17/3/26

Episode 3: NCC 2022 Across the States: QLD, NT, WA, SA & TAS Explained (Part 1)

Episode 3

NCC 2022 Across the States: Queensland, Northern Territory, Western Australia, South Australia and Tasmania

17 March 2026 · 36 minutes · Part 1 of 2 · Hosted by Brian Haines, Matthew Graham and Andrew Hooper

Summary

The National Construction Code sets a national direction, but adoption has been anything but national. This episode works state by state through what NCC 2022 actually means on the ground, and finds a country where the same house can require seven stars, six stars, or five depending entirely on which side of a border it sits.

Part one covers Queensland, the Northern Territory, Western Australia, South Australia and Tasmania. It goes deep on the Queensland outdoor living area concession — every dimension, the fan requirements, and the design trap that catches people out — and on the state variations that quietly remove or add insulation requirements. Victoria, the Australian Capital Territory and New South Wales follow in part two.

Where each state sits

JurisdictionThermal requirementNotable variationsNational baseline7 stars for a new house; class 2 apartments average 7 with a minimum of 6Whole of Home appliesQueensland7 stars, reducible to 6.5 or 6 through the outdoor living area concessionQDC MP4.1 extends the concession beyond NCC climate zones 1 and 2 to zones 3 and 5, covering the whole stateNorthern Territory5 stars for houses, 3.5 stars for apartmentsState variation reverts to the 2009 code; no Whole of Home; no heating or cooling load capsWestern Australia7 stars from 1 May 2025; additions and alterations may use 6 stars or NCC 2019Climate zone 6 is treated as climate zone 5, removing the under-slab insulation question; variation on suspended floor insulationSouth Australia7 stars, with several defined exemptions at 6 stars under NCC 2019Mount Barker district, small blocks, irregular blocks and transportable homes; Whole of Home still applies under NCC 2022Tasmania6 starsForm 55 competent person declaration required

In this episode

  • 0:40A federation of building codes: 125 years and still not aligned

  • 1:40What NCC 2022 actually introduced, and the three compliance pathways

  • 5:10Queensland: the outdoor living area concession explained in full

  • 6:50Every dimension a compliant outdoor living area must meet

  • 7:57The U-shaped alfresco trap

  • 8:30Ceiling fan requirements, and why they are not in the NatHERS model

  • 9:23"Readily openable" has no definition — and what that means in practice

  • 11:55How the Queensland Development Code extends the concession statewide

  • 12:47Why elemental compliance drove Queensland towards NatHERS

  • 15:00It is not a bonus star: it is a top-up to reach seven

  • 15:41Northern Territory: five stars, no caps, and almost no data

  • 18:57Western Australia, and the variation that removed slab insulation

  • 21:51South Australia: Mount Barker, and complying with two codes at once

  • 23:56Small blocks, irregular blocks and transportable homes

  • 27:04The clause that leaves Victoria alone on under-slab insulation

  • 28:46Who South Australia says can certify an energy rating

  • 30:02Tasmania: still six stars, and a theory about why

  • 32:32Form 55, and what you are signing

Key points

What NCC 2022 introduced

Two core ideas. A higher thermal performance target, roughly equivalent to seven stars in a NatHERS rating. And Whole of Home: an annual energy budget covering heating and cooling, hot water, lighting and pool pumps, less any on-site renewable generation such as solar photovoltaics. The provisions apply to new houses, to apartments, and to class 4 dwellings such as caretakers' flats. Compliance can be reached through NatHERS software, through elemental provisions — both Deemed-to-Satisfy pathways — or through a performance solution, provided both the thermal requirement and the energy budget are met.

Queensland: the outdoor living area concession in full

Under NCC Specification 42, a compliant outdoor living area allows a dwelling to be assessed at 6.5 stars, or at 6 stars if that area also has a compliant ceiling fan. To qualify, the outdoor living area must have a fully covered impervious roof with R1.5 insulation to the ceiling, a minimum floor area of 12 square metres with no individual side less than 2.5 metres, and it must sit at least 900 millimetres from a boundary or obstruction such as a fence or neighbouring dwelling. The access door must be no lower than 2.1 metres and must open off a living area — not a bedroom, and not a special purpose room such as a theatre. One side must be permanently openable and another readily openable.

