Combustible cladding · Building owners & FMs
Combustible cladding compliance: what Victorian building owners and facilities managers must do.
The OC framework gets most of the attention. The building-owner and facilities-manager framework is different — distinct audience, distinct decisions, same regulatory backbone.
The obligation
Where the compliance obligation comes from.
The duty to maintain a building in a safe condition derives from the Building Act 1993 and the National Construction Code. For a strata-titled residential building it sits with the owners corporation; for a commercial, mixed-use, or single-owner residential building it sits with the building owner directly. A facilities manager acts as the building owner's agent in operational decisions, but the legal duty rests with the owner. The obligation applies regardless of CSV status — the closure of the funded programme in 2023 did not transfer or waive it. It changed the funding pathway, not the duty.
Compliance process
What compliance requires in practice.
Compliance is not a single action but a process. Three components, each with its own evidence requirement, and the evidence is as important as the action itself.
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Assessment and identification
Accredited identification of cladding type and extent across the building. Without this, every subsequent step is built on assumption.
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Defect reporting and documentation
Photo-referenced defect report that classifies fire risk under the NCC and recommends action. This becomes the foundation document for board reporting, insurer disclosure, and any later regulatory engagement.
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Remediation or documented risk-management plan
Either compliant rectification within a defined timeframe, or a documented risk-management approach (interim measures, monitoring, planned remediation schedule) that an insurer and the VBA can review. Doing nothing while you 'think about