Victoria’s planning and construction landscape shifted significantly in 2025, and apartment developers who haven’t yet reviewed their project designs against the new solar requirements may be carrying unquantified risk into their next planning permit application. Between Amendment VC267 (March 2025), the updated National Construction Code (NCC 2025, effective October 2025), and the broader reforms introduced under the Planning Amendment (Better Decisions Made Faster) Bill 2025, the rules governing solar access, solar-ready design, and on-site energy generation for Class 2 apartment buildings have changed materially. Understanding what changed, when it applies, and how it affects your development costs and approval pathway is now a baseline requirement for feasibility modelling.
This article outlines the key changes affecting small-to-medium apartment developers in Melbourne’s Eastern Suburbs — covering projects from four-storey walk-ups through to mid-rise apartment buildings. It covers what the new standards require, which projects are affected, how the changes interact with planning permit timelines, and what action items developers should prioritise before lodging their next application.
SQM Architects has worked across a range of apartment and multi-dwelling projects in Melbourne’s Eastern Suburbs. The following information draws on that experience alongside the current regulatory framework — but it is general information, not professional advice specific to your site.
What Changed: The Three Layers of New Solar Requirements
The new solar requirements for apartment developers operate across three distinct regulatory layers, each with different triggers and implications. Developers need to understand all three to accurately assess their design obligations.
Layer 1: NCC 2025 — Mandatory On-Site Solar for Class 2 Buildings
The National Construction Code 2025, which took effect in October 2025, introduced mandatory on-site solar photovoltaic (PV) requirements for Class 2 buildings — the building classification that covers most apartment developments. Under NCC 2025, common areas of new apartment buildings must be served by on-site solar generation. The code also requires “battery-ready” electrical switchboards, meaning reserved circuit breaker slots and DIN rail spaces must be incorporated into the building’s electrical design from the outset.
For developers, this is no longer a design aspiration or a sustainability credit — it is a construction compliance requirement. Buildings that do not incorporate compliant solar systems and battery-ready switchboards may not receive an occupancy permit. This means the solar system must be integrated into structural and electrical design from concept stage, not retrofitted during documentation. Switchboard upgrades can add meaningful cost if not scoped early; electrical engineers should be engaged at schematic design to confirm capacity and layout requirements.
Layer 2: Amendment VC267 — New Clause 57 for Four-Storey Apartments
Amendment VC267, gazetted in March 2025, introduced Clause 57 as the governing planning scheme standard for four-storey residential apartment developments. This is a significant structural change: four-storey projects previously assessed under Clause 55 (ResCode) now have their own dedicated clause with specific sustainability standards, including solar access requirements for communal open space (Standard D11) and energy efficiency performance (Standard D6).
Importantly, Clause 57 retains full third-party appeal rights at VCAT — unlike the deemed-to-comply pathway available under Clause 55 for lower-density projects. This means four-storey apartment developers cannot rely on code compliance alone to eliminate objection risk. Design quality and solar performance standards that are clearly addressed in the application may help reduce VCAT exposure. Clause 58 continues to govern apartment developments of five or more storeys, with equivalent solar access and energy efficiency standards applying.
Layer 3: Standard B5-2 and B5-3 — Solar Protection and Solar-Ready Roofs
Under Clauses 55 and 57, two new sustainability standards now apply directly to apartment and multi-dwelling developments. Standard B5-3 requires developers to set aside unobstructed rooftop space for solar PV — a designated solar energy generation area that must be incorporated into the roof design. Standard B5-2 introduces solar protection obligations, requiring that new developments do not overshadow existing rooftop solar installations on neighbouring properties between 9am and 4pm on 22 September (the equinox).
The solar protection standard has direct implications for building envelope design. On sites where neighbouring properties have existing solar panels — particularly on north-facing boundaries — developers may need to reduce building height, adjust roof form, or modify upper-level setbacks to achieve compliance. Shadow diagrams demonstrating compliance with Standard B5-2 are now a standard application requirement, and the responsible authority will assess these as part of the planning permit process.
Who’s Affected: Project Types and Thresholds
The new solar requirements affect a broad range of apartment project types, but the specific obligations vary depending on building height, storey count, and the planning scheme clause under which the project is assessed.
- Two to three-storey multi-dwelling developments: Assessed under Clause 55 (Townhouse and Low-Rise Code). Standards B5-2 and B5-3 apply. Deemed-to-comply pathway available if all standards are met, which may remove third-party VCAT appeal rights.
- Four-storey apartment buildings: Now assessed under Clause 57 (introduced via VC267). Solar access to communal open space (D11) and energy efficiency (D6) apply. Third-party appeal rights are retained regardless of code compliance.
