# Accessible Class 2 Apartment Design in NSW: Why NCC Part G7 Is Blank and What Accessibility Standards Apply Instead
Why NSW Exempted Class 2 Apartments From Livable Housing Design Requirements
NSW is the only Australian jurisdiction that deliberately left Part G7 of NCC 2022 Volume One blank, meaning the Livable Housing Design Standard (LHDS) Silver level does not apply to sole-occupancy units in Class 2 buildings in NSW. While every other state and territory adopted the Silver tier accessibility requirements for apartments from 1 October 2023, NSW chose a different pathway — relying instead on the Apartment Design Guide (ADG), local council Development Control Plans (DCPs), and the Disability (Access to Premises – Buildings) Standards 2010 for common areas. For developers and design practitioners working on Class 2 projects in NSW, understanding what this exemption means — and what accessibility standards do apply — is essential to avoid costly rework during certification.
NSW Planning determined that the Apartment Design Guide under the Housing SEPP 2021 already addressed liveability and accessibility outcomes through its design quality principles, and that mandating Silver level inside individual apartments would duplicate state-level controls. The practical effect is that NSW Class 2 apartments are not required to include step-free entries, 820mm doorways, reinforced bathroom walls for future grabrails, or hobless showers under the NCC — but many councils require these features through DCP provisions, and market demand increasingly expects them.
This creates a complex compliance landscape. We have seen projects in Parramatta where developers assumed Part G7 applied, designed to Silver level, then discovered the council DCP required a higher standard of adaptable housing under AS 4299. The reverse also occurred in the Hills Shire: teams over-engineered accessibility features that were never legally required, adding $15,000–$25,000 per unit in unnecessary costs. For a broader overview of Class 2 building definitions and approval pathways, see our guides on What Is a Class 2 Building and Class 2 Building Approval Pathways: DA vs CDC.
What NCC Part G7 Requires Everywhere Except NSW
Part G7 of NCC 2022 Volume One sets livable housing design requirements for sole-occupancy units in Class 2 buildings. The provisions are based on the Silver level of the Livable Housing Design Guidelines and are administered through the ABCB Standard for Livable Housing Design. In every state and territory except NSW, these requirements took effect from 1 October 2023 (Tasmania delayed to 1 October 2024).
| Requirement | Silver Level (LHDS) | NSW Status |
|---|---|---|
| Step-free path from street to dwelling entrance | Required | Not mandated |
| At least one level (step-free) entrance | Required | Not mandated |
| Internal doorways: 820mm clear opening | Required (entry level) | Not mandated |
| Hallways: minimum 1000mm width | Required (entry level) | Not mandated |
| Toilet on ground/entry level | Required | Not mandated |
| Hobless (walk-in) shower | Required (one bathroom) | Not mandated |
| Reinforced bathroom walls for future grabrails | Required | Not mandated |
| Stairway design for future lift installation | Not required (Silver) | N/A |
The key distinction is between sole-occupancy units (the individual apartments) and common areas (lobbies, corridors, lifts, communal spaces). Part G7 applies only to apartment interiors. Common areas in Class 2 buildings are covered by Part D4 (Access for People with a Disability) in all jurisdictions, including NSW. This means the building's entrance, foyer, lift access, and communal corridors must still meet full accessibility standards under AS 1428.1 — only the apartment interiors are exempt in NSW. For more on the regulatory framework, see our guide on the Design and Building Practitioners Act 2021.
What Accessibility Standards DO Apply to Class 2 Buildings in NSW
Three separate regulatory frameworks govern accessibility in NSW Class 2 developments. Understanding the interaction between them is critical for design practitioners and developers.
1. NCC Part D4 — Common Area Accessibility (Applies in All States)
Part D4 of NCC Volume One addresses access for people with disability and applies to common areas in Class 2 buildings nationwide, including NSW. This includes the building entrance, foyer, lift lobbies, corridors serving sole-occupancy units, communal facilities (gyms, laundry, bin rooms, bike storage), and any shared outdoor spaces. Compliance is demonstrated through AS 1428.1:2021 (Design for Access and Mobility), which specifies dimensions for doorways, circulation spaces, ramp gradients, tactile indicators, and accessible sanitary facilities.
