Access Reports for Apartment Buildings in NSW: What Your DA and CC Need
Most NSW councils and certifiers expect an access report for a residential flat building or shop-top housing project at DA stage, and a more detailed one at construction certificate. The report has to cover three things with different legal force: NCC Volume One Part D4 common-area access (binding at CC), the Apartment Design Guide universal design benchmark (weighed at DA), and the council DCP adaptable housing percentage. Inside the apartments the NCC access provisions do not apply. The Silver and adaptable features come from planning controls.
The short answer: what the access report must cover for a Class 2 building
- Path from the allotment boundary to the entrance (D4D3).
- Common areas per D4D2(4): to at least one floor of units and every unit entry door on that floor, at least one of each type of common room, and every level the lift or AS 1428.1 ramp serves.
- Passenger lifts (E3D7 and E3D8).
- TGSIs, signage and glazing (D4D9, D4D7, D4D13).
- Apartment Design Guide 4Q Silver units.
- DCP adaptable units with pre- and post-adaptation plans.
- Any parking the DCP allocates to adaptable units.
Which rule, which stage, what force
| Rule | Source | Legal force | Assessed at | What the report shows | Common RFI |
|---|---|---|---|---|---|
| NCC D4D2(4) common areas | NCC 2022 Vol One (NSW until 1 May 2027) | Mandatory (DtS or Performance Solution) | CC (signalled at DA) | Accessway to one unit floor, every unit door on that floor, one of each common room type, every level served by the lift | Common rooftop not shown as accessible |
| ADG 4Q-1 (20% Livable Housing Silver benchmark) | Apartment Design Guide Part 4, via Housing SEPP Chapter 4 | Design guidance, a matter for consideration | DA | Unit schedule of Silver units, LHA Silver elements on plans | Schedule does not identify Silver units |
| ADG 4Q-2 adaptable per council policy, plus DCP AS 4299 percentage | Council DCP | DCP control; not displaced by the ADG | DA, then CC | Nominated units, Class C pre- and post-adaptation layouts | No post-adaptation plans |
| Premises Standards | Disability (Access to Premises — Buildings) Standards 2010 s2.1 | Apply to a new Class 2 only if short-term rent accommodation is available; never to SOU interiors | CC | Statement of whether the trigger applies | Report cites Premises Standards without saying why |
| Mixed-use parts (retail, commercial, childcare at ground) | NCC D4D2(6), Premises Standards | Mandatory for those classes | DA and CC | Separate assessment per class | Retail tenancy not assessed |
NSW building work is currently assessed against NCC 2022 Amendment 2 until 1 May 2027. See NCC 2025 adoption in NSW.
What the NCC requires in a Class 2 apartment building
Common areas only, not apartment interiors. From an accessible pedestrian entrance there must be access to at least one floor containing sole-occupancy units and to the entrance doorway of each unit on that floor. There must be access to and within at least one of each type of common room or space. Where a lift or AS 1428.1 ramp is installed, every level it serves must be accessible. A rooftop tennis court or spa used only by a penthouse does not have to be accessible. A common rooftop for all residents on a lift-served level does. Entrances follow D4D3: accessway from the main points of pedestrian entry at the allotment boundary and from any required accessible car parking; the principal pedestrian entrance; at least 50% of entrances. Lifts, corridors and turning spaces follow D4D4 and E3D7/E3D8. D4D6 lists no accessible parking rate for Class 2 itself; counts usually come from the DCP or mixed-use classes. See NCC Part D4 access guide and accessible car parking NSW.
The ADG 20% Livable Housing Silver benchmark: mandatory or not?
