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QBCC Names Eight Priority Harms in Its 2026 to 2030 Enforcement Strategy, Replacing a Fifteen Point List

The regulator has published a four year statement of intent that changes what it says it is watching, when it escalates, and how much warning the industry gets. The QBCC published its Compliance and Enforcement Strategy 2026 to 2030 on 17 August 2026.  It replaces the Compliance and Enforcement Strategy 2024 to 2026, released in […]

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Mon 21 Sep 26 6:00:00 AM

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The regulator has published a four year statement of intent that changes what it says it is watching, when it escalates, and how much warning the industry gets.

The QBCC published its Compliance and Enforcement Strategy 2026 to 2030 on 17 August 2026. 

It replaces the Compliance and Enforcement Strategy 2024 to 2026, released in November 2024. That document ran two years and listed fifteen separate commitments across enduring priorities and shorter term focus areas.

The new strategy runs four years, is half the length, and sorts the regulator’s stated priorities into eight standing categories rather than a list. It is the first full statement of regulatory intent published since the current commissioner and refreshed board took up the reform mandate handed to them in 2025, and it lands alongside the wider changes to Queensland building laws already in train.

What the strategy names as priority harm

The strategy sets out what it calls a priority portfolio of harm. Eight areas sit inside it.

Those areas are structural and life safety risks, unlicensed work and market integrity, financial and solvency risks, defective and incomplete work, accountability for the quality of building work, water ingress and moisture failures, plumbing and drainage compliance, and fire safety systems and passive fire protection.

Six carry over in substance from 2024. Two are new as named categories: structural and life safety risks, and accountability for the quality of building work.

The second is the one with immediate operational consequence, because it names subcontractors directly.

Several 2024 priorities are no longer named

Present in the 2024 document and absent from the new portfolio: combustible cladding audits, pool fencing safety, non conforming building products, proactive compliance across key risk areas of the National Construction Code, active monitoring of security of payment legislation, and licensing efficiency.

None of those functions have been removed from the QBCC. They sit in legislation the regulator administers, and the underlying licensing and compliance obligations are unchanged.

In the six months to 31 December 2025 the QBCC reported 150 Safer Buildings Program audits covering combustible cladding, and 144 trust account audits, of which 77 were recorded as non compliant.

Absence from the named portfolio is not absence from the workload.

What has changed is which harms the regulator has put its name against for four years, and therefore which ones it expects to be measured on.

Enable, Assure and Enforce replaces the escalation pyramid

The 2024 strategy pictured regulation as a pyramid, escalating from education at the base through infringement notices and licence conditions to prosecution at the top. The sorting mechanism was the licensee’s behaviour, running from willing to deliberately non compliant.

The new strategy groups the same tools into three modes. Enable covers education, guidance, data led insight and early engagement. Assure covers targeted inspections, risk based audits, thematic assessments and follow up checks. Enforce covers penalties, licence action, public warnings, enforceable undertakings and prosecution.

Assure is where most licensees will meet it. Proactive inspection figures for the six months to 31 December 2025 show 877 building inspections, 808 plumbing inspections, 102 fire inspections and 99 mechanical services inspections, with initial compliance rates of 84, 75, 83 and 58 per cent respectively.

The strategy states that enforcement applies where behaviour is deliberate, repeated or high risk. Repeated is the word doing the work.

Repetition is the stated trigger for escalation

One of the worked examples in the strategy describes a licensee who receives multiple directions to rectify over a two year period for similar defective work, after education and assurance activity has already occurred.

The response described is a licence condition requiring that licensee to complete specified formal training before further work is undertaken, followed by suspension if non compliance continues.

Training as a condition of licence, imposed on the basis of a pattern rather than one serious breach, is the sharpest practical signal in the document.

Base rates give it context. Between 1 July and 31 December 2025 the QBCC received 2,952 complaints about defective work, issued 671 directions to rectify and issued 213 penalty infringement notices for failure to rectify. Thirty three matters proceeded to QCAT.

Across roughly 126,000 licensees, the QBCC recorded that 0.53 per cent received a direction to rectify in that period. The escalation pathway is pointed at a narrow group, and the strategy is explicit that repetition rather than volume moves a licensee into it.

Subcontractor defect accountability is now written into the strategy

The QBCC refined how it applies the Direction to Rectify process from 30 March 2026 through a new guideline. The strategy carries that approach forward as a four year priority rather than a standalone policy.

Where a defect is clearly caused by a licensed subcontractor and the evidence supports it, the direction may be issued to that subcontractor first. Where responsibility is unclear, particularly across multiple trades and interfaces, it goes to the principal contractor.

The QBCC has stated this is not a change to legislation. It is a change to sequencing and to the evidence the regulator expects to see, and principal contractors keep responsibility for supervision and for coordinating rectification.

Directions are recorded as complied or not complied on the public licence record of whichever licensee receives them. For anyone managing subcontractors, that moves defect history from a builder level record to one that attaches to individual trade businesses.

What the QBCC means by a priority portfolio of harm

A priority portfolio of harm is a standing set of harm categories a regulator commits to prioritising for the life of a strategy. It is not the same thing as a priority focus area. Under the QBCC’s Compliance and Enforcement Strategy 2026 to 2030, the eight harm categories are fixed for four years, while the specific priority focus areas sitting beneath them are informed by QBCC data and stakeholder engagement and published annually.

