The Building Codes Board already publishes the mandatory requirements as a standalone document. We downloaded it and measured it. The numbers reframe what the argument about code length has actually been about.

A week of argument about how long the National Construction Code should be has produced one useful clarification and one set of numbers nobody has put on the table.

The clarification first. The proposal put to the National Press Club was widely reported, including here, as replacing the National Construction Code with a document of roughly 80 pages. Senator Bragg’s office has since told the ABC that the intention is an 80 to 90 page Basic Australian Standard sitting within a slimmed down and simplified construction code. It is the mandatory core, not the whole document.

That is a different proposition, and a more serious one. It also invites a question the debate has not answered. How big is the mandatory core right now.

What is actually mandatory in the National Construction Code

The National Construction Code is a performance based code, and it has a hierarchy.

Clause A2G1 sets it out, in the same terms in both NCC 2022 and NCC 2025. Compliance is achieved by complying with the Governing Requirements and the Performance Requirements. The Governing Requirements are the procedural rules about how the code is used. The Performance Requirements set the minimum standard a building, building element or plumbing and drainage system has to achieve.

Underneath those sit the Deemed to Satisfy Provisions, which the Building Codes Board describes as a recipe book: they tell you what, how and where. And here is the sentence that matters, in the Board’s own words. The Performance Requirements are the only NCC technical provisions that must be satisfied.

The Deemed to Satisfy Provisions are not separately mandatory. They are one of the ways of demonstrating a Performance Requirement has been met. There are three routes: a Deemed to Satisfy Solution, a Performance Solution, or a combination of both. In the Board’s words, there is no obligation to adopt any particular material, component, design factor or construction method.

So how long is the mandatory part

This is answerable, because the Building Codes Board already publishes it as a standalone document called the Consolidated Performance Requirements.

The NCC 2022 edition of that document runs to 234 pages. But that total is not the mandatory content, and this is where the public argument has gone wrong in both directions. Here is what is actually in it.

The Performance Requirements for all three volumes occupy pages 44 to 116 of that document. That is a span of 73 pages, of which 71 are requirements and two are the contents listing sitting between Volume Two and Volume Three.

Everything else in that 234 page document is supporting apparatus. Forty pages of definitions and glossary. Twenty pages listing referenced documents. Fifty eight pages of state and territory variations, which is more than three quarters as long as the Performance Requirements themselves and is worth sitting with for a moment.

Evidence to the Senate Select Committee on Productivity in Australia from Simon Croft, chief executive of industry and policy at the Housing Industry Association, put the mandatory performance requirements at 200 pages. On our measurement that is closer to the size of the compilation than to the Performance Requirements within it.

What this means for a house

There is no single number for residential, and anyone offering one is simplifying.

The Building Codes Board states that the technical requirements for Class 1 and 10 buildings, which is what a standard house and its garage or shed are, are mostly covered by Volume Two. Volume Three covers plumbing and drainage for all building classifications.

So a residential builder’s mandatory technical set is the 15 pages of Volume Two, plus the 21 pages of plumbing and drainage in Volume Three, sitting underneath the 34 pages of Section A that govern how the code is applied at all, and adjusted by whichever state or territory variations apply. It is a small document by any measure. It is not 15 pages.

Which edition of the code you are actually working to

Two separate things are being described as a pause and they are getting mixed up.

NCC 2025 is not on hold. The Building Codes Board published a preview on 1 February 2026 and released the final edition on 1 May 2026. What is paused is the next round: no further residential changes to the code, beyond essential quality and safety measures, until mid 2029. That was announced by the Commonwealth on 24 August 2025 and agreed by Building Ministers in October 2025. NCC 2025 was the last edition through before the door closed.

Released is not the same as in force. Adoption is a decision for each state and territory, and they have gone in different directions.

Victoria adopted NCC 2025 on 1 May 2026 with no transition period, and it has applied to all new building work there since. New South Wales, Queensland and the Australian Capital Territory have all deferred mandatory adoption to 1 May 2027, with voluntary early adoption open in the meantime. South Australia, Western Australia, Tasmania and the Northern Territory have had it available since 1 May 2026 without confirming a firm mandatory date, and Tasmania has paused some NCC 2025 measures.

