For property developers in Melbourne’s Eastern Suburbs, bathroom compliance is no longer a straightforward checklist exercise. The National Construction Code (NCC) 2022 introduced the most substantial changes to Australia’s building standards in many years, and with mandatory commencement dates now passed and NCC 2025 preview drafts already published, the regulatory landscape continues to shift. Getting bathroom standards wrong — whether on a townhouse development in the City of Whitehorse or an apartment project in the City of Boroondara — can trigger costly redesigns, permit delays, and failed inspections.
This article outlines the current bathroom standards applicable to new residential construction in Victoria, covering livable housing design requirements, waterproofing specifications, wet area drainage, energy efficiency obligations, and the emerging reforms under NCC 2025. It also addresses the structural changes to Victoria’s building regulatory framework following the establishment of the Building and Plumbing Commission (BPC) on 1 July 2025.
SQM Architects has delivered projects across Melbourne’s Eastern Suburbs over many years. Our team works closely with developers to help ensure bathroom and wet area designs align with current NCC requirements from the earliest design stages — which may help reduce the rework that can affect development margins.
The Regulatory Framework: NCC, Victorian Building Regulations, and the New BPC
In Victoria, bathroom standards are governed by a layered framework. The National Construction Code (NCC) — produced and maintained by the Australian Building Codes Board (ABCB) — sets the minimum technical requirements for design and construction. These are given legal effect in Victoria through the Building Act 1993, the Building Regulations 2018, and the Plumbing Regulations 2018.
A significant structural change took effect on 1 July 2025 with the establishment of the Building and Plumbing Commission (BPC). Created under the Building Legislation Amendment (Buyer Protections) Act 2025 — which received Royal Assent on 3 June 2025 — the BPC consolidates the functions previously held by the Building and Plumbing Commission (BPC), Domestic Building Dispute Resolution Victoria (DBDRV), and the domestic building insurance arm of the Victorian Managed Insurance Authority (VMIA). For developers, this means a single integrated regulator now oversees building quality control, compliance, insurance, and dispute resolution.
The BPC will also have new enforcement powers, including rectification orders directing builders and developers to fix defective work — including after occupancy. A new first-resort statutory warranty scheme applies to projects up to three storeys, and a developer bond applies to apartment buildings above three storeys. These changes have direct implications for how bathroom waterproofing and wet area compliance are documented and inspected throughout construction.
For each project, the appointed building surveyor remains responsible for issuing the building permit and verifying that the proposed design complies with Victorian regulations and the NCC. Under the Building Amendment 2025 Draft Regulations, two additional mandatory notification stages have been prescribed — including a stage during the carrying out of waterproofing work in Class 2, 3, or 4 buildings. This formalises what was previously an informal inspection point and means waterproofing in multi-residential developments now requires a mandatory hold point before concealment.
NCC 2022 Livable Housing Design Requirements: What Applies to Bathrooms
The NCC 2022 introduced Part H8 — Livable Housing Design — which applies to Class 1a buildings (houses and townhouses) and Class 2 sole-occupancy units (individual apartments). In Victoria, the mandatory commencement date for these accessible housing requirements was 1 May 2024. Any building permit issued on or after that date must comply with Part H8.
The livable housing design standard is based on the Livable Housing Design Guidelines silver standard, with a voluntary gold standard available for developments seeking to exceed minimum requirements. The core intent is to ensure housing can accommodate the needs of older Australians and people with mobility limitations — both now and as their needs change over time.
For bathroom and sanitary compartment design specifically, four elements of Part H8 are directly relevant:
- Part 4 – Sanitary compartment: At least one sanitary compartment must be located on the ground or entry level of the dwelling. This compartment must meet prescribed clearance requirements around the toilet pan to allow ease of movement and future adaptation.
- Part 5 – Shower: At least one shower in the dwelling must have a hobless and step-free entry. The standard clarifies that both attributes are required — a shower may be hobless (no hob) but still have a step, which would not comply. An optional lip of no more than 5mm in height may be provided solely to retain water.
- Part 6 – Wall reinforcement: Walls adjacent to toilet pans, showers, and baths must be reinforced to provide a fixing surface capable of supporting the future installation of grab rails. This does not require grab rails to be installed at the time of construction — only that the wall substrate can support them if needed later.
