Licensing requirements for building professionals under AS 1851-2012
From 13 February 2026, all class 1b and class 2 to class 9 buildings in NSW must inspect and test essential fire safety measures in accordance with AS 1851-2012 (unless there is a performance solution in place).
Building owners should be aware of the licensing requirements of building professionals inspecting and testing fire protection systems under AS 1851-2012.
Key information
Australian Standard AS 1851-2012 sets the requirements for the routine service of fire protection systems and equipment. In NSW, the 2012 version of the standard (including all amendments) is applicable.
From 13 February 2026, all class 1b and class 2 to class 9 buildings in NSW must inspect and test essential fire safety measures in accordance with the standard. The requirements are set out under Section 81 and Section 81A of the Environmental Planning and Assessment (Development Certification and Fire Safety) Regulation 2021.
There is currently no one set of comprehensive licensing or accreditation schemes that authorise a person to do work related to AS 1851-2012. Some of the work may not necessarily require a licence.
It is also acknowledged that AS 1851-2012 is structured in a manner that is consistent with how the fire protection industry categorises work and this does not align with the current licensing categories.
Requirements under the Home Building Act
The Home Building Act (HBA) covers residential building work as well as all specialist work. It is important to note that the HBA applies to all specialist work, even if the work is not inside a residential building, such as a standalone office building.
Types of specialist work
Specialist work is defined under Schedule 1 of the HBA as:
- plumbing and drainage work, other than roof plumbing work
- mechanical services and medical gas work
- medical gasfitting work
- medical gas technician work
- gasfitting work
- electrical wiring work
- any work declared by the regulations to be refrigeration work or air-conditioning work.
Find out more about specialist trade work.
Contract requirements
By law, builders and tradespeople must provide a written contract for residential building work if:
- the contract price is over $5,000 (including GST), or
- the price isn’t known but the reasonable market cost of labour and materials exceeds $5,000.
This includes specialist work.
Specialist trades do not need to comply with the contract requirements of the HBA if they are working on a building that is not a dwelling (e.g. an office building).
Unlicensed contracting
Section 4 of the Home Building Act does not allow unlicensed contracting. This means that you cannot enter into a contract to do work with the intention of sub-contracting parts of the work out that you are not licensed to do.
This does not apply to a person or company with a builder’s licence.
Types of work covered under AS 1851-2012
AS 1851-2012 is an inspection, testing and maintenance standard. Generally, inspection type work which involves only visual inspection would not be considered residential building work or specialist work.
Testing type work is not considered residential building work and does not need to be done by a person with a licence. The exception to this is mechanical services work because the definition of mechanical services work includes testing.
Maintenance type work where the building is physically altered is considered residential building work if it is part of a contract where the commercial value exceeds $5,000.
Contract splitting to reduce the contract value
The Home Building Act does not allow for contract splitting and there could be significant penalties for engaging in contract splitting.
For example, if the work involves inspection based activities and maintenance type activities on the same item which together amounts to over $5,000, the contract cannot be split.
Example
AS 1851-2012 requires fire shutters to be inspected and if a fusible link is older than 25 years old, the fusible link must be replaced. The contracts for the inspection and replacement of the fusible link cannot be split into 2 contracts. This is because the 2 contracts would be substantively about only one piece of work.
Note: this only applies to work in a residential building or a building with a residential part.
Contract splitting to multiple trades
It is acceptable to contract split if the work involves multiple trades. Alternatively, the building owner can engage a builder who can then subcontract to each qualified trade.
Maintenance type activities not covered by AS 1851-2012
Maintenance and repair type activities not covered by AS 1851-2012 are treated the same as any other building work.
If the work occurs in a residential building, then it is considered residential building work. The work may also be specialist building work requiring a specialist licence.
If the work does not occur in a residential building and it is specialist work, then it must be done by someone with a specialist licence.
Work that is not specialist work and not in a residential building is not covered by the HBA and can be done by anyone.
