reminders to the responsible person and their backup 30/14/7 days out.
- Monthly compliance huddle: review upcoming tasks, open defects, and approvals needed.
- Evidence upload within 48 hours of each service; no file, no tick.
- Quarterly committee review: sign off on the matrix, budgets, and any scope changes.
Insurance-ready pack
- Maintain a rolling “pre-renewal” folder with last 12 months of AS 1851 reports, AFSS/occupier’s/ESM statements, rectification evidence, and impairment logs. This stabilizes premiums and speeds underwriting.
7) Strategic Upside: Turn Compliance Into Performance
Compliance done right lowers total cost of risk and accelerates value creation.
- Insurance leverage: clean evidence trails reduce premium volatility and exclusions.
- Capex clarity: trend defects to plan proactive renewals, not reactive call-outs.
- Tenant velocity: documented compliance speeds fit-out approvals and rent commencement.
- Governance confidence: committee members reduce personal exposure and improve decision quality.
Metrics to track
- On-time compliance rate (by asset and building).
- Defect aging and time-to-close.
- Evidence completeness score (documents on file / required documents).
- Insurance outcomes: premium delta and coverage changes year-on-year.
8) 30-Day Action Plan and Call to Action
- Build and minute the obligations matrix (assets → law → frequency → responsible person → evidence).
- Amend management/letting agreements to confirm delegations and escalation rules.
- Stand up a single-source register; migrate the last 12 months of certificates and reports.
- Launch reminders and a monthly compliance huddle; publish a one-page RACI.
- Prepare the insurance pre-renewal pack now—don’t wait for the broker’s email.
Compliance is not paperwork—it’s continuity, insurability, and trust. Start today, reduce uncertainty this quarter, and face renewal with confidence.
