Emergency Lighting Requirements in QLD: Does Your Business Need Exit Signs and Emergency Lights?
Most business owners only think about emergency lighting when a fit-out certifier, a fire safety adviser or the landlord asks about it. By then the lease is signed and the opening date is set. Knowing early whether your premises needs emergency lights and exit signs, and who has to look after them, saves a scramble later.
This guide covers where the rules come from, which buildings and rooms need emergency lighting under the code in force in Queensland, when exit signs are required, what changes when you fit out or change the use of a tenancy, and who is responsible once the fittings are on the ceiling. If you already know you have them and need them looked after, our emergency and exit lighting maintenance covers the testing and records. For how often they must be tested, see our separate guide to emergency lighting testing in QLD.
Where emergency lighting requirements come from in Queensland
Two sets of rules apply here.
- The National Construction Code (NCC) decides whether a building needs emergency lighting and exit signs in the first place. Part E4 of NCC Volume One covers “visibility in an emergency, exit signs and warning systems”.
- Queensland’s fire safety laws decide who has to keep those installations working. The Building Fire Safety Regulation 2008 makes the occupier of a building responsible for maintaining each prescribed fire safety installation.
Business Queensland says the state has delayed the start of NCC 2025 until 1 May 2027, and that NCC 2022 continues to apply to building work in Queensland until then. Everything below is based on NCC 2022.
Which businesses need emergency lighting under the NCC?
The NCC sorts buildings into classes. The ones most small businesses deal with are Class 5 (offices), Class 6 (shops and other premises that sell to the public) and Class 9b (places where people assemble, such as entertainment and recreation venues). The NCC’s building classification guidance says that if the general public has access to a Class 6 building, it is considered a shop. Your building certifier confirms the class for your premises, and some uses, such as gyms, clinics and venues with live entertainment, need a closer look.
Under clause E4D2 of NCC 2022 Part E4, as we read it, emergency lighting is required in these situations most relevant to business premises:
| Situation | Emergency lighting required? | Who it usually catches |
|---|---|---|
| Any storey over 300 m² in a Class 5, 6, 7, 8 or 9 building | Yes, in passageways on the path of travel to an exit, rooms over 300 m², and rooms over 100 m² that don’t open to a corridor or space with emergency lighting, or to a road or open space | Larger shops, office floors, warehouses, showrooms |
| A Class 5, 6 or 9 sole-occupancy unit over 300 m² whose exit doesn’t open to a road or open space | Yes | Tenancies inside arcades, centres and multi-level buildings |
| Rooms open to the public in a Class 6 or 9b building where the storey is over 300 m², any point is more than 20 m from a qualifying doorway, or getting out involves a vertical rise over 1.5 m | Yes | Deep, narrow shops, cafes and venues with stairs or a mezzanine |
| Every fire-isolated stairway, passageway or ramp, and every required non-fire-isolated stairway | Yes | Any multi-storey building, including unit blocks |
| Class 2 and 3 buildings (units, short-stay accommodation): passageways over 6 m from a unit door to an exit, external stair, balcony, road or open space | Yes | Strata buildings and holiday apartment complexes |
| A small single-storey shop or office under 300 m², with every point close to a door that opens straight onto the street | Often not, but check the room-size and 20 m tests | Strip-shop tenancies, small studios and consulting rooms |
There are further triggers for health-care buildings (Class 9a), aged care (Class 9c) and fire control centres. The table is a plain-English summary of the clause, not a substitute for it. The distances are measured along the actual path of travel, not in a straight line, which is why a long, narrow shop can trip the 20 m test even when it feels small.
Every required system must comply with AS/NZS 2293.1, the Australian Standard for emergency lighting and exit signs. That’s where the detail on fitting types, spacing and duration lives, and it’s why emergency lighting design is a job for an electrician who works with the standard.
When do you need exit signs?
Clause E4D5 requires exit signs to be clearly visible to people approaching, and installed on, above or next to doors that serve as required exits, such as doors to stairs, passageways and ramps, doors to external access balconies, discharge doors and horizontal exits. It also requires them above doors on any storey that needs emergency lighting under E4D2.
As a rule of thumb, if a storey needs emergency lighting, it needs exit signs too. Where the way out isn’t obvious, clause E4D6 adds direction signs in corridors, hallways, lobbies and foyers pointing people to the exit. Exit signs must comply with AS/NZS 2293.1, or with the NCC’s specification for photoluminescent signs, and must be clearly visible whenever people with a legal right of entry are in the building.
Fit-outs, new leases and changing the use of a tenancy
Most of the questions we get about emergency lighting come up at one of these points.
- A fit-out that needs building approval. New building work is assessed against the code in force when the approval is given. Queensland’s Building Act 1975 also says alterations can’t be approved if they unduly reduce existing fire protection and egress, and in some cases a certifier can require part of an existing building to be brought up to current provisions. Moving walls, adding a mezzanine or creating a back room often changes what’s needed.
- A change of use. Turning a shop into a gym, a warehouse into a showroom, or an office into a clinic can change the building’s class, and with it the emergency lighting triggers. Talk to a building certifier before you sign, not after.
- Taking over an existing lease. The previous tenant’s lights may have been compliant for their layout and still fail their tests today. Ask for the maintenance records and the last occupier statement before you take the keys. Our guide to commercial lease electrical checks covers the rest of that list.
For what a full electrical fit-out involves, including handover documents, see our commercial fit-out guide.
Who is responsible for emergency lights once they’re installed?
The occupier. Section 54 of the Building Fire Safety Regulation says the occupier of a building must ensure each prescribed fire safety installation is maintained by an appropriately qualified person and inspected and tested at the intervals set by the Queensland Development Code, part MP 6.1. A Queensland Fire Department information sheet for unit buildings names exit signs and emergency lighting as prescribed fire safety installations.