- Five or more storeys: Assessed under Clause 58. Standards D6 and D11 apply. NCC 2025 mandatory solar requirements also apply to common areas.
- All Class 2 buildings (new construction): Subject to NCC 2025 mandatory on-site solar and battery-ready switchboard requirements, regardless of storey count.
Developers working within the 60 Activity Centres designated under Plan for Victoria should also note that the Housing Choice and Transport Zone (HCTZ) applies within the 800-metre walkable catchment of these centres. Sites over 1,000m² in Inner Catchments may achieve up to six storeys under the Built Form Overlay — but all solar requirements apply at the relevant clause for that building height. Higher density does not reduce solar compliance obligations; in many cases it increases their complexity due to roof space constraints and neighbouring overshadowing considerations.
In Melbourne’s Eastern Suburbs, developers working across the City of Whitehorse, City of Boroondara, Manningham City Council, City of Monash, Knox City Council, and Maroondah City Council will find that state-level solar standards now set the baseline. However, some councils may apply additional local policy requirements — particularly in areas with heritage overlays or established sustainability policies — so early pre-application engagement with the relevant responsible authority remains important.
Timeline: When Do These Requirements Apply?
Understanding the effective dates is important for developers with projects currently in design or pre-lodgement stages.
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- Amendment VC267 (Clause 57): In effect from March 2025. Any four-storey apartment planning permit application lodged after this date is assessed under Clause 57.
- NCC 2025 (mandatory solar and battery-ready switchboards): Effective October 2025. All building permit applications for new Class 2 buildings lodged after this date must comply.
- Standard B5-2 and B5-3: Operative under the current planning scheme. Applications lodged now must address these standards.
- Solar for Apartments rebate program (Round 3): Available until 30 April 2026, or until the rebate allocation is exhausted. Up to $2,800 per apartment, capped at $140,000 per building, for buildings up to eight storeys with between 5 and 50 participating lots — subject to program terms; confirm current figures with Solar Victoria before relying on these amounts. Note: this rebate applies to completed buildings under owners corporation management — not to new developments under construction — but is relevant for developers considering the long-term appeal of their product to purchasers and owners corporations.
- Planning Amendment (Better Decisions Made Faster) Bill 2025: Passed in early 2026. Introduces a three-tier permit classification system (Type 1: 10 business days; Type 2: 30 business days; Type 3: 60 business days). Projects that meet deemed-to-comply standards under Clause 55 may qualify for faster assessment with restricted third-party appeal rights.
What Developers Should Do Now
The cumulative effect of these changes means that solar requirements can no longer be treated as a late-stage design consideration. The following action items reflect what developers should be addressing at each project stage.
At Feasibility Stage
- Assess available rooftop area against Standard B5-3 requirements. Complex roof forms, plant rooms, and lift overruns compete with the unobstructed solar generation area required by the standard.
- Identify whether neighbouring properties have existing solar installations, particularly on north-facing boundaries. Commission a preliminary solar access analysis to assess Standard B5-2 exposure before committing to a building envelope.
- Incorporate estimated solar system costs into your development budget. For a 20-apartment building, indicative system costs (panels, inverters, cabling, switchboard upgrades, and solar sharing technology) may range from $40,000 to $120,000 depending on system size and building complexity — though your electrical engineer and solar retailer should provide project-specific estimates.
- Confirm which planning scheme clause applies to your project based on storey count and zone, and assess whether the deemed-to-comply pathway under Clause 55 is achievable for lower-density projects.
At Design Stage
- Engage your electrical engineer at schematic design — not at documentation — to confirm NCC 2025 switchboard and solar system requirements.
- Integrate the solar energy generation area (Standard B5-3) into the roof design from the outset. Retrofitting this into an advanced design is costly and may require redesign of structural elements.
- Produce shadow diagrams demonstrating Standard B5-2 compliance. These are required at planning permit application stage and should be used to inform the building envelope during design development.
- For four-storey projects under Clause 57, ensure the design clearly addresses Standards D6 and D11 to help reduce VCAT exposure, even though deemed-to-comply protections do not apply at this scale.
At Planning Permit Application Stage
- Include solar access analysis and shadow diagrams in the application package as a standard item — not an afterthought.
- Confirm the permit classification under the new three-tier system to understand your likely assessment timeframe and third-party appeal exposure.
- For projects in Activity Centres, confirm whether the HCTZ applies and what density uplift may be achievable, noting that higher density does not reduce solar compliance obligations.