The design that fails without anyone noticing

The trap is the U-shaped alfresco recessed into the building. That configuration does not deliver one permanently open side plus one readily openable side. The fix is to push the alfresco roughly two and a half metres clear of the house so that two openable sides exist. Brian notes this catches a lot of people out.

The fan requirements live outside the model

To claim the additional concession the fan must be permanently installed, have a speed controller, and be a minimum of 1,200 millimetres in diameter — with a second fan required for larger outdoor living areas. None of this can be captured in the NatHERS file, because outdoor fans are not modelled. The practical advice: put the requirements on your cover sheet or notes so the builder knows what has to be installed for the rating to hold.

"Readily openable" is undefined, and that is the whole problem

There is no definition. The ABCB will refer you to the intent of the code and then to the certifier, and certifiers interpret it differently. Does a column in that side count? A 1,200 millimetre nib wall? Plantation shutters? The same ambiguity applies to the 12 square metre floor area — whether eaves count toward it depends on who you ask. The team's practical position is that a fully enclosed side will never be accepted, and everything between that and open air is a conversation with the building surveyor.

Why Queensland moved to NatHERS

Taking the concession means rolling back to the previous code version, which for the elemental pathway means using the NCC 2019 glazing calculator — a tool assessors in other states abandoned around 2010 because it is so hard to satisfy. Queensland assessors lobbied successfully to have the concession apply to elemental reports, then discovered the calculator made that route impractical anyway. The result is that NatHERS assessment, with its ability to trade one element against another, became the path of least resistance across the state.

Frame the concession correctly

A house rating 6.7 stars with the concession does not become a 7.7 star house. The concession is a top-up of up to one star to reach the equivalent of seven. As Brian puts it, do not think of it as a bonus star — think of it as being allowed to arrive at seven from below.

Two states quietly removed the under-slab insulation question

Western Australia's amendment instructs that wherever climate zone 6 appears, it is to be treated as climate zone 5 — which removes both under-slab and slab edge insulation from the requirement. South Australia took a different route to the same end, adding clause references that clarify Specification 42 applies to slab edge insulation rather than under-slab. That clarification has been carried into the draft NCC 2025, which will eventually flow through to Victoria. Until then, Victoria stands alone in requiring under-slab insulation under NCC 2022.

South Australia's exemptions are worth knowing

Ministerial Building Standard MBS 007, amendment 2, dated December 2025, part 2.2.46B, allows class 1 buildings in the Mount Barker district to roll back to NCC 2019 at six stars for the thermal requirement — while still complying with NCC 2022 for Whole of Home. In practice that means running the older NatHERS software and the older Chenath engine, then using the ABCB Whole of Home calculator separately, because a Whole of Home assessment cannot be produced from an NCC 2019 energy report. The heating and cooling load limits still apply. Similar six star rollbacks exist for small allotments with a primary street frontage of 10 metres or less, for irregular allotments under 300 square metres that cannot contain a minimum 9 metre by 15 metre rectangle beyond the primary street setback, and for transportable or manufactured homes without wheels under 70 square metres, or located in climate zone 4.

Where assessors rank in South Australia

The wording on who may certify energy efficiency compliance lists a person with the necessary skills, software expertise and knowledge — including architects, building designers, builders, building certifiers, and lastly energy assessors. The team's dry observation is that being last on that list is what happens without mandatory accreditation.

Tasmania stayed at six, and nobody is certain why

The team's theory, offered explicitly as speculation, is condensation. Reaching seven stars in a climate that cool would require insulation beyond current levels, which may raise condensation risk in a cool, wet climate. Tasmania also requires a Form 55 declaration, equivalent to the Queensland Form 15: a competent person statement recording your accreditation, the drawing numbers, versions and dates, the software and methodology used, and which parts of NCC Part 13 were applied. It must be signed, and completed per lot rather than reused per building surveyor — and in practice some relevant building surveyors request it while others never mention it.

Documents referenced

Transcript

Lightly edited for readability. Hesitations and repetition have been removed and technical terms corrected; the substance is unchanged. Part two, covering Victoria, the Australian Capital Territory and New South Wales, is Episode 4.

