Tenant Fit-Out Evacuation Diagram Requirements in Australia

A commercial fit-out, whether it's a full strip-out and rebuild or a modest internal reconfiguration, almost always triggers an obligation to update evacuation diagrams. Yet this is one of the most commonly overlooked compliance steps in the fit-out and handover process. The result is that newly completed tenancies open for business with diagrams that bear no resemblance to the actual layout, or with no diagrams at all.

The obligations around fit-out evacuation diagrams sit at the intersection of several regulatory frameworks: AS 3745:2010 (the Australian Standard for emergency planning in facilities), the National Construction Code (NCC), Work Health and Safety legislation, and the specific terms of the lease. Understanding which party is responsible for what, and at which point in the fit-out timeline, prevents compliance gaps at handover and avoids disputes between landlords and tenants.

When Does a Fit-Out Trigger New Evacuation Diagrams?

AS 3745:2010 requires that evacuation diagrams accurately represent the current layout of the facility. Any change to the physical layout that alters exit paths, changes the location of fire safety equipment (extinguishers, hose reels, first aid kits), creates or removes compartments, or changes the assembly area arrangement is a trigger for diagram review and update.

In practice, most commercial fit-outs exceed this threshold. Even a relatively minor fit-out that adds a partitioned meeting room or reconfigures a reception area changes the exit path geometry visible from that part of the floor. A full floor fit-out, stripping back to a base building shell and rebuilding the entire tenancy, requires a complete set of new diagrams before occupation.

The trigger is the change in layout, not the scale of the works. A small tenancy that adds a single internal wall next to an existing evacuation diagram location has technically created a requirement to update that diagram to reflect the new wall. For practical purposes, any fit-out that involves a development application (DA) or building approval, or that requires a new occupation certificate, should automatically include evacuation diagram updates as part of the handover checklist.

• Any new or removed internal partitions that affect exit paths
• Relocation of fire extinguishers, hose reels, or first aid kits
• Addition or removal of doorways, including changes to door swing direction
• Changes to stairwell access or fire door arrangements
• New plant or equipment rooms that alter the floor plan
• Reconfiguration of open-plan areas that changes the path to exits
• Changes to assembly areas or emergency access routes

Landlord vs Tenant Obligations

The division of responsibility between landlord and tenant for evacuation diagrams is a source of genuine confusion in the commercial property sector. The short answer under AS 3745:2010 is that the occupier of a facility, the entity that controls and uses the space, is primarily responsible for maintaining compliant evacuation diagrams. In most commercial leases, that is the tenant.

However, base building diagrams, which cover common areas such as fire stairs, lobbies, car parks and end-of-trip facilities managed by the building owner, remain the landlord's responsibility. Where a tenancy connects to these common areas, the base building diagrams need to be consistent with the tenancy diagrams so that an evacuee moving from the tenancy into a stairwell encounters signage that is coherent and consistent.

The lease itself may impose additional obligations. Many commercial leases in Australia now include provisions requiring the tenant to obtain and maintain compliant evacuation diagrams, to notify the landlord's building manager before commencing fit-out works, and to provide updated diagrams to the building manager as part of the fit-out handover. Tenants who overlook these lease obligations may find themselves in breach of their lease as well as WHS legislation.

• Tenant responsibility: diagrams within the demised tenancy area
• Landlord responsibility: base building common areas, fire stairs, car parks, lobbies
• Joint responsibility: coordination between tenancy and base building diagrams at interface points
• Check your lease: many modern leases impose explicit diagram obligations on tenants
• Building manager: should hold a master set of all diagrams across the building

What Triggers a DA or Building Approval Requirement

Not all fit-out works require a development application or building approval, and the threshold varies between jurisdictions. In New South Wales, internal fit-out work that does not involve structural changes, changes to the building envelope, or changes to the fire and life safety systems may be carried out under a Complying Development Certificate (CDC) or may be exempt development in some circumstances. In Victoria, similar works may require a Building Permit.

Where a building permit or CDC is required, the certifier will typically include evacuation signage and diagrams as part of the compliance certificate conditions. In these cases, the certificate of occupancy or certificate of final inspection cannot be issued until the applicant can demonstrate that compliant evacuation diagrams are in place. This creates a hard deadline for diagram completion within the fit-out timeline.