Frequently Asked Questions
Does my four-storey apartment project need to install actual solar panels, or just provide solar-ready roof space?
Under the planning scheme standards (B5-3), the requirement is to provide an unobstructed solar energy generation area — the standard does not mandate actual panel installation at the planning permit stage. However, NCC 2025 requires mandatory on-site solar for common areas of Class 2 buildings at building permit stage. In practice, most four-storey apartment projects will need to install a functioning system to achieve building permit compliance.
What happens if a neighbouring property’s solar panels are already overshadowed before my project is built?
Standard B5-2 requires that your development does not overshadow more than a specified proportion of an adjoining solar panel array between 9am and 4pm on 22 September. The responsible authority must consider the extent of existing overshadowing when assessing your application. If the panels are already significantly overshadowed by existing structures, this context may be relevant — but you should not assume existing overshadowing eliminates your compliance obligation. A solar access analysis prepared by a qualified consultant will clarify your position.
Can my project qualify for the Solar for Apartments rebate program?
The Solar for Apartments Program (Round 3, available until 30 April 2026, subject to program terms) may be available to completed buildings under owners corporation management — not to projects under construction or off-the-plan. The rebate is up to $2,800 per apartment, capped at $140,000 per building, for buildings up to eight storeys with between 5 and 50 participating lots — confirm current eligibility criteria with Solar Victoria. As a developer, this programme may be relevant to your marketing and handover strategy, but it cannot be accessed during the construction phase.
How does the new three-tier permit classification affect my apartment project’s approval timeline?
Under the Planning Amendment (Better Decisions Made Faster) Bill 2025, complex apartment projects (Type 3) may be assessed within 60 business days, with third-party appeal rights restricted to directly impacted neighbours sharing a boundary. Lower-density projects that meet deemed-to-comply standards under Clause 55 in some cases may qualify for Type 2 assessment (30 business days) with further restricted appeal rights. The classification your project receives will depend on its scale, zone, and whether it meets the relevant code standards — including the new solar requirements.
Do the new solar requirements add significant cost to a typical small apartment project?
The cost impact varies considerably depending on project scale, roof complexity, and whether switchboard upgrades are required. For a small apartment project of 10 to 20 dwellings, indicative additional costs associated with solar system installation, battery-ready switchboard provisions, and solar access analysis could range from $30,000 to $100,000+ — though these figures are indicative only and your project team should develop site-specific estimates. Early integration of solar requirements into the design may reduce costs compared to late-stage redesign.
Are there council-specific solar requirements I need to be aware of in Melbourne’s Eastern Suburbs?
State-level planning scheme standards and NCC 2025 set the baseline requirements across all councils. However, some councils may apply additional local policy overlays — particularly in heritage areas or where sustainability management plan requirements apply. Pre-application meetings with the relevant responsible authority (City of Whitehorse, City of Boroondara, Manningham City Council, City of Monash, Knox City Council, or Maroondah City Council) are the most reliable way to identify any council-specific requirements that may apply to your site.
What is the solar protection standard and how does it affect my building height?
Standard B5-2 requires that your development does not overshadow existing rooftop solar installations on adjoining properties beyond a specified threshold between 9am and 4pm on 22 September. In practice, this standard may constrain building height or upper-level setbacks on north-facing boundaries where neighbouring properties have solar panels. Shadow diagrams must be submitted with your planning permit application, and the responsible authority will assess compliance as part of the permit process.
What This Means for Your Next Project
Victoria’s new solar requirements for apartments represent a genuine shift in the baseline design and compliance obligations for developers — not a marginal adjustment. The combination of NCC 2025 mandatory solar, planning scheme Standards B5-2 and B5-3, and the new Clause 57 framework for four-storey projects means that solar access analysis, solar-ready roof design, and on-site generation systems must be integrated from feasibility stage. Developers who treat these requirements as a late-stage add-on risk cost overruns, design rework, and planning permit delays. Those who integrate them early may find that compliance also supports faster permit assessment under the new three-tier classification system — a potentially useful outcome in the current market.
SQM Architects has worked across a range of apartment and multi-dwelling projects in Melbourne’s Eastern Suburbs. If you are assessing a site or preparing a planning permit application for an apartment project, understanding your solar compliance obligations from day one is part of sound project management. Contact SQM Architects to arrange a complimentary site assessment and discuss how the current regulatory framework applies to your project.
Request a Complimentary Site Assessment — or call us on (03) 9005 6588.
This article provides general information about Victorian planning for property developers. It does not constitute professional advice. For specific guidance on your project, contact SQM Architects for a complimentary site assessment.