0:04Welcome to The Rating Room, the podcast where we unpack everything. I am Brian Haines, and alongside me are my co-hosts Matthew Graham and Andrew Hooper. Together we dive into the technical, the practical and sometimes the controversial aspects of the NatHERS scheme and everything in between. Whether you are an accredited assessor, a building designer, an energy efficiency specialist, or just trying to navigate the ever-evolving world of residential energy performance in Australia, this is the room where the ratings get real. Andrew, over to you — we are talking about jurisdictions this week.

0:40It is funny. It is 125 years this year since federation, when all the different states — or countries, as they effectively were — came together as a commonwealth. Yet we are still a nation of countries. Each state and territory has its own constitution, its own acts, its own regulations, its own laws. If I hitch my caravan up and go for a drive, I can travel at 110 in Victoria, hit New South Wales and have to drop to 100. We cannot even agree on what a potato cake is, or for some people a potato scallop. So it is no surprise that our building regulations are completely different as well.

1:32Today we are talking about NCC 2022, and a lot has changed — especially in how the states and territories are handling it. At a national level, NCC 2022 is one of the biggest shifts we have seen in maybe over a decade, and it introduces two core ideas. First, a higher level of thermal performance, roughly equivalent to seven stars in a NatHERS rating. Second, Whole of Home: an annual energy budget that looks at heating and cooling, but also covers hot water, lighting and pool pumps, minus any on-site renewables such as solar photovoltaics.

2:31The intent is fairly simple: use less energy, cut emissions, reduce peak demand, and give people homes that are more comfortable to live in. These provisions apply to new houses, to apartments, and to class 4 buildings — caretakers' flats and the like. They have climate-specific solutions rather than a one-size-fits-all recipe. In cooler climates that means better insulation and glazing; in hotter climates it leans more towards shading, ventilation and lighter colours.

3:42You can comply through different pathways. NatHERS software is one. Another is the elemental provisions — both are Deemed-to-Satisfy pathways, just different ways of getting there. Alternatively you have a performance solution, and as long as you meet both the star equivalent thermal requirement and the annual energy budget, you comply.

4:24Here is where it gets interesting: the states and territories have not all moved at the same pace over the last couple of years, and we have differences in the Australian Capital Territory, Victoria and South Australia. Maybe we go through each of the states. Let us start at Queensland.

5:10Let us start with the overarching position. Under the NCC we have to have seven stars for a new home. Additions and alterations do not really get mentioned in the NCC, so that tends to be jurisdictionally based. Apartments, or class 2, are seven stars average with a minimum of six. That is our benchmark.

5:46Queensland relies on that, but has extra requirements through the Queensland Development Code MP4.1. That is the one that gives you the one star credit if you have a compliant alfresco, which is mentioned in Specification 42 within the NCC. They adopted NCC 2022 around May 2024.

6:25There are two provisions within Specification 42 clause 2. There is a 6.5 star possible energy rating for a compliant outdoor living area with no fan, or if you have a ceiling fan in that compliant outdoor living area you can get away with six stars. But when we say compliant outdoor living area, there are very specific requirements.

6:50You are talking about a fully covered impervious roof with R1.5 to that ceiling. It has to be a minimum of 12 square metres with no individual side less than 2.5 metres, and it cannot be within 900 millimetres of a boundary or an obstruction — whether that is a side fence or a dwelling next door. The access door from that living area cannot be any lower than 2.1 metres, though do you ever have a sliding door under 2.1 metres anyway? And it has to come off a living area, but it cannot be a special purpose area like a theatre room, and obviously it cannot be off bedrooms.

7:51One of the sides needs to be permanently openable and the other side needs to be readily openable. What catches a lot of people out is that type of design where you have a U-shaped alfresco that goes into the house. That does not have one permanently open side with one readily openable side. What has to happen there is that you push that alfresco two and a half metres out from the house, and then you have a minimum of the two openable sides. You have got to be very clear on that, because a lot of people make those mistakes.

8:30With regard to the fans on that ceiling, to get the one star credit there are a few things to mention. The fan must be permanently installed and have a speed controller, and a minimum diameter of 1,200 millimetres. Depending on the size of the alfresco, the area determines whether you need one fan or two if it is quite a large outdoor living area. But not necessarily from a NatHERS point of view, because we cannot put the fans in the data when doing a NatHERS assessment. For the builder, they need to know those requirements, so I would definitely suggest putting that on your cover sheet or your notes so everybody is aware.