2. Disability (Access to Premises — Buildings) Standards 2010
The Premises Standards are a federal instrument under the Disability Discrimination Act 1992 and apply to new building work in Class 2 buildings where common areas exist. They are closely aligned with NCC Part D4 and reference the same technical standards (AS 1428.1). The Premises Standards are legally enforceable — it is unlawful to contravene them — and they apply regardless of state NCC variations. For NSW Class 2 projects, this means common area accessibility cannot be skipped even though Part G7 is blank.
3. Local Council DCPs and the Apartment Design Guide
This is where NSW Class 2 accessibility gets genuinely complex. Many Sydney councils require adaptable housing units in apartment developments through their DCPs, typically mandating 10–20% of units be designed as Adaptable Housing under AS 4299. The City of Sydney DCP, for example, requires 10% of units in developments of 10 or more dwellings to be adaptable. Parramatta Council's DCP requires adaptable units in certain zones. Inner West Council has similar provisions.
The Apartment Design Guide (ADG), operating under Chapter 4 of the Housing SEPP 2021 (formerly SEPP 65), addresses accessibility through its design quality principles. The ADG does not mandate specific Silver level features inside apartments, but requires developments to demonstrate consideration of accessibility and adaptability. Councils use the ADG as assessment criteria, and many interpret the adaptability principle as requiring at least some units to meet AS 4299 Class C minimums. For BASIX and NatHERS compliance in Class 2 buildings, see our BASIX and NatHERS compliance checklist. For fire safety requirements, see our BCA Section C compliance guide.
How Adaptable Housing (AS 4299) Differs From Livable Housing (LHDS)
Many practitioners confuse these two standards, but they serve different purposes and have different compliance pathways.
| Feature | Livable Housing Design Standard (Silver) | Adaptable Housing AS 4299 |
|---|---|---|
| Scope | All dwellings (Class 1a and Class 2) | Percentage of units (council-mandated) |
| Door width | 820mm clear opening | 850mm clear opening (wider) |
| Application | NCC Part G7 (not in NSW) | Council DCP conditions |
| Classification levels | Silver, Gold, Platinum | Class A, B, C |
| Bathroom reinforcement | Wall reinforcement for future grabrails | Full structural provision for future modification |
| Car parking | No specific accessible parking | Accessible parking per AS 2890.6 |
| Compliance pathway | Building certifier (NCC DTS) | DA condition compliance |
Adaptable Housing under AS 4299 is more stringent than LHDS Silver in several areas. The doorway width is 850mm compared to 820mm. Adaptable units require full structural provisions for future bathroom modification, not just wall reinforcement. Councils typically require accessible car parking in association with adaptable units, designed to AS 2890.6:2022 dimensions (3200mm × 5400mm with shared aisle). For acoustic separation requirements that also apply to adaptable unit walls, see our acoustic and separation guide for Class 2 buildings.
Accessible Car Parking Requirements for NSW Class 2 Buildings
The BCA does not mandate accessible car parking for Class 2 residential buildings unless adaptable housing has been required as a condition of consent. However, once a council DCP requires adaptable units, associated accessible parking must be provided to AS 2890.6:2022 standards. The standard specifies:
- Minimum accessible space dimensions: 2400mm × 5400mm (with 3200mm shared aisle) or 3200mm × 5400mm (dedicated shared area)
- One accessible space per adaptable unit
- Gradients not exceeding 1:20 in the parking area
- Continuous accessible path of travel from the parking space to the building entrance
- Signage with the International Symbol of Access
The NCC 2022 also introduced EV-ready infrastructure requirements for Class 2 parking, though NSW's adoption of these provisions has its own timeline. Developers should confirm current NCC amendment status with their certifier, as the EV provisions interact with electrical infrastructure design from the DA stage.