- Part 3 – Internal doors and corridors: The clear opening width of required internal doors — including those leading to the compliant sanitary compartment and bathroom — must be a minimum of 820mm. Note that clear opening width is measured differently from frame opening width, accounting for usable circulation space. Door thresholds must be level or have no more than a 5mm height difference, or a compliant ramp threshold.
It is important to note that only one sanitary compartment and one shower in the dwelling need to comply with Part H8. The compliant shower does not need to be on the ground or entry level — though locating it there is generally considered best practice for accessibility purposes. For developers designing multi-storey townhouses, this provides some flexibility in bathroom layout across levels.
Wall Reinforcement: Materials and Scope
The wall reinforcement requirement under Part 6 of the Livable Housing Design Standard is one of the more frequently misunderstood elements of the NCC 2022 changes. The requirement applies to:
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- The sanitary compartment subject to Part 4
- Any bathroom containing a shower subject to Part 5, or a bath (if provided) — other than a freestanding bath — where the bath is located in a room that also contains a compliant shower
The reinforcement requirement does not apply where walls are constructed of concrete, masonry, or another material inherently capable of supporting grab rails without additional reinforcement. For lightweight framed construction — which is common in townhouse developments across Manningham City Council and Knox City Council areas — additional blocking or backing boards are typically required within the wall framing behind the toilet, shower, and bath zones.
Taps, niches, soap holders, and similar fittings may be fixed to the wall within reinforced zones without affecting compliance. Skirting boards, architraves, toilet roll holders, skirting tiles, and door stops may be disregarded when determining compliance with clearance requirements under Clause 4.2.
For freestanding baths, no wall reinforcement is required — because a freestanding bath has no adjoining walls to which grab rails could be fixed. A bath with only one adjoining wall need only have reinforcing provided in that single adjoining wall.
Wet Area Waterproofing Standards
Waterproofing requirements for wet areas in residential construction are set out in Part 10.2 of the ABCB Housing Provisions, with Australian Standard AS 3740 providing the technical specification. The NCC 2022 introduced updated and more detailed waterproofing requirements for Class 1 buildings, and these have been mandatory in Victoria since 1 May 2023 for the main provisions, with wet area waterproofing updates forming part of that initial commencement.
Key waterproofing requirements for residential bathrooms include:
- Wall height: Floors and walls in wet areas must be waterproofed to a minimum height of 1,800mm to prevent water damage and protect the building fabric.
- Floor falls to wastes: Where a floor waste is installed, the minimum continuous fall of the floor plane to the waste must be 1:80. A maximum continuous fall of 1:50 also applies — meaning falls that are too steep are now non-compliant, not just falls that are too shallow.
- Hobless shower waterproofing: Step-free, hobless showers required under Part H8 have specific waterproofing requirements. Because there is no hob to contain water, the waterproofing membrane and drainage design must compensate. Part 10.2 of the ABCB Housing Provisions and AS 3740 include specific provisions for this configuration.
Under the Building Amendment 2025 Draft Regulations, waterproofing work in Class 2, 3, and 4 buildings now triggers a mandatory notification stage. This means the building surveyor must be notified before waterproofing is concealed — effectively creating a mandatory inspection hold point. Developers and builders working on apartment projects in the City of Monash or Maroondah City Council areas should factor this inspection stage into their construction programmes to avoid delays.
Energy Efficiency and Condensation Requirements
The NCC 2022 also introduced updated energy efficiency and condensation mitigation requirements that affect bathroom design, particularly in relation to ventilation and thermal performance. In Victoria, these requirements became mandatory on 1 May 2024.
For bathrooms, the condensation mitigation provisions are particularly relevant. Bathrooms are high-moisture environments, and inadequate ventilation can lead to condensation-related damage and mould growth — issues that have generated significant warranty claims and disputes in multi-residential developments. The NCC 2022 requirements address construction details, vapour management, and ventilation to reduce condensation risk.
The minimum thermal performance requirement for Class 1 and Class 2 buildings has increased from 6-star to 7-star NatHERS (National Home Energy Rating Scheme). While this primarily affects the building envelope rather than bathroom fitout, it influences decisions about window placement, glazing specifications, and exhaust ventilation design — all of which intersect with bathroom layout in medium-density developments.