9:23You mentioned readily openable. Is there a definition of readily openable? You can call up the Australian Building Codes Board and ask them. No — there is no specific definition. They talk about the intent of the code. If you speak to the ABCB they will always refer back to the intent of the code, then tell you to consult the certifier, and you go and consult the certifier, and everybody has a different interpretation.

9:56Say one of those sides at 2.5 metres has a column in that area, or a nib wall 1,200 millimetres high, or shutters or plantation blinds. Is all of that readily openable? In the end it is the intent of the code, and it is somewhat up to your own interpretation — but I do not think you are going to get away with a fully enclosed side. That is never going to happen.

10:33Do you think architects and building designers have come up with a recipe to make this work? A recipe to make it work with the certifier, let us say. Some certifiers will allow some things and others will allow other things. With the 12 square metre floor area, do the eaves count in that 12 square metres? There is no real worked example you can look at.

11:05It says 12 square metres of floor area. Generally that would not include eaves — but say you poured concrete out to the eaves. What if you poured it to the fence? It is all interpretation. So where does that 12 square metres start and finish? A lot of this is really just consultation with the building surveyor, because the ABCB will not put anything in writing. It is whatever the intent of the code actually is. Sounds like we need to get a relevant building surveyor from Queensland in here.

11:55So that seven star equivalence from six and six and a half is for climate zones 1 and 2 in the NCC. But the difference is that the Queensland Development Code then says it will also apply to climate zones 3 and 5. So it is basically going all over Queensland now, which it did not before — in NCC 2019 it did not span the entirety of Queensland. Another change with NCC 2022, but it is basically a roll back of the National Construction Code.

12:32Within the NatHERS software you can choose whether you have the alfresco and whether it has the fan, and it will adjust the heating and cooling loads appropriately. You press calculate, you get six stars, and it is compliant, which is fantastic.

12:47But if you are doing elemental Deemed-to-Satisfy, you are rolling back a National Construction Code version, so you would be using the NCC 2019 glazing calculator — and that is notoriously hard to comply with. Back when the Queensland Development Code MP4.1 was a preview document and had not been released, there were no provisions for the alfresco to work with an elemental Deemed-to-Satisfy report, and local assessors were quite unhappy about that, because they would not be able to roll back an NCC version and still use elemental Deemed-to-Satisfy. They lobbied the state government, and in the end the one star credit was allowed to apply to an elemental report.

13:50What they did not realise is exactly what we said: that NCC 2019 glazing calculator is so notoriously hard to comply with. If you had been doing energy reports in Victoria or South Australia you would have dumped that calculator in 2010, because it is the same calculator — it has been the same calculator from 2010 to 2019. So you already had a decade of knowing that was never going to work. That is why there is this transition to NatHERS assessments in Queensland: it is simply the easiest way to comply, because of all the offsets you can do. Trade one element for another.

14:29What else in the Queensland Development Code comes into play? The heating and cooling loads roll back to the previous NCC version as well, and it is all in the software. Everything is applicable to class 2 as well, so you have those same offsets.

15:00The other thing builders sometimes find strange: say I rate the house and it comes out at 6.7 stars. A top-up of up to one star does not make your house 7.7 stars. It gives you the three tenths you need to achieve the equivalent of seven stars. So let us not think about it as a one star credit — think about it as an up-to-one-star top-up to achieve seven. That is really the way you need to think about it. Equivalency is the way it was worded. Equal to.

15:41If we have finished with Queensland, maybe we go across the border to the Northern Territory. That is a nice easy one. They have not upgraded and are still at five stars. Their NCC 2022 state variation takes them back to the 2009 code. So five stars for new homes, three and a half stars for apartments, no Whole of Home requirements, and that is it for them.

16:15In twenty plus years I do not think we have ever done an energy rating on a house in the Northern Territory. Do we know roughly how many houses are built there each year? In twenty-four years I did one, and that was before the client realised he did not actually need it, so it was never finished. I have no idea what happened to that project.

16:54What is interesting about looking these numbers up is that for a lot of the other states and territories, heating and cooling caps have been introduced over time. In the Northern Territory you are going to have essentially zero heating and it is all going to be cooling — but no cap, no limit. I think that is interesting, because you would all agree it is not just about achieving a six or a seven star rating. It is also about balancing that heating and cooling. That is why those load limits were introduced.