Project Examples: When Accessibility Requirements Caught Developers Off Guard
Project 1: 24-Unit Development, Parramatta CBD
A 24-unit apartment development in Parramatta was designed in 2024 assuming NCC Part G7 applied. The design team incorporated 820mm doorways, step-free entries to ground-floor units, and hobless showers in all bathrooms — adding approximately $8,000 per unit in construction costs. During DA assessment, Parramatta Council's DCP required 10% of units (3 units) to be Adaptable Housing Class C under AS 4299. The design had to be revised: those 3 units needed 850mm doorways, wider corridors, and full structural bathroom provisions. The remaining 21 units had over-designed accessibility features that were never legally required under NSW's blank Part G7. Total unnecessary cost: approximately $168,000 across the 21 non-adaptable units.
Project 2: 12-Unit Townhouse-Style Apartments, Inner West
A 12-unit development in Marrickville was designed without any Silver level features, based on the assumption that Part G7 was blank in NSW. The local DCP required 10% adaptable units, but the design team missed this requirement during pre-DA. At DA lodgement, the council requested additional information demonstrating compliance with adaptable housing provisions. The project was delayed by 6 weeks while two units were redesigned to AS 4299 Class C standard, including structural modifications to bathroom walls, widened doorways from 760mm to 850mm, and reconfiguration of the ground-floor toilet layout. The redesign cost approximately $22,000 per unit for the 2 adaptable units, plus consultant fees of $8,500.
Project 3: 40-Unit Build-to-Rent, Liverpool
A 40-unit build-to-rent project in Liverpool took a market-driven approach, voluntarily including 5 adaptable units (12.5%) exceeding the council's 10% minimum, plus Silver level features in all remaining units. This added approximately $6,500 per unit but increased marketability to disability housing providers and reduced vacancy risk. The project achieved DA approval 3 weeks faster than a comparable project with minimal accessibility provisions, as council assessment was streamlined by the proactive approach. For a full design-to-approval timeline, see our Class 2 case study.
The Compliance Workflow: What Design Practitioners Should Do
For NSW Class 2 projects, we recommend a structured accessibility compliance workflow that accounts for the state's unique regulatory position.
Step 1: Pre-DA — Check the council DCP. Before commencing design, obtain the relevant council's DCP and identify adaptable housing requirements. Most Sydney metropolitan councils publish their DCPs online. Look specifically for "adaptable housing," "accessible housing," or "universal housing" provisions. Note the required percentage, classification level (Class A, B, or C under AS 4299), and any associated car parking requirements. Step 2: Design Brief — Incorporate accessibility from the start. Even though Part G7 is blank in NSW, we recommend incorporating Silver level features as a design baseline for all units, not just adaptable ones. The marginal cost is minimal when planned from the outset (typically $2,000–$5,000 per unit for wider doorways, hobless showers, and reinforced walls). This future-proofs the development against potential regulatory changes and broadens market appeal. Step 3: DA Documentation — Demonstrate compliance clearly. Include an accessibility compliance matrix in the DA documentation showing: which units are adaptable (with AS 4299 classification), which common areas comply with Part D4 / AS 1428.1, and any Silver level features incorporated voluntarily. This streamlines council assessment and reduces RFIs. Step 4: Construction Certificate — Verify before building. Engage an access consultant to review the construction documentation against the approved DA conditions. Confirm that adaptable units meet AS 4299 requirements and that common areas comply with AS 1428.1. This is the final checkpoint before construction begins. Step 5: Practical Completion — Certify and document. Obtain an access compliance certificate from an accredited access consultant. Document the location and dimensions of accessible features for the building's operations manual and strata records. This is important for future modifications and compliance with the defect liability period under the Home Building Act 1989 (6 years for major defects, 2 years for minor defects). For common design mistakes to avoid, see our guide on common Class 2 building design mistakes. For cost expectations, see our Class 2 design fees vs construction costs breakdown.Frequently Asked Questions
Does NCC Part G7 (Livable Housing Design) apply to Class 2 apartments in NSW?