Which means that for most of Australia, NCC 2022 as amended is still the code you are building to. Victoria is currently the exception. The compliance structure described here is identical in both editions, so nothing above changes with the edition, but the specific provisions do. Confirm the adoption date and the trigger point with your certifier before you lodge, because in several jurisdictions the edition is locked by the lodgement date rather than the approval date.

Which changes what the argument is about

Set the figures side by side and the shape of the debate changes.

The mandatory technical requirements across all three volumes run to 73 pages. The proposed Basic Australian Standard is 80 to 90 pages. The proposed simpler standard is larger than the mandatory technical content that already exists.

That is not a gotcha, and it should not be read as one. There is a straightforward explanation. The proposal narrows what a house is required to include rather than how much text describes it, and a standard written to be read by a general audience carries far more explanatory material than a bare performance clause does. Eighty to ninety pages covering fewer requirements is entirely coherent.

But it does mean the reduction on offer was never a reduction in reading. It is a reduction in scope. Which is precisely the argument that has not been had, because the page counts have been standing in for it.

The other 2,000 or so pages of the code are the Deemed to Satisfy material, the guidance that explains how to apply it, the worked examples and diagrams, and the jurisdictional variations. All of that is real reading. None of it is what makes a house compliant.

The flexibility already sitting in the code

There is a practical payload here with nothing to do with the reform debate.

Because the Deemed to Satisfy Provisions are a pathway rather than an obligation, a builder is entitled to depart from them, provided the departure can be shown to meet the relevant Performance Requirement. That is a Performance Solution, and it is the compliance pathway builders already have on every job today.

It must be verified using one or a combination of four Assessment Methods: Evidence of Suitability, a Verification Method, Expert Judgement, or Comparison with the Deemed to Satisfy Provisions. Some Performance Requirements have no Deemed to Satisfy Solution at all, and where that applies a Performance Solution is the only route.

One of those four is being taken away. NCC 2025 removes Expert Judgement as an Assessment Method for specified structural and fire safety Performance Solutions, and introduces minimum reliability levels that a structural Performance Solution has to demonstrate under clauses B1P1(2) and H1P1(2). The Building Codes Board’s stated reason is to reduce subjectivity in safety critical areas and to require analysis that can be independently reviewed. For the materials caught by the change, which include timber, steel, concrete and masonry systems, a Performance Solution now has to demonstrate equivalence with the Deemed to Satisfy Provisions rather than rest on an expert’s judgement.

Victoria has varied the code to keep Expert Judgement available for structural and fire safety Performance Solutions. Everywhere else, once NCC 2025 is adopted, it goes.

It is not informal. The code prescribes the process: prepare a performance based design brief in consultation with relevant stakeholders, carry out the analysis, evaluate the results against the acceptance criteria in the brief, and prepare a final report covering all three. The relevant building surveyor then has to approve it.

Why most residential builders never use it

The honest answer is not that builders do not know it exists. It is that the pathway carries costs the prescriptive route does not.

It generally needs an engaged professional to prepare and assess it, which is a fee on a job that may not have carried one. It needs a documented basis that will still stand up years later. It needs a certifier willing to accept it, and appetite for departing from the recipe varies enormously between practitioners and between jurisdictions. And it sits inside a professional indemnity environment where the person signing has to be comfortable carrying it.

On a standard house the prescriptive route usually wins, not because it produces a better building, but because it is faster to evidence and cheaper to defend. Any departure has to be priced and documented in the building contract, and that administrative load is the real barrier rather than the technical one.

The structural limitation described above does not bite immediately. It takes effect one year after the NCC 2025 adoption date in the relevant jurisdiction, so the date moves depending on where you build. In Victoria that is 1 May 2027. In New South Wales, Queensland and the ACT, which adopt on 1 May 2027, it would be a year later again.