17:47I do not think there are very many at all. First of all, I am not sure there is any official total record for Northern Territory residential building permits, or that they are aggregated. I think processing is mainly by private certifiers and I do not think they have central reporting. So the only records we have may be Australian Bureau of Statistics building approvals data, or the Australian housing data for the number of certificates issued. And we do not know how many they do elementally either. Based on the Bureau of Statistics data it seems like maybe a hundred each month. Not a huge market.

18:57We will go around to the west coast. Western Australia brought in seven stars — first of May 2025. But under the amendments in the NCC they can use six stars or NCC 2019 for additions and alterations, so we have that variation happening.

19:26Like Queensland, they do have a climate zone 1, so the NCC allows for the equivalence through the outdoor room credits. I do not know how popular that is, but it applies up on the north coast around the Kimberley region, around to the Northern Territory border.

20:09There is a nice little variation. We have climate zone 6 down in the south, and climate zone 6 requires insulation under the slab — if you read the NCC the way that I do. Western Australia changed that in their amendment. They said every time you see climate zone 6, treat it as climate zone 5.

20:42Should I put my tinfoil hat on again? The rumour I was told is that they brought that in specifically to get rid of the under-slab insulation. So there is no question about whether the clause comes into play or just the edge — if it is climate zone 5, or if it is 6, just call it 5. So no slab insulation and no edge slab insulation. That would be nice if they did that in Victoria.

21:11Then there is another variation to change the insulation on a suspended floor. Everything else in Western Australia is pretty much the same. We still have the same Whole of Home requirements — meeting 60 out of 100, or 50 out of 100 for class 2. And they adopted the other requirements that came along with NCC 2022, such as Livable Housing and condensation management.

21:51Continuing anticlockwise to South Australia. South Australia has a lot of unique circumstances, and depending on what region you are in things can change. For argument's sake it is seven stars, but let me pull up one individual item. There is a South Australian Ministerial Building Standard, most recently updated December 2025 — MBS 007, amendment number two — and the specific part I want to talk about is part 2.2.46B.

22:30That is for class 1 buildings basically in the Mount Barker district. If you are building in Mount Barker you can roll back again to NCC 2019 for the house energy rating at six stars. The funny thing is that this is performance requirement H6P1, which is your six star energy rating in this case — but you still have to comply with performance requirement H6P2, which I find quite odd but sort of understandable. That is your Whole of Home. So it would be NCC 2022 for Whole of Home and NCC 2019 for the star rating.

23:11And for NCC 2019 for the star rating you have also got to comply with the heating and cooling loads. So it is not just the total load at six stars, it is also the heating and cooling loads. The way I understand it, you would have to use the older NatHERS software and the older Chenath engine, and then you are bound to use the Australian Building Codes Board Whole of Home calculator to do that assessment, because there would be no other way of doing it — you cannot run Whole of Home from an NCC 2019 energy report. A bit of a strange one.

23:56Andrew, you know about odd block sizes and small blocks and small homes. Yes — irregular shaped blocks and small blocks. They both have the same 2019 application with the 2022 Whole of Home. A small block is a frontage less than 10 metres, so that could be a battleaxe block, or one in the bowl of a court. Irregular shaped blocks are those with an area less than 300 square metres and unable to contain a minimum 9 metre by 15 metre rectangle beyond the primary street setback.

24:54Honestly, I am just glad there is a definition. That is in the ministerial guidelines — at the back there are a heap of definitions and that was one of them, because I had to go and look up what an irregular block is. It has to be able to fit that rectangle in. If it can, it is regular. If it cannot, it is not.

25:19Is that rectangle a house, or is it just a rectangle boundary to boundary? That is the definition — area less than 300 square metres and unable to contain a minimum sized rectangle. So you still have to get it in that 300 square metres too. If you had a narrow block, or a tapering block, there are going to be situations where that rectangle is difficult to fit in.

26:04The other ones are transportable homes, which again can be six star under 2019. Transportable, manufactured offsite is the wording they have used, so that can be a tiny home. The guideline says without wheels and a floor area of less than 70 square metres, and or located in climate zone 4. So they have quite a broad range of exclusions. Climate zone 4 is Ceduna, so the hotter areas heading around to the western border, and I think up to the northern border.

