Annual Fire Safety Statements: Mechanical Essential Services

What You Need to Know

Every building in NSW with a fire safety schedule must lodge an annual fire safety statement (AFSS). This includes mechanical systems. Smoke exhaust fans, stair pressurisation systems, fire dampers, and smoke dampers all count as essential fire safety measures.

Building owners must prove these systems work. That means routine inspections, testing, and maintenance under AS 1851-2012. The results go into a logbook. The logbook supports the AFSS.

From 13 February 2026, NSW requires all Class 1b and Class 2 to 9 buildings to maintain essential fire safety measures in line with AS 1851-2012. This is not optional. Penalties for non-compliance reach up to 800 penalty units for a corporation (Environmental Planning and Assessment (Development Certification and Fire Safety) Regulation 2021, section 89).

• EP&A (Development Certification and Fire Safety) Regulation 2021, Part 12, Division 2 sets out AFSS obligations. Sections 88 to 91 cover fire safety certificates, annual statements, display requirements, and supplementary statements. This is the primary NSW legislation for AFSS compliance.
• Section 89 requires the building owner to give the council an AFSS within 12 months of the previous statement. A copy must also go to Fire and Rescue NSW. A copy must be displayed in the building. Maximum penalty: 800 penalty units (corporation) or 400 penalty units (individual). Each week of non-compliance is a separate offence.
• AS 1851-2012, Section 12 covers passive fire and smoke systems. Fire dampers are inspected on a 3-monthly and 6-monthly basis. Checks include physical condition, operation, and closure under test conditions.
• AS 1851-2012, Section 13 covers fire and smoke control features of mechanical services. This includes smoke exhaust systems, stair pressurisation fans, smoke dampers, fire fan control panels, and AHU fire-mode controls. Inspection and testing frequency: every 3 months.
• The fire safety schedule lists every essential fire safety measure in the building and its minimum standard of performance. The AFSS must confirm each measure meets its listed standard. The schedule is issued with the construction certificate or occupation certificate.
• Logbook requirements: All inspection and test results must be recorded in a logbook under AS 1851-2012. The logbook can be digital or hard copy, but a hard copy must be kept on site. The logbook is the evidence base for the AFSS.
• Competent persons must carry out the inspections. Under the NSW Building Commission requirements, practitioners servicing fire protection systems under AS 1851-2012 must hold relevant licences or competencies. Unqualified inspections will not support a valid AFSS.

Most building owners know about sprinklers and fire alarms. Few think about the mechanical systems. A smoke exhaust fan that sits idle for 10 years will not work when a fire breaks out. That is the entire point of routine testing.

Mechanical essential services are split across two sections of AS 1851-2012. Section 12 covers fire dampers. Section 13 covers everything else: smoke exhaust systems, stair pressurisation fans, smoke dampers, fire and smoke control panels, motorised relief openings, and AHU fire-mode shutdown controls.

Section 13 systems require quarterly inspections. Each inspection checks that the system activates on signal, achieves the required airflow or pressure, and returns to normal after reset. For stair pressurisation, the test confirms the pressure differential across the fire door meets the design value. For smoke exhaust, the test confirms the fan starts and delivers the rated extraction rate.

Fire dampers under Section 12 need 3-monthly visual inspections and 6-monthly operational tests. The operational test closes the damper under controlled conditions to confirm it seals fully. A damper blocked by cable trays, ductwork modifications, or debris will fail.

These systems often share infrastructure with the HVAC system. The same air handling unit that provides comfort cooling may have a fire-mode function that shuts down supply air and activates smoke exhaust. If someone modifies the HVAC controls without updating the fire-mode logic, the smoke management system may not work.

The AFSS process requires a competent fire safety practitioner to assess each measure on the fire safety schedule. They sign off that each measure performs to its listed standard. If a mechanical system fails its test, the owner must repair it before the AFSS can be issued. There is no provision for lodging an AFSS with known deficiencies in essential services.