AFSS in NSW: What Building Owners Need to Know for 2026–2027

If you manage AFSS compliance in NSW, the requirements in 2026 are quite different from those in place only a few years ago.

The changes have been introduced in stages. Since February 2026, AS 1851-2012 has applied to routine maintenance of essential fire safety measures in Class 1b–9 buildings where the standard covers the relevant maintenance activity. Further requirements are due in February 2027.

For building owners, strata managers and facility managers, meeting the AFSS deadline is only one part of compliance. Maintenance records, practitioner accreditation, baseline data and assessment timing all need to be in order.

How the requirements have changed

February 2023

Councils and certifiers were given the ability to re-issue a Fire Safety Schedule on request to correct minor errors or replace a missing schedule. Previously, correcting an inaccurate schedule could require a development control order.

August 2023

Referral of performance solutions for Class 2–9 buildings to Fire & Rescue NSW became mandatory during the building certificate and occupation certificate stages. New Fire Safety Schedule templates also became compulsory.

Since 1 July 2020

An AFSS must be endorsed by an Accredited Practitioner (Fire Safety) recognised under the Fire Protection Accreditation Scheme (FPAS).

The current AFSS form refers to an APFS rather than the former “Competent Fire Safety Practitioner” terminology.

13 February 2026

Routine maintenance of essential fire safety measures in Class 1b–9 buildings must be carried out in accordance with AS 1851-2012 where the relevant maintenance activity is covered by the standard.

On-site logbooks are required. Where AS 1851-2012 requires a measured result, that result must be recorded. A tick or a general “satisfactory” entry is not enough.

From 1 August 2025, FPAS accreditation was also enforced for fire systems design work. New or significantly modified system designs require sign-off by appropriately FSD-accredited practitioners.

13 February 2027 or 18 months after an accreditation scheme is approved, whichever occurs first

Building owners will need to use accredited persons to certify newly installed fire safety measures before a Fire Safety Certificate is issued.

The Fire Safety Certificate will also need to include relevant information about the accredited person who carried out the certification.

What the February 2026 requirements mean on site

Since the February changes took effect, a number of recurring gaps have become apparent in buildings that updated their service agreements but have not fully adapted their records and maintenance processes to AS 1851-2012.

Measured results

A record stating “sprinkler system inspected — satisfactory” may not be sufficient.

Where AS 1851-2012 requires a measurement, the actual result needs to be recorded. Depending on the system and activity, this may include pressure readings, flow results, emergency lighting test times or other specified values.

The service record needs to show not only that the activity was completed, but also the result required by the standard.

Baseline data

AS 1851-2012 uses baseline data to compare routine service results with the expected performance of the system.

In older buildings, and in properties that have changed hands, this information is often incomplete or unavailable.

Where usable baseline data cannot be located, a new baseline may need to be established through a full performance test using calibrated equipment. This should be planned separately rather than treated as part of a routine inspection.

Logbook location

The logbook needs to be available on site for inspection.

Records held only in a contractor’s office, in a contractor-only system or at the managing agent’s premises do not meet the on-site requirement, even where the records themselves are complete.

What changes in February 2027

The 2027 requirements relate to newly installed fire safety measures, including systems installed for the first time and measures installed or significantly upgraded as part of building works.

From 1 August 2025, FPAS-accredited I&T practitioners are already required to certify newly installed fire safety measures.

From 13 February 2027, building owners must also use an accredited person to certify those measures before the Fire Safety Certificate is issued, and the certificate must include details of the accredited person.

Buildings most likely to be affected include:

• Buildings under construction that will receive a Fire Safety Certificate after February 2027

• Buildings undergoing significant fire system upgrades

• Projects adding new essential fire safety measures or extending existing systems

• Developers and builders planning works involving fire safety system installation

Existing occupied buildings that are not carrying out significant works are not directly affected by this particular change. Their annual AFSS obligations continue under the current framework.

Projects finishing around February 2027

If a project is expected to finish close to the February 2027 transition date, confirm before work begins who will certify the newly installed measures and whether that person holds the appropriate FPAS accreditation.

A project scheduled to finish in January 2027 may be delayed into March. Checking accreditation at the start of the project avoids having to resolve certification issues when the Fire Safety Certificate is ready to be issued.

Managing your AFSS cycle in 2026–2027

The annual AFSS process remains the main compliance cycle for existing fire safety measures.

There are five areas worth checking before the next assessment.

1. Check the Fire Safety Schedule

The Fire Safety Schedule identifies the essential fire safety measures in the building and the performance standard each measure is required to meet.

It determines the maintenance scope, testing and inspection requirements and the measures the APFS will assess.

If the schedule does not accurately reflect the systems installed in the building, address the discrepancy before the next AFSS cycle.