Objective 4Q-1 design guidance states that developments achieve a benchmark of 20% of the total apartments incorporating the Livable Housing Guideline’s silver level universal design features. The 1 July 2026 Practice Note “Using the Apartment Design Guide” says the ADG is to be applied as a guide, not as development standards, unless explicitly required by Chapter 4 of the Housing SEPP. If a proposal does not meet the design criteria, the consent authority considers whether the alternative approach achieves the objective. In practice, councils still ask for the 20% benchmark and consent conditions often impose it. Plan for it unless your planner has a reasoned alternative. Do not confuse the Livable Housing Design Guidelines (LHA Silver/Gold/Platinum) with the NCC Livable Housing Design Standard. NSW has not adopted the NCC livable housing provisions. See livable housing and livable housing design NCC 2022. Sydney Access Consultants assesses designs against the LHA Silver elements as part of the access report. We do not hold Livable Housing assessor registration.
Adaptable housing (AS 4299): your council sets the number
There is no statewide percentage. The DCP sets it. Universal design and adaptable housing are not on the Housing SEPP list of matters where the ADG overrides a DCP. The DCP control still bites. See adaptable housing for Class C essentials. Silver and adaptable units can overlap. The access report should schedule them separately so the certifier can tick each one.
Do the Premises Standards apply to apartments?
Default: no. Class 2 is not covered. The exception is a new Class 2 building with accommodation available for short-term rent (serviced apartments or a short-stay component). Then the Standards apply, but still not inside the sole-occupancy units. The Disability Discrimination Act still applies generally. Mixed-use ground floors (shops, cafés, childcare) are Class 5, 6 or 9b and are fully covered. See what certifiers want in an access report.
DA report versus CC report for an apartment project
A DA report tests capability: can the scheme comply, are the Silver and adaptable units identified, is there a continuous accessway, and does the lift serve the common levels? A CC report covers construction detail: door hardware and circulation, TGSIs, handrails, luminance contrast, signage, sanitary facilities in common areas, and lift car specification. Many DA reports state they are not for CC use. See DA versus CC access report and access reports for DA, CC and CDC. A Performance Solution may be needed on a sloping site where the boundary-to-entrance accessway cannot meet AS 1428.1 ramp limits, or where a rooftop common area is reached by a stair only. See performance solutions and what is an NCC Performance Solution.
Common apartment access issues at RFI stage
- Unit schedule does not flag Silver and adaptable units.
- No post-adaptation plans for AS 4299 units.
- Common rooftop or communal open space served by stairs only.
- Accessway from the boundary relies on the driveway.
- Basement lift lobby doors fail circulation. See door circulation space AS 1428.
- Report cites the Premises Standards with no trigger analysis.
- Mixed-use retail tenancy left out of the report.
These are typical compliance points rather than specific project examples.
How Sydney Access Consultants prepares apartment access reports
Scope includes DA access reports, CC access reports, Performance Solutions where needed, and design-stage mark-ups with the architect. SDA apartments are a separate product. See SDA certification. 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 locations.
Call Sydney Access Consultants on (02) 9586 3111 for a fee proposal for your scheme.
Frequently asked questions
Does an apartment building in NSW need an access report, and at which stage?
Most councils and certifiers expect one at DA and a more detailed one at CC. The DA report shows capability against NCC common-area rules, the ADG benchmark and the DCP adaptable percentage. The CC report covers construction detail.
What does the NCC actually require for access in a Class 2 building?
Common areas only: from an accessible entrance to at least one floor of units and every unit entry on that floor, at least one of each type of common room, and every level served by a lift or accessible ramp. Inside the sole-occupancy units the NCC access provisions do not apply.
Is the 20% Livable Housing Silver benchmark mandatory in NSW?
It is design guidance in the Apartment Design Guide, not a strict development standard unless the Housing SEPP explicitly requires it. Councils still ask for it and conditions often impose it. Plan for the benchmark unless a reasoned alternative achieves the objective.
How many adaptable (AS 4299) units do I need?
The council DCP sets the percentage. There is no statewide number. The access report should include pre- and post-adaptation plans for the nominated units.
Do the Premises Standards apply to apartments?
Generally no. They apply to a new Class 2 building only if accommodation is available for short-term rent, and even then not inside the sole-occupancy units. Mixed-use ground floors are covered separately.
Does a rooftop terrace, gym or pool have to be accessible?
If it is a common space used by all residents on a lift-served level, yes. A space used only by a single penthouse does not.
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