Lead-Free Plumbing Products: Mandatory from 1 May 2026
One of the most significant upcoming changes for bathroom specification is the mandatory commencement of lead-free plumbing product requirements on 1 May 2026. From this date, plumbing products intended for use in contact with drinking water — including tapware, mixers, and fittings commonly specified in bathrooms — must comply with new lead-free standards.
For developers with projects currently in design or documentation, this deadline has direct implications for product specification. Tapware and fittings specified now for projects completing after May 2026 may need to be reviewed against the new requirements. The WaterMark Certification Scheme, administered by the ABCB, lists compliant plumbing and drainage products — and this list is updated regularly as manufacturers achieve certification for lead-free products.
Developers and their design teams may need to allow additional lead time for product procurement, particularly for projects where specific tapware aesthetics are important to the development’s market positioning.
NCC 2025: What’s on the Horizon
The ABCB has published preview drafts of NCC 2025, covering Volume One, Volume Two, Volume Three (Plumbing Code of Australia), the Housing Provisions, and the Liveable Housing Design Standard. While NCC 2025 has not yet been formally adopted, the preview drafts signal the direction of upcoming changes.
From 1 May 2025, NCC 2022 is to be read in conjunction with NCC 2022 Amendment 1, which includes minor corrections and state-specific variations. From 29 July 2025, NCC 2022 Amendment 2 also applies — aligning the NCC with recent amendments to the Disability (Access to Premises – Buildings) Standards 2010 (Premises Standards). These amendments affect accessibility requirements in Class 2 buildings and may have implications for bathroom design in apartment developments.
A submission has also been prepared to the ABCB requesting that NCC 2025 include provision for all-gender bathrooms as an acceptable configuration under the code. While this has not yet been adopted, it reflects an emerging area of regulatory development that developers of commercial and mixed-use projects may need to monitor.
Victoria’s Townhouse and Low-Rise Code: Implications for Bathroom Design
Amendment VC267, gazetted in early 2025, introduced the Townhouse and Low-Rise Code (Clause 55) and the 4 Storey Apartment Standards (Clause 57) into Victoria’s planning schemes. These changes have direct relevance for developers of medium-density residential projects across Melbourne’s Eastern Suburbs.
The new Clause 55 introduces “deemed to comply” standards for multi-residential developments of three storeys or less. Developments that meet these standards may benefit from a faster and more certain planning permit process, with no third-party appeal rights. Relevant to bathroom and internal amenity design, the new standards include:
- Standard B3-7 – Functional layout: Applies minimum apartment bedroom and living room dimensions to all dwellings, including townhouses. This affects how bathroom footprints interact with overall floor plan efficiency.
- Standard B3-8 – Room depth: Applies minimum apartment room depth requirements to all dwellings, influencing the planning of ensuite and main bathroom configurations.
- Standard B3-4 – Entry: Simplified and made deemed to comply, incorporating elements from existing accessibility standards — which interact with the NCC Part H8 requirements for step-free access.
For developers targeting the deemed-to-comply pathway under the new Townhouse and Low-Rise Code, bathroom design must satisfy both the planning scheme standards and the NCC 2022 livable housing design requirements simultaneously. Coordinating these two regulatory layers from the earliest design stages is essential to help avoid conflicts that could delay the planning permit process.
Renovation and Existing Dwellings: When Do New Standards Apply?
A common question from developers undertaking renovation or refurbishment projects is whether the NCC 2022 livable housing design requirements apply to existing bathrooms. The answer depends on the nature and extent of the work.
For like-for-like replacements — such as retiling floors, replacing a vanity, or swapping a toilet — the new standards may not apply, provided the work complies with the original standard for waterproofing, drainage, and the like. However, where a bathroom is being substantially reconfigured or a new bathroom is being created in a space that did not previously function as a bathroom, the new requirements may apply to that bathroom as if it were new construction.
Where a dwelling previously complied with the livable housing design standard, some exclusions apply to renovation work. For example, additional circulation space is not required if the room size would need to be increased to achieve compliance and no walls are being moved. Minimum door opening requirements are not triggered unless the door itself is being demolished and replaced. However, if a new compliant shower is being installed — for example, removing a hob to create a step-free entry — the waterproofing must comply with current standards for hobless shower configurations.
Developers undertaking value-add renovation strategies on existing stock in the City of Boroondara or Manningham City Council areas should seek specific guidance on which requirements may apply to their proposed scope of works before committing to a design.