Business Queensland’s page on fire safety installations in buildings spells out who that is:
- If a tenant occupies the building, the tenant must ensure the fire safety installations are maintained.
- If the owner occupies it, the owner does. If there’s no occupier, the owner signs the occupier statement.
- In a building with several tenancies, each occupier generally looks after the installations in its own tenancy and the building manager looks after common areas.
- A body corporate can contract an appropriately licensed person for ongoing maintenance of common property.
The regulation also sets deadlines once a fault is found. Repairs or corrective action shown as needed in the maintenance record must happen no later than one month after the maintenance was carried out, unless the occupier has a reasonable excuse. The person doing the maintenance must give the occupier a critical defect notice within 24 hours if they find a critical defect. And the occupier must prepare an occupier statement at the intervals set by MP 6.1, which Business Queensland describes as yearly, and give a copy to the QFD Commissioner within 10 business days after it is due.
Get an electrician in now if
- An exit sign or emergency light is dark, flashing or showing a fault light
- Fittings have been painted over, covered by signage or blocked by stock
- Your last test is overdue or nobody can find the log book
- You’ve moved walls or shelving and an exit sign is no longer visible from the path to the door
- There’s a burning smell or scorch mark at any fitting
The QFD’s Fire Safety Management Tool advisory notes say a licensed electrician or appropriately qualified person is required to conduct the emergency lighting maintenance inspections, that a log book (which can be electronic) records the six-monthly and annual inspections, and that the occupier must keep exit sign covers clean, in place and unbroken. If you have a flashing fitting now, our post on why an exit light flashes explains what it usually means.
What we check when a business asks “do we need emergency lighting?”
From our experience on Gold Coast tenancies, the answer is rarely a simple yes or no. A site visit usually covers:
- The floor area of each storey and of the larger rooms, and whether each room opens to a lit space or straight outside.
- The walking distance from the furthest point to a door that leads outside, measured along aisles, not as the crow flies.
- Stairs, ramps and mezzanines, including short level changes at the back of a shop.
- What’s already installed, its age, and whether it still passes a discharge test.
- Whether exit signs can be seen from the path of travel once stock, partitions and signage are in.
Where a building certifier is involved, we work to their requirements. Where none is, we tell you what we found and what the code says, and quote any work at a fixed price before we start. Ongoing testing can go into a preventative maintenance programme so the six-monthly checks and records happen without anyone having to remember them.
Emergency lighting for southern Gold Coast businesses
We look after emergency and exit lighting for shops, offices and strata buildings from Palm Beach and Burleigh Heads through to Coolangatta, plus the office and retail precincts in Varsity Lakes and Robina. In our experience, beachside tenancies in Miami and along the Gold Coast Highway see more corrosion on fitting terminals and battery contacts than inland sites, which is one reason coastal fittings can fail their discharge tests sooner than expected.
The work runs through our emergency and exit lighting service, with strata and body corporate work for common property, and shop and office lighting where the general lighting is being redone at the same time. If you’re working through the strata side of this, see hiring an electrician for a body corporate.
Frequently asked questions
Does a small shop need emergency lighting in Queensland?
Not always. Under NCC 2022 Part E4, a Class 6 shop needs emergency lighting where a storey is over 300 m², or where rooms open to the public are more than 20 m from a qualifying door or involve a vertical rise over 1.5 m. A small single-storey shop with doors straight onto the street may not. A building certifier or electrician can check your layout.
Do I need exit signs if I have emergency lighting?
Usually yes. NCC clause E4D5 requires exit signs above doors on any storey that needs emergency lighting, as well as on required exits such as stair, passage and discharge doors. Where the way out isn’t obvious, direction signs are needed too. Exit signs must comply with AS/NZS 2293.1 or the NCC’s photoluminescent sign specification.
Who is responsible for emergency lighting in a leased shop or office?
The occupier. Business Queensland says that if a tenant occupies the building, the tenant must ensure fire safety installations are maintained. In multi-tenancy buildings each occupier generally looks after its own tenancy and the building manager looks after common areas. Check your lease too, because it can allocate costs differently.
Does an existing building have to upgrade to the latest code?
Not simply because the code changed. The NCC applies mainly to new buildings and new building work. But Queensland’s maintenance rules apply to existing buildings, and when you do building work, such as a fit-out needing approval, the certifier assesses it against current provisions and can sometimes require existing parts to be upgraded.
Which version of the National Construction Code applies in Queensland right now?
NCC 2022. Business Queensland says the Queensland Government delayed the start of NCC 2025 until 1 May 2027, so NCC 2022 continues to apply to building and plumbing work in Queensland until then. If your fit-out approval is issued after that date, check with your certifier which edition applies.
Can staff test the emergency lights themselves?
Staff can do a quick visual check that fittings are lit and undamaged. The formal six-monthly and annual inspections are different. The Queensland Fire Department’s guidance says a licensed electrician or appropriately qualified person is required to conduct them, with results recorded in a log book, which can be electronic.
What happens if an emergency light fails its test?
The Building Fire Safety Regulation says repairs shown as needed in the maintenance record must be done no later than one month after the maintenance, unless the occupier has a reasonable excuse. If the fault is a critical defect, the person doing the maintenance must give the occupier a critical defect notice within 24 hours.
Do body corporates need emergency lighting in unit blocks?
Often, yes. NCC Part E4 requires emergency lighting in fire-isolated stairways and in Class 2 and 3 buildings where a passageway from a unit door to an exit is longer than 6 m. Business Queensland says a body corporate can contract an appropriately licensed person to maintain common property installations.
Need to know whether your premises needs emergency lighting or exit signs? Call us. We’ll check the layout and what’s installed, and give you a fixed price on site for any work.