Hotels, motels, boarding houses, hostels, backpacker lodges, and serviced apartments all share a fire safety challenge that distinguishes them from most other commercial buildings: overnight guests who are unfamiliar with the building layout, may be asleep when a fire starts, and in some cases may be in a compromised state to respond.
This combination of factors makes accommodation buildings some of the most carefully regulated building types in Australia from a fire safety perspective, and building owners who underestimate these obligations do so at significant risk.
This guide covers the key fire safety requirements for Class 3 accommodation buildings in Australia, from sprinkler mandates and essential services through to AFSS compliance, the July 2026 DBP Act changes, and the specific challenges of managing fire safety in a building that never fully stops operating.
Managing fire safety for a hotel or accommodation property? Fire Safe ANZ provides essential services maintenance and AFSS support for Class 3 buildings across Australia. Request a quote today
Under the National Construction Code, Class 3 buildings are residential buildings providing accommodation for groups of unrelated people, either on a short-term or long-term basis. This classification covers a broad range of property types including:
The Class 3 classification triggers specific NCC requirements around fire safety systems, compartmentation, evacuation routes, and emergency lighting that reflect the overnight occupancy risk profile of these buildings. A guest asleep on the fourth floor at 2am has a fundamentally different evacuation profile to an office worker on the same floor at 2pm, and the building’s fire safety systems and procedures must account for that.
From NCC 2019, mandatory fire sprinkler systems are required in Class 3 buildings with a rise of four storeys or more. This requirement covers hotels, motels, and other accommodation buildings of four storeys and above, bringing them into line with the sprinkler mandate that already applied to taller buildings.
For hotels greater than 11 storeys, the trigger also applies where the floor area exceeds 6,000 square metres. For buildings between four and ten storeys, floors where the floor area exceeds 1,500 square metres require sprinkler protection.
For existing hotels built before these requirements came into effect, the NCC does not mandate retrofitting unless significant building work or a change of use triggers reassessment. However, many insurers now require evidence of sprinkler systems for accommodation buildings of any significant size, making retrofitting a practical as well as regulatory consideration.
Where sprinkler systems are installed, they must be maintained to AS 1851 at the prescribed inspection frequencies, with all records documented on site.
Class 3 buildings require fire-rated separation between each sole-occupancy unit and between units and common areas including corridors, stairwells, and service areas. This compartmentation means that in the event of a fire in one guest room, the fire-rated walls, floors, and doors surrounding it should contain the fire long enough for guests to evacuate and for fire services to respond.
Fire doors in accommodation buildings are therefore critical elements. Corridor fire doors, stairwell doors, and unit entry doors must all self-close and latch correctly, have current compliance tags, and not be propped open or fitted with non-compliant hardware. In a hotel environment, this is a daily operational challenge. Housekeeping, deliveries, and maintenance activities frequently result in fire doors being held open, and without active management this becomes a persistent compliance gap.
For a full breakdown of fire door compliance requirements, read: Fire Door Compliance Tags: What Building Owners Need to Know
Depending on the building’s fire safety schedule, classification, and size, essential fire safety measures in a hotel or accommodation building typically include:
Every essential fire safety measure on the fire safety schedule must be maintained at the correct AS 1851 frequency and documented. All records must be retained on site for a minimum of seven years.
For a full breakdown of AS 1851 requirements, read: What Is AS 1851? A Guide for Building Owners
From 1 July 2026, remedial building work on Class 3 buildings in NSW requires DBP-registered contractors, professional indemnity insurance, and Planning Portal lodgement. This applies to fire safety upgrades and passive fire protection work, facade remediation, structural repairs, and waterproofing work on Class 3 buildings.
In practical terms, this means hotel and accommodation building owners undertaking any significant rectification work identified during a fire safety audit or AFSS assessment must now ensure their contractors are registered under the DBP Act. Using an unregistered contractor for remedial work on a Class 3 building after 1 July 2026 is non-compliant, regardless of the quality of the work performed.
This is a significant change for accommodation building owners who may have previously used general building contractors for rectification work. Confirm your contractor’s DBP registration before engaging them for any remedial fire safety work on your property.
Hotels present specific evacuation planning challenges that do not exist in most other building types. Guests are often unfamiliar with the building layout, may have consumed alcohol, and may be disoriented when woken by an alarm at night. International guests may not speak English. Guests with mobility limitations may not be able to use stairs.
Under AS 3745, hotels must have current evacuation diagrams displayed in every guest room and at regular intervals throughout common areas and corridors. These diagrams must be correctly oriented for each placement location and must show the nearest exit from that position clearly.
Evacuation diagrams in guest rooms have a specific compliance requirement that many accommodation buildings overlook: the diagram must show the route from that specific room to the nearest exit, not a generic floor plan of the whole building. A diagram on the back of a room door that shows a complete floor plan but does not clearly highlight the route for that particular room does not fully meet the standard’s intent.
Read our full guide: Evacuation Diagrams: Does Your Building Need One?
Fire Safe ANZ produces evacuation diagrams for accommodation buildings of all sizes, including room-specific diagrams and multi-floor common area diagrams that meet AS 3745 requirements.
Evacuation diagrams in your guest rooms may not be meeting the standard. Fire Safe ANZ produces compliant, correctly oriented diagrams for every room and floor. Get in touch
One challenge that is specific to accommodation buildings is that they operate continuously. There is no overnight shutdown during which testing can be carried out without disturbing guests or operations. This requires careful scheduling of routine testing and inspections to minimise disruption while meeting all AS 1851 service frequencies.
Monthly checks, six-monthly discharge tests for emergency lighting, and annual comprehensive inspections all need to be planned around occupancy levels and operational periods. Fire Safe ANZ works with accommodation property managers to schedule servicing in a way that meets compliance requirements with minimal disruption to guests and staff.
If your hotel or accommodation building has a fire safety schedule, you are required to lodge an Annual Fire Safety Statement with your local council every 12 months. From 13 February 2026, the AFSS cannot be endorsed unless maintenance records demonstrate compliance with AS 1851’s prescribed service frequencies across every system on your fire safety schedule.
For a full breakdown of the AFSS process:
Fire Safe ANZ provides comprehensive fire safety compliance services for hotels, motels, boarding houses, and accommodation buildings across NSW, Queensland, Victoria, Western Australia, and beyond. Our services include:
Keep your guests and your property protected with a compliant fire safety program. Call 1300 553 566 or request a quote online