Frequently Asked Questions
Do all bathrooms in a new dwelling need to comply with the NCC 2022 livable housing design requirements?
No. Only one sanitary compartment and one shower in the dwelling need to comply with Part H8 of the NCC 2022. The compliant sanitary compartment must be on the ground or entry level, but the compliant shower does not need to be — though locating it on the entry level is generally considered best practice. All other bathrooms in the dwelling are not subject to Part H8 requirements.
What does “hobless and step-free” mean for shower design, and why are both required?
A hobless shower has no raised hob or threshold at the shower entry. A step-free shower has no level change between the shower floor and the adjacent floor. Both attributes are required because a shower can be hobless but still have a step — for example, where the shower floor is recessed below the bathroom floor level. The NCC 2022 requires both conditions to be met simultaneously to achieve a genuinely accessible shower entry. An optional lip of no more than 5mm may be provided solely to retain water.
When does the mandatory waterproofing inspection stage apply in Victoria?
Under the Building Amendment 2025 Draft Regulations, a mandatory notification stage during waterproofing work applies to Class 2, 3, and 4 buildings — that is, apartment and multi-residential developments. The building surveyor must be notified before waterproofing is concealed. This requirement commenced on 30 June 2025. Developers should factor this hold point into construction programmes to avoid delays.
What is the deadline for lead-free plumbing products, and does it affect current projects?
Lead-free plumbing product requirements become mandatory in Victoria on 1 May 2026. Tapware, mixers, and fittings specified for projects completing after this date may need to be reviewed for compliance with the new standards. Developers and their design teams may need to allow additional procurement lead time, particularly for projects where specific product aesthetics are important to the development’s market positioning.
Does the new Townhouse and Low-Rise Code (Clause 55) affect bathroom design requirements?
Yes, indirectly. The new deemed-to-comply standards under Clause 55 include functional layout and room depth requirements that affect how bathroom footprints interact with overall floor plan efficiency in townhouse and low-rise apartment developments. Bathroom design must satisfy both the planning scheme standards under Clause 55 and the NCC 2022 livable housing design requirements simultaneously. Coordinating these requirements from the earliest design stages helps avoid conflicts that could delay the planning permit process.
Do the NCC 2022 livable housing design requirements apply in all Victorian councils?
Yes. The NCC 2022 Part H8 livable housing design requirements became mandatory across Victoria on 1 May 2024 for all new Class 1a and Class 2 buildings. There are no council-specific exemptions. Note that in New South Wales, Part H8 does not apply to Class 1a buildings — but this exemption does not extend to Victoria. Developers working across state borders should be aware of this distinction.
What is the role of the Building and Plumbing Commission (BPC) compared to the former BPC?
The BPC, established on 1 July 2025, consolidates the functions of the Building and Plumbing Commission (BPC), Domestic Building Dispute Resolution Victoria (DBDRV), and the domestic building insurance arm of VMIA into a single integrated regulator. For developers, the BPC is now the primary point of contact for building compliance, insurance, and dispute resolution. The BPC also has new powers including rectification orders — which can direct builders and developers to fix defective work, including after occupancy — making documentation of bathroom waterproofing and wet area compliance more important than ever.
Conclusion
Bathroom standards in Australia have undergone substantial change since the NCC 2022 reforms took effect, and the regulatory environment continues to evolve with NCC 2025 preview drafts published, the BPC now operational, and lead-free plumbing requirements approaching in May 2026. For property developers in Melbourne’s Eastern Suburbs, staying across these requirements is not optional — non-compliance may result in failed inspections, mandatory rectification, and delays that could affect development margins. The interaction between NCC Part H8 livable housing design requirements, updated waterproofing standards, the new Townhouse and Low-Rise Code under Clause 55, and the BPC’s expanded enforcement powers means that bathroom design decisions made early in a project may have significant downstream consequences.
SQM Architects has worked with property developers across the City of Whitehorse, City of Boroondara, Manningham City Council, City of Monash, Knox City Council, and Maroondah City Council on a wide range of residential projects. Our team can help you navigate current bathroom and wet area standards from concept through to building permit — which may help reduce the risk of costly redesigns and compliance delays. Book a Strategy Call to discuss your project’s specific requirements.
This article provides general information about Victorian building standards for property developers. It does not constitute professional advice. For specific guidance on your project, contact SQM Architects for a complimentary site assessment.