27:04One slight change South Australia put into Specification 42: like Western Australia, they rewrote it just enough to take out the under-slab insulation question, by adding in clause references where that is purely for slab edge insulation, where the other subclause was under-slab. So they clarified that clause in Specification 42 which has been causing confusion in other jurisdictions. Victoria is now the only one that, under NCC 2022, still requires under-slab insulation.

27:51So South Australia followed Western Australia? Not quite — Western Australia said if it is zone 6 just change it to zone 5 and take it out that way. South Australia put in extra clarification in the clause number, which is now in the draft version of NCC 2025, and will then also apply to Victoria when that comes out eventually, considering we are already in 2026.

28:20For some of those tougher climate zones like Mount Barker, you would probably need the under-slab insulation to comply regardless of whether you have the option not to put it in. Correct. And there are good reasons for under-slab insulation for what it does, but that in itself is a whole other topic.

28:46The last bit is the wording they have for who can do an energy rating, which was interesting. Energy efficiency compliance can be certified by a person with the necessary skills, software program expertise and knowledge, including architects, building designers, builders, building certifiers, and lastly energy assessors. I cannot believe we are right at the bottom of the list of people who can do an energy rating. Well, we do not have mandatory accreditation, so we are at the bottom of the list. And being a registered practitioner would be a nice thing as well.

29:32Let us leave South Australia. Where next — Victoria, Tasmania or New South Wales? Let us head down to Tasmania. We are going on holiday, so we may as well. They have a lovely new ship sitting in Geelong dock at the moment, and they are paying a fortune per month to hold it there while they build the dock. For some reason they did not build the dock before they got the ship, but that is Victoria. Tasmania is a lovely place to go though.

30:02So what is it down there? Six stars. Still six. You know this, Matthew. Yes, it is still six stars — I am just seeing whether everybody is still listening.

30:21Do you know why they stayed at six stars and did not move to seven? I have a theory. The only thing I can think of is cost implications. I actually think it might be more related to condensation. In order to get from six to seven stars in such a cool climate you would have had to increase insulation beyond current levels, and that would potentially exacerbate the risk of condensation.

30:46If it were condensation, then the condensation management requirements in NCC 2022 — you can introduce one and not the other. They could have introduced energy efficiency and not condensation management. Absolutely. But if we are all using vapour permeable barriers and we are all at R2.5 or R2.7 in the walls and R7 in the roof, I understand — but out of all the states, Tasmania is a particularly cool and wet climate.

31:46I do not see too much difference in the specification in Tasmania versus Victoria though. Maybe they just were not ready for the move from six to seven stars. Andrew, do you have any thoughts on why Tasmania stayed at six? No. Like you, I believe it is something to do with condensation and their specific climate, but I do not know the details. It is pure speculation. Or maybe they are waiting to see how it pans out everywhere else.

32:32Tasmania do have a specific requirement for energy raters though. They require a form to be completed — Form 55. What does that mean? It means you are a competent energy assessor. It is very similar to the Form 15 in Queensland; it is basically the same form.

32:59What are you saying when you sign it, and what information do you put on there? You put in your accreditation, all the drawing versions, drawing numbers and dates, what software you used or what methodology you are using to do the assessment, and all the requirements as far as NCC Part 13 goes — which parts of Part 13 you used to assess the dwelling. So it is basically for the building surveyor to know that you are a competent person and can do your job properly.

33:41Can you copy and paste? Some parts, but you are not going to be able to copy the drawing numbers or who the architect or builder was. I tried doing one document per building surveyor so I did not have to keep redoing it, but no — you have to do it for every lot number or deposited plan number. And you have to sign it, although you can sign it digitally.

34:36We did our own version, put our own logo on it and customised it to us. As long as it is as per the formal document, that is fine as well. I have done a couple of projects in Tasmania but have not always been asked to complete this form. There have been projects where the relevant building surveyor required it, and others where it was silent and simply accepted. So it is something assessors should be aware of — it should be within the document set every time.

35:08To be honest, the first one did not ask for it and the second one did, and now that I know a form is required, I cannot unknow it. So I am a little more proactive: is this form required, and here is one I prepared earlier.

35:26Is that Tasmania done? I think that is Tasmania done. So maybe we move up to Victoria — home of the potato cake, the correct terminology.

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