How Many Accessible Hotel Rooms Do You Need? NCC Rules for Hotels and Motels in NSW
Under NCC Table D4D2b a Class 3 hotel or motel needs 1 accessible sole-occupancy unit for 1 to 10 rooms, 2 for 11 to 40, 3 for 41 to 60, 4 for 61 to 80 and 5 for 81 to 100, then more on a sliding scale. The same numbers appear in the Premises Standards. Get the count and placement right at concept stage so the floor plan and room mix do not have to be redrawn later.
Is your building Class 3, Class 1b or Class 2?
Class 3 includes the residential part of a hotel, motel, boarding house, guest house, hostel or backpackers. Class 1b covers a small guest house (not more than 300 m² and not more than 12 residents) or 4 or more single dwellings on one allotment used for short-term holiday accommodation. For the latter, Table D4D2a sets the number of accessible dwellings. Serviced apartments and aparthotels can be Class 2 or Class 3 depending on the approved use; confirm the classification with the principal certifier. See SDA building types and NCC classification for how classification works, and change of use and fit-out access NSW for conversions.
The accessible room numbers: Table D4D2b
Table D4D2b (NCC 2022 Amendment 2, confirmed against the ABCB text) sets the minimum number of accessible sole-occupancy units in a Class 3 or Class 9c building:
| Total number of sole-occupancy units | Number required to be accessible |
|---|---|
| 1 to 10 | 1 |
| 11 to 40 | 2 |
| 41 to 60 | 3 |
| 61 to 80 | 4 |
| 81 to 100 | 5 |
| 101 to 200 | 5 sole-occupancy units plus 1 additional for each additional 25 units or part thereof in excess of 100 |
| 201 to 500 | 9 sole-occupancy units plus 1 additional for each additional 30 units or part thereof in excess of 200 |
| More than 500 | 19 sole-occupancy units plus 1 additional for each additional 50 units or part thereof in excess of 500 |
Worked examples:
- 30 keys: 2 accessible rooms.
- 120 keys: 5 + 1 (20 over 100 counts as one part of 25) = 6.
- 150 keys: 5 + 2 (50 over 100) = 7.
- 250 keys: 9 + 2 (50 over 200 is one full 30 and part of another) = 11.
For Class 1b short-term holiday accommodation on one allotment, Table D4D2a applies: 4 to 10 dwellings require 1 accessible dwelling, 11 to 40 require 2, and so on, with further increments for larger numbers. Verify the exact wording in the current NCC edition that applies to the certificate.
Where the accessible rooms can go: the three distribution rules
In a Class 3 building, no more than 2 required accessible sole-occupancy units may be adjacent to each other. Where more than 2 are required, they must be representative of the range of rooms on offer, taking into account amenity, views, proximity to features and pricing. Where there is more than one accessible sole-occupancy unit, the sanitary facilities should alternate between left-hand and right-hand layouts. Suites, view rooms and connecting rooms all affect both revenue and compliance, so settle the mix early. See the ABCB Guide to D4D2 for the representative-room example.
Common areas: what else must be accessible (D4D2(5))
From an accessible pedestrian entrance there must be access to at least one floor containing sole-occupancy units and to each sole-occupancy unit entrance on that floor. There must also be access to and within at least one of each type of common room or space used by guests, such as a pool, gymnasium, sauna, dining room, laundry, lounge or shop. Where a lift or an AS 1428.1 ramp is installed, every level it serves must be accessible. Public-area sanitary facilities, accessible car parking and hearing augmentation are covered by other clauses. See accessible car parking NSW and disabled toilet regulations NSW. NSW building work is currently assessed against NCC 2022 Amendment 2 until 1 May 2027.
Inside the accessible room: AS 1428.1 essentials
Door clear width and circulation space, bedside circulation, an ensuite that meets AS 1428.1, switch and control heights, luminance contrast, and visual or vibrating alarms for guests who are deaf or hard of hearing. See door circulation space AS 1428, luminance contrast AS 1428, and visual alarm systems.
Refurbishing an existing hotel, motel or pub with rooms
The Premises Standards affected-part rules and any upgrade triggers still apply. Existing accessible rooms may count if they remain compliant. Unjustifiable hardship is a last resort, not a design choice. Performance Solutions can address heritage or structural constraints that block a Deemed-to-Satisfy layout. See existing building access audit NSW, unjustifiable hardship NSW, and what is an NCC Performance Solution.
NCC 2022 or NCC 2025?
ABCB shows the same Table D4D2b and notes in both the 2022 and 2025 editions. In NSW the edition that applies is NCC 2022 Amendment 2 until NSW adopts NCC 2025 on 1 May 2027. Name the edition in the access report and confirm it with the principal certifier.
What a hotel access report covers
Key-count check against Table D4D2b, distribution review on plans, common-area path of travel, parking, sanitary facilities, hearing augmentation, a DA-stage statement, and a construction-certificate stage Deemed-to-Satisfy or Performance Solution report. Sydney Access Consultants is an ACA Accredited Member 435. Practice work concentrates on Cronulla, Sutherland Shire and Hurstville / Georges River, with Mid North Coast support from Sandy Grey at Black Beach and coverage in Perth / Western Australia. See access reports for DA, CC and CDC, DA versus CC access report, and what certifiers want in an access report.
Frequently asked questions
How many accessible rooms does a hotel need in Australia?
Under NCC Table D4D2b a Class 3 hotel or motel needs 1 accessible room for 1 to 10 rooms, 2 for 11 to 40, 3 for 41 to 60, 4 for 61 to 80 and 5 for 81 to 100. Between 101 and 200 rooms, add 1 for every 25 rooms or part over 100, so a 120-room hotel needs 6. The Premises Standards contain the same table.
Can all the accessible hotel rooms be grouped together?
No. In a Class 3 building no more than 2 required accessible rooms can be next to each other. Where more than 2 are required they must represent the range of rooms on offer, including views, amenity and price. Where there is more than one accessible room the bathrooms should alternate between left-hand and right-hand layouts.
Do the pool, gym and restaurant in a hotel need to be accessible?
Yes. NCC D4D2(5) requires access to and within at least one of each type of room or space used in common by guests, such as a pool, gymnasium, sauna, dining room or lounge. It also requires access from an accessible entrance to at least one floor of guest rooms. Every level served by a lift or accessible ramp must also be accessible.
Fixing your key count or room mix? Call Sydney Access Consultants on (02) 9586 3111 for a fee proposal or quote on a hotel access review.
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