Where the actual agreement is

Strip out the page counts and there is a large area of the housing debate where both sides of federal politics are saying the same thing.

Modern methods of construction. Prefabricated, modular and offsite manufacture, along with newer technologies applied to building. The Senate committee that produced the framework spans Liberal, Nationals and Labor members, and its interim report recommends the Commonwealth embrace these methods. The Government is already funding them, with $39.3 million committed to modern methods of construction and discussed at the housing, homelessness, planning and building ministers meeting in May 2026. Federal, state and territory treasurers meeting on Friday were reported to have agreed to review the barriers to wider adoption.

The concrete piece has been moving for two years. The Australian Building Codes Board has been tasked by the Australian Government, as part of National Competition Policy reform, with delivering a national voluntary certification scheme for manufacturers of prefabricated construction along with consistent NCC definitions, and the prefab certification scheme out for consultation now has draft rules and a proposed definition on the table, with feedback closing on 15 September 2026.

Note the word voluntary. The Board has been explicit that existing methods of demonstrating compliance remain valid and that the scheme is a streamlined alternative pathway, not a replacement. The economic case cited for it is substantial: Productivity Commission analysis, quoted by the Board, puts the potential cost reduction at up to 20 per cent, with construction up to 50 per cent faster than traditional methods.

If you want to know what will actually change on an Australian site in the next two years, that is a better place to look than the length of a document.

The Good Builder Take

Seventy three pages, of which 71 are the requirements themselves. That is the whole of the mandatory technical content of the National Construction Code, across commercial buildings, houses and plumbing, and the Building Codes Board has been publishing it as its own document the entire time.

Which means the proposed 80 to 90 page standard is not smaller than what is already compulsory. It is a narrower set of requirements written at greater length. That is a legitimate proposal and it deserves a proper argument, but the argument is about what a house should be required to include, not about how much anyone has to read.

The number in that table we would put money on mattering more is 58. Fifty eight pages of state and territory variations, sitting inside a document that exists to state what is nationally mandatory. That is the reform industry actually asked Treasury for, it is unglamorous, and it would do more for a builder working across a border than any page count ever will. It is also not being ignored. Victoria cut its own appendix from 115 variations to 60 in adopting NCC 2025, which is a real reduction and the kind of thing that deserves more attention than it got.

The useful thing buried in all of this is that you are not obliged to build to the recipe. You are obliged to meet the Performance Requirements. Most builders will still choose the recipe, for sound commercial reasons, and NCC 2025 narrows the alternative in a couple of specific places. But knowing the difference is what lets you have an informed conversation with a certifier instead of an assumption.

Where this leaves builders

Nothing has changed on site. The National Construction Code applies as adopted in your own state or territory, and residential changes to the code remain paused until mid 2029.

What has changed is the shape of the argument. It has moved from how long the document should be to what belongs in its mandatory core, which is a more useful conversation. It is also the part of the wider reform cycle builders are working inside that will determine what a new home is required to include.

Two things are worth doing now. If you build anything that repeatedly runs into a Deemed to Satisfy Provision that does not suit the site, it is worth asking your certifier whether a Performance Solution is viable and what it would cost to document. And if you work with prefabricated or modular components in any form, the certification scheme consultation closes on 15 September and it will set the rules you work under.

Frequently asked questions

This article is general information only. It reflects publicly available material as at 17 August 2026 and does not take into account the circumstances of any particular business or project. Page figures are measured from the Australian Building Codes Board publication Consolidated Performance Requirements, NCC 2022 edition dated 1 May 2023, and page counts differ between editions. Adoption of NCC 2025 varies by state and territory and dates cited were current at the time of writing. Compliance pathways under the National Construction Code, including the use of Performance Solutions, should be confirmed with your building surveyor or certifier for the specific project and jurisdiction. Builders and trades should confirm their obligations under the National Construction Code as adopted in their own state or territory, and seek their own professional guidance where required.

Hear more conversations like this on The Good Builder Podcast, and get the week’s construction industry news at thegoodbuilder.com.au.

Author: TGB Editorial