Unlicensed work stays at the top of the investigation list

Unlicensed contracting was the most common category of compliance investigation in the six months to 31 December 2025, out of 1,434 cases opened. It also ranked second among reasons for a penalty infringement notice, behind failure to comply with a direction to rectify.

Enforcement here is not confined to notices. Fifteen of the charges prosecuted in the period were for unlawfully carrying out building work under section 42 of the QBCC Act, with $167,000 in fines imposed across 31 charges.

The strategy adds public warnings to the named response for this harm, describing them as a way of alerting consumers where an operator or practice presents immediate risk.

Financial risk is being read from a wider set of signals

The strategy lists what feeds the intelligence picture: complaints, audits, licensing history, notifiable work, inspections, payment and financial indicators, product trends, ongoing compliance activity and partner insights.

Payment indicators and partner insights are the additions worth noting. Both point to distress being identified from behaviour rather than from a lodged report measured against a threshold, which is a different exercise to annual reporting compliance.

The activity already runs at that level. In the six months to 31 December 2025 the QBCC recorded 197 financial audits and 93 non compliant findings, made 240 requests for internal management accounts, and recorded $17 million injected back into licensee balance sheets as a result. Cancellations in the period included 17 for failure to comply with an audit and eight for breach of minimum financial requirements.

Subcontractor payment sits alongside that. The QBCC received 368 monies owed complaints worth about $6 million and recorded roughly $2.4 million recovered, on the basis that failing to pay a debt when it falls due is a breach of a licence condition rather than purely a cash flow matter between two parties.

Contract compliance appears in the same data. Domestic building contract offences were the second most common investigation category, and a non compliant domestic building contract the third most common reason for an infringement notice, which is consistent with the long running issues around the consumer building guide and pre contract documents.

Early resolution is given a bigger role than it currently carries

The strategy names mediation and conciliation as central early resolution pathways for 2026 to 2030, on the basis that many issues arise from misunderstanding rather than deliberate misconduct.

The service is still small. In the six months to 31 December 2025, 55 cases were referred to a conciliator and 47 proceeded to a session, with 24 fully resolved and seven partially resolved.

Against 2,952 defect complaints in the same period, that is a narrow funnel. Whether it widens is one of the more testable claims in the document.

The industry now gets annual notice of what is being targeted

The eight harm categories are fixed for four years. Underneath them, the strategy commits to publishing priority focus areas annually, informed by QBCC data and stakeholder engagement.

It also commits to publishing high level findings from thematic audits, summaries of common defect patterns and examples of what the regulator considers good practice, alongside biannual regulatory reports and organisational performance metrics.

That is the most useful structural change in the document. A four year harm portfolio, an annual priority list and published audit findings together mean the areas under active scrutiny are stated in advance rather than worked out after the fact.

The Good Builder Take

Read the two strategies side by side and the change is one of posture rather than power. The tools are the same tools. What has moved is a regulator saying in advance, in writing, that it will act on patterns and publish what it finds. For most licensees very little changes day to day. For anyone carrying a run of rectification history, or working off informal subcontract scopes, the document reads as fair warning.

Frequently asked questions

What does the QBCC Compliance and Enforcement Strategy 2026 to 2030 target?

It names eight priority harm categories: structural and life safety risks, unlicensed work and market integrity, financial and solvency risks, defective and incomplete work, accountability for the quality of building work, water ingress and moisture failures, plumbing and drainage compliance, and fire safety systems and passive fire protection. Specific priority focus areas sitting beneath those eight categories are published annually.

How is the 2026 to 2030 strategy different from the 2024 to 2026 strategy?

It runs four years instead of two, replaces a fifteen point list of commitments with eight standing harm categories, groups regulatory tools into three modes called Enable, Assure and Enforce, and commits to publishing priority focus areas annually. Combustible cladding, pool fencing safety, non conforming building products, National Construction Code compliance activity, security of payment monitoring and licensing efficiency were named in 2024 and are not named in the new portfolio, although the QBCC continues to administer all of them.

Can the QBCC issue a direction to rectify to a subcontractor?

Yes. Under the refined Direction to Rectify approach that took effect on 30 March 2026, where a defect is clearly caused by a licensed subcontractor and the evidence supports it, the QBCC may issue the direction to that subcontractor first. Where responsibility is unclear, the direction is issued to the principal contractor, who remains responsible for supervision and for coordinating rectification. The QBCC states this is not a change to legislation.

What does intelligence led regulation mean in practice for QBCC licensees?

The QBCC states it analyses complaints, audits, licensing history, notifiable work, inspections, payment and financial indicators, product trends and partner insights to identify patterns, then directs inspection and audit activity toward the areas and licensees those patterns point to. In practice that means selection for audit is driven by recorded history and data signals rather than random sampling.


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Last updated 24 September 2026.

General information only. This article reports on published regulatory documents and QBCC reported data. It is not legal advice and does not take account of any particular licensee’s circumstances. Anyone dealing with a specific compliance or enforcement matter should obtain advice suited to their situation.


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