Responsibilities of building owners
AS 1851-2012 mandates that the routine service of fire protection equipment must be done by a competent person. In NSW, there is no single licence category which directly aligns with each category of fire protection equipment. Building owners must individually assess the competency of each contractor.
Compliance with AS 1851-2012 is assigned to the building owner and therefore, any fines will be paid by the building owner. Building owners may be able to assign or apportion some or all fines to the contractor that was engaged depending on the specific commercial arrangement entered into. However, they must first seek their own legal advice on this.
Licensing and recommended competencies for each category of work in AS 1851-2012
AS 1851-2012 has 13 categories of fire safety measures, each with specific inspection, testing and maintenance schedules. The following section nominates the requirements for licensing and suggested competencies for each category.
Where a licence category is nominated, the person doing the work must have that licence to contract to do the work, or, have a general building licence who then sub-contracts to the applicable licence.
The recommended unit of competency is a suggested qualification the person should have to demonstrate they are suitably qualified. The list of competencies is not exhaustive and is meant as a guide only.
For works over $5,000, a builder's licence is required if the work is classified as residential building work under the Home Building Act.
Inspection and testing type work that is not specialist work is generally excluded from the definition of residential building work but maintenance type work is included.
This section covers:
- Wet pipe systems
- Dry pipe systems
- Deluge and water spray systems
- Pre-action systems
Required licence
Inspection and testing work do not require a licence.
The following licences are required when physical work is being done to the system (for example, changing a part):
- Plumbing, or
- Water plumbing or
- Water plumbing – fire protection systems or
- Water plumbing – Fire sprinkler systems.
Recommended units of competency
- CPCPFS3040 Conduct basic functional testing of water-based fire-suppression systems
- CPPFES2047 Inspect and test control and indicating equipment
- CPCPFS3042 Conduct annual routine service of complex water-based fire-suppression system
- CPCPFS3043 Conduct functional water flow testing.
Note: CPCPCM2043 Carry Out WHS Requirements, is a pre-requisite for CPCPFS3042 and CPCPFS3043.
Required licence
There is no applicable licence category for this work. However, works which require physical work to be done to the fire pumpset is considered residential building work requiring a builder’s licence if the work exceeds $5,000 in value and is in a residential building.
Recommended units of competency
Certificate III in Fire Protection, or Certificate III in Fire Protection – Inspection and Testing, or any engineering or construction or automotive related Certificate III, plus the following units of competency:
- CPCPFS3041 Inspect and test fire pumpsets.
Required licence
Inspection and testing work do not require a licence.
The following licences are required when physical work is being done to the system (for example, changing a part):
- Plumbing or
- Water plumbing or
- Water plumbing – fire protection systems.
Recommended units of competency
Certificate III in Fire Protection, or Certificate II in Fire Protection – Inspection and Testing, or any engineering or construction or automotive related Certificate II or higher, plus the following units of competency:
- CPPFES2037 Inspect and test fire hydrant systems
- CPCPFS3043 Conduct functional water flow testing.
There is no unit of competency for 5 yearly testing.
Required licence
The following licences may be required when physical work is being done to the system, otherwise, no licence is applicable.
- Plumbing or
- Water plumbing or
- Water plumbing – fire protection systems.
Recommended units of competency
There are no units of competency for this.
Required licence
There is no applicable licence category for this work.
Recommended units of competency
Certificate II in Fire Protection – Inspection and Testing, or any engineering or construction or automotive related Certificate II or higher, plus the following units of competency:
- CPPFES2047 Inspect and test control and indicating equipment
- CPPFES2029 Conduct functional tests on fire detection, warning and intercommunication devices
There is no unit of competency for 5 yearly testing.
This section covers gaseous, aerosol and open nozzle water mist special hazard fire suppression systems.
Required licence
The following licences may be required when physical work is being done to the system, otherwise, no licence is applicable.
- Plumbing; or
- Water plumbing; or
- Water plumbing – fire protection systems.
For non-water related suppression systems:
- An extinguishing agent handling licence from the Fire Protection Industry (ODS & SGG) Board may be required. The board administers the zone Protection and Synthetic Greenhouse Gas Regulations 1995 on behalf of the Australian Government.
Recommended units of competency
Certificate III in Fire Protection or Certificate III in Fire Protection – Inspection and Testing, or any engineering or construction or automotive related Certificate II or higher, plus the following units of competency:
- CPPFES2025 Inspect, test and maintain gaseous fire-suppression systems.
- CPPFES2043 Apply regulations to prevent ozone depleting substance and synthetic greenhouse gas emissions
- CPPFES2047 Inspect and test control and indicating equipment
- CPPFES3044 Interpret installation requirements for gaseous fire-suppression systems
- CPPFES3045 Install gaseous agent containers and actuators,
- CPPFES3046 Decommission gaseous agent containers and actuators
- CPPFES3032 Conduct enclosure integrity testing.
This is not considered an essential fire safety measure in NSW and is not required to be maintained.
Required licence
The following licences may be required when physical work is being done to the system, otherwise, no licence is applicable.
- Plumbing or
- Water plumbing or
- Water plumbing – fire protection systems.
Recommended units of competency
Certificate II in Fire Protection – Inspection and Testing, or any engineering or construction related Certificate II or higher, plus the following units of competency:
- CPPFES2010 Inspect and test fire hose reels.
Recommended units of competency
Certificate II in Fire Protection – Inspection and Testing, or any engineering or construction or automotive related Certificate II or higher, plus the following units of competency:
- CPPFES2020 Conduct routine inspection and testing of fire extinguishers and fire blankets.
Recommended units of competency
Certificate II in Fire Protection – Inspection and Testing or any engineering or construction or automotive related Certificate II or higher, plus the following units of competency:
- CPPFES2020 Conduct routine inspection and testing of fire extinguishers and fire blankets.
Required licence
Passive fire systems can include a wide range of building elements, including windows, walls, floors, joints, access panels and framing.
The following licences may be required when physical work is being done to the system, otherwise, no licence is applicable:
- General building licence
- Carpentry
- Dry plastering
- Joinery.
Recommended units of competency
Certificate II in Fire Protection – Inspection and Testing, or any engineering or construction or automotive related Certificate II or higher, plus the following units of competency:
- CPPFES2039 Identify, inspect and test passive fire and smoke containment products and systems
- CPPFES2035 Identify, inspect and test fire and smoke doors.
Required licence for mechanical ventilation work
In NSW, any work on the mechanical ventilation system of a building must be done by a person with a mechanical services and medical gas work licence.
The definition of mechanical services is:
"The construction, installation, replacement, repair, alteration, maintenance, testing or commissioning of a mechanical heating, cooling or ventilation system in a building, which is associated with the heating, cooling or ventilation of that building and includes:
- any valve, regulator, pipe, flue, tank, heating or cooling pipe or surface, boiler, burner, solid fuel heater, coil or other item that is used in the system
- in the case of a cooling tower, any water pipe, valve, pump, automated dosing device or automated bleeding device or any other mechanical component that affects the cooling tower’s cooling water flow rate or wastewater disposal
- roof sheeting and roof flashing that is necessary for the purpose of any work described in this paragraph."
Unlike other licence categories, any testing work associated with mechanical services must be done by a licensed person.
Examples of testing and maintenance work in AS 1851-2012 requiring a mechanical services licence:
- Check that the damper is capable of operating from fully open to fully closed, and is clear of obstructions. Where the damper is not required to fully open or close, check that it is capable of operating between maximum and minimum positions.
- Ensure damper/s moves to its fire mode position upon removal of a power source.
- Drain any fluid that has accumulated in the air filter.
Recommended units of competency
UEERA0098 Inspect, test and repair fire and smoke control features of mechanical services systems.
Recommended units of competency
- PUAFER002 Ensure facility emergency prevention procedures, systems and processes are implemented
- PUAFER003 Manage and monitor facility emergency procedures, equipment and other resources.