No. NSW deliberately left Part G7 of NCC 2022 Volume One blank, meaning the Livable Housing Design Standard Silver level does not apply to sole-occupancy units in Class 2 buildings in NSW. This is a state-specific variation — all other Australian states and territories have adopted Part G7. However, common areas in Class 2 buildings must still comply with NCC Part D4 and AS 1428.1 for disability access.
What accessibility standards apply to Class 2 apartment common areas in NSW?
Common areas in NSW Class 2 buildings must comply with NCC Part D4 (Access for People with a Disability), the Disability (Access to Premises – Buildings) Standards 2010, and AS 1428.1:2021 (Design for Access and Mobility). This covers building entrances, foyers, lift lobbies, corridors, communal facilities, and shared outdoor spaces. These requirements apply regardless of the Part G7 exemption for apartment interiors.
Do NSW councils require adaptable housing in apartment developments?
Many do, but the requirements vary by council. The City of Sydney requires 10% of units in developments of 10+ dwellings to be adaptable under AS 4299. Parramatta, Inner West, and Northern Beaches have similar provisions. The specific percentage and classification level (Class A, B, or C) is set in each council's Development Control Plan. Always check the DCP before commencing design.
What is the difference between Livable Housing (LHDS) and Adaptable Housing (AS 4299)?
Livable Housing Design Standard (Silver level) applies to all dwellings and focuses on basic accessibility features like step-free entries, 820mm doorways, and hobless showers. Adaptable Housing (AS 4299) is more stringent, requiring 850mm doorways, full structural provisions for future bathroom modification, and is typically applied to a percentage of units. LHDS is a building code requirement (except in NSW); AS 4299 is a council DCP condition.
Are accessible car parking spaces required for Class 2 buildings in NSW?
The BCA does not mandate accessible car parking for Class 2 residential buildings unless adaptable housing has been required as a DA condition. Once a council DCP requires adaptable units, associated accessible parking must be provided to AS 2890.6:2022 standards (minimum 2400mm × 5400mm with shared aisle, or 3200mm × 5400mm dedicated). The accessible spaces must connect to the building entrance via a continuous accessible path of travel.
Should I include Silver level features in NSW Class 2 apartments even though they are not required?
We recommend incorporating Silver level features as a design baseline even though Part G7 is blank in NSW. The marginal cost when planned from the outset is approximately $2,000–$5,000 per unit. Benefits include broader market appeal, future-proofing against potential regulatory changes, eligibility for disability housing provider tenancies, and reduced vacancy risk in build-to-rent developments. Many projects that exceed minimum accessibility standards achieve faster DA approval.
How does the NSW Part G7 exemption interact with the DDA and Premises Standards?
The Disability Discrimination Act 1992 and the Disability (Access to Premises – Buildings) Standards 2010 apply to common areas in Class 2 buildings regardless of state NCC variations. The Part G7 exemption in NSW only affects the interior of sole-occupancy units. The DDA itself can apply to individual apartment interiors in certain circumstances (such as short-term rental accommodation), but this is assessed case-by-case and is not a blanket requirement for residential apartments.
Who can certify accessibility compliance for a Class 2 building in NSW?
Accessibility compliance is typically certified by an accredited access consultant (member of the Association of Consultants in Access Australia) and verified by the principal certifier (council or private certifier). For adaptable housing under AS 4299, the access consultant confirms that the design and as-built construction meet the required classification level. For common areas under Part D4 and AS 1428.1, the access consultant provides a compliance report at DA and CC stages.
Written by Franz Phan, Registered Design Practitioner and Senior Building Designer at giantA Pty Ltd. Franz has 15+ years of experience in NSW multi-residential development, with over 40 Class 2 apartment projects delivered across Greater Sydney. giantA Pty Ltd is a registered Design Practitioner under the Design and Building Practitioners Act 2021 for Class 2 buildings. This article is for informational purposes only and does not constitute legal or building code advice. Always consult your local council DCP, a qualified access consultant, and your certifier for project-specific compliance requirements. NSW planning and building regulations are subject to change — verify currency with nsw.gov.au and the NSW Planning Portal.