Since February 2023, councils and certifiers have been able to re-issue a schedule to correct certain errors or replace a missing schedule.

2. Check AS 1851-2012 compliance measure by measure

For every applicable essential fire safety measure on the Fire Safety Schedule, confirm that:

• Required monthly activities are being carried out

• Quarterly, six-monthly and annual activities are occurring at the correct intervals

• Actual results are being recorded where the standard requires them

• Records are complete and accurate

• The logbook is available on site

Identifying a gap before the APFS assessment gives you more time to correct it.

3. Keep the three-month APFS window in mind

Regulation 88 of the Environmental Planning and Assessment (Development Certification and Fire Safety) Regulation 2021 requires the inspection and assessment supporting an AFSS to be carried out within the three months immediately before the statement is issued.

For sites with complex systems, multiple essential fire safety measures or unresolved defects, it is sensible to allow enough time within that period for rectification and re-inspection if required.

FPAS accreditation is also measure-specific.

A practitioner accredited for extinguishers and hose reels may not hold accreditation for mechanical smoke control or VESDA.

Check the FPAA register before the assessment.

4. Resolve defects before the annual assessment

A critical defect that prevents a fire safety measure from performing its primary function cannot simply be signed off.

The measure needs to be rectified and reassessed.

If a critical defect is identified late in the three-month assessment window, there may be limited time to obtain quotes, arrange access, complete the repair and organise a re-inspection before the AFSS due date.

5. Confirm the lodgement requirements

Once completed, the AFSS must be provided to the local council and Fire & Rescue NSW, with a copy displayed in the building.

Council submission processes vary, so confirm the correct lodgement method before the anniversary date.

The issues we are seeing most often

Across Greater Sydney, several problems continue to appear in buildings that were compliant under the previous arrangements but have not fully adjusted to the February 2026 requirements:

• Service records showing that an activity occurred without recording the required measured result

• Logbooks stored off site or only inside a contractor-controlled system

• Missing baseline data for pumpset or hydrant flow testing

• APFS accreditation assumed rather than checked against the FPAA register

• AFSS assessments falling outside the three-month window because the inspection was bundled with an earlier annual maintenance visit

These issues are generally manageable when identified early.

They become more difficult when they first come to light close to an AFSS deadline, during a council audit or when documentation is reviewed as part of an insurance matter.

Frequently asked questions

Does AS 1851-2012 apply to my building?

AS 1851-2012 applies to Class 1b–9 buildings where the maintenance activity for an essential fire safety measure is addressed by the standard.

Most commercial, strata and industrial buildings in NSW with essential fire safety measures will be covered.

If you are uncertain, your Fire Safety Schedule and a qualified fire safety contractor can confirm which measures are affected.

Can my maintenance contractor sign my AFSS?

Not unless they also hold current FPAS FSA accreditation for each measure being assessed.

Routine maintenance and AFSS assessment are separate functions under NSW regulation.

The person endorsing your AFSS must be an Accredited Practitioner (Fire Safety) with current FPAS accreditation for the specific measures on your Fire Safety Schedule.

See our guide to Accredited Practitioners (Fire Safety) for more detail.

What is the penalty for not lodging an AFSS on time?

Penalty notices begin at $1,000 for the first week and escalate to $4,000 per week from week four onward.

Council can also pursue prosecution in the Land and Environment Court, where maximum penalties reach 800 penalty units for a corporation.

Separate penalties apply under the WHS Act if fire safety failures create a risk to workers or occupants.

What if my building is undergoing works that include fire system installation?

Before work begins, confirm that the contractor and certifier hold current FPAS accreditation relevant to the certification function.

From 13 February 2027, or 18 months after an accreditation scheme is approved, whichever occurs first, building owners must use an accredited person to certify newly installed fire safety measures before a Fire Safety Certificate is issued.

Relevant details of that person must also be included on the certificate.

What if I can’t find my Fire Safety Schedule?

Since February 2023, councils and certifiers can re-issue a Fire Safety Schedule to correct errors or replace a missing one.

Contact your local council or engage a Registered Certifier to request a corrected or replacement schedule before proceeding with the next AFSS cycle.

How EverSure Fire Protection supports the AFSS cycle

EverSure Fire Protection works with commercial, industrial and strata properties across Greater Sydney on AFSS compliance, including AS 1851-2012 routine maintenance, measured service records, on-site logbooks, APFS assessment by appropriately accredited practitioners, defect identification and rectification, and AFSS lodgement support.

For buildings planning fire system installations or major upgrades, we can also review the accreditation requirements associated with the February 2027 changes before work starts.

Disclaimer: This article provides general information about NSW fire safety compliance requirements as of September 2026. Regulatory requirements are subject to change. The February 2027 changes are contingent on an accreditation scheme being approved. Always verify current requirements with the NSW Building Commission and the FPAA before making compliance decisions.