Even where formal building approval is not required, WHS obligations still apply. The fact that a fit-out did not require a DA does not exempt the tenant from ensuring that evacuation diagrams are accurate and in place before the tenancy opens. WHS regulators, including SafeWork NSW, WorkSafe Victoria and their equivalents, have the power to issue improvement notices requiring diagram rectification, regardless of whether building approval was required.

Base Building vs Tenancy Diagrams

Understanding the distinction between base building and tenancy evacuation diagrams is essential for both landlords and tenants. A base building diagram covers the building-wide emergency infrastructure: the locations of all fire stairs and exit doors, the assembly areas, the fire hydrant and booster locations, and the building's overall floor layout at the time the base building was certified. These diagrams are typically produced by the building owner and updated whenever base building works are carried out.

A tenancy diagram covers the fit-out specific to a particular lease area. It shows the internal layout of that tenancy, including meeting rooms, open-plan areas, reception and amenities, and how occupants within that space connect to the base building's fire stair and exit network. Tenancy diagrams reference but do not duplicate the base building information; they show the occupant how to get from their specific location within the tenancy to the nearest base building exit.

Problems arise when tenancy diagrams and base building diagrams are out of sync. This typically happens when a tenant completes a fit-out and produces a new tenancy diagram, but the base building diagram has not been updated in years and shows corridors or exits that have since been modified. The building manager should maintain a process for reconciling tenancy and base building diagrams whenever either is updated.

Temporary Diagrams During Construction

During the fit-out construction phase, the tenancy may be in a partially demolished or partially built state, with existing evacuation diagrams removed or no longer accurate. This creates a period of elevated risk: construction workers are present in the space, the layout may change daily, and temporary hazards such as open penetrations and debris are present.

AS 3745:2010 applies to occupied facilities, and construction sites are primarily governed by the WHS (Construction Work) Code of Practice. However, where a fit-out is being carried out in a partly occupied building, for example one floor being refurbished while the rest of the building continues to operate, the base building's emergency systems and evacuation procedures must remain functional, and temporary signage should be in place to direct occupants away from the construction zone during any emergency.

The principal contractor is responsible for emergency planning on the construction site itself. For occupied buildings, the landlord or building manager needs to coordinate with the principal contractor to ensure that base building evacuation routes are not compromised by the works, that any changes to common area fire systems are appropriately managed, and that the building's occupants receive updated information about any changes to assembly areas or evacuation routes during the construction period.

• Principal contractor must maintain an emergency plan for the construction phase
• Base building evacuation routes must remain operational throughout fit-out works
• Temporary signage must direct occupants away from construction zones
• Notify all building wardens of any changes to egress during construction
• Post updated temporary diagrams if access to a fire stair is closed during works
• Reinstate all evacuation signage and diagrams before handing over the completed tenancy

The Fit-Out Handover Checklist

Evacuation diagrams should be a mandatory item on any commercial fit-out practical completion checklist. By the time the keys are handed to the tenant, diagrams should be printed, framed and mounted at every evacuation diagram location (EDL) identified in the tenancy. The standard requires diagrams to be posted at every location where a person might need to know their evacuation route, typically at all entry and exit points, in main corridors, in breakout areas, and in any enclosed rooms that staff occupy for extended periods.

The handover documentation package should include a digital copy of all diagram files in high-resolution PDF format. This allows the tenant to reprint diagrams quickly if one is damaged or removed, and provides a reference point for future updates. The building manager should also receive a copy for their master records.

Following handover, the tenant's first act as occupier should be to establish the Emergency Planning Committee and conduct an initial orientation with all staff, covering the location of evacuation diagram posting points, the assembly area, and the warden structure. The first evacuation exercise should be conducted within the first three months of occupation. This is not merely best practice; for most occupied facilities it is a requirement of AS 3745.

Get Evacuation Diagrams for Your Tenant Fit-Out

EvacPath provides AS 3745-compliant evacuation diagrams for new commercial fit-outs, refurbishments and tenancy changes across Australia. We work with tenants, building managers, fitout contractors and certifiers to ensure diagrams are ready for practical completion and handover.

Send us your floor plan and we will deliver print-ready PDFs in 3 to 5 business days. No site visit required. Pricing starts at A$70 per diagram. Basic Package A$280 for up to 4 diagrams, Standard Package A$420 for up to 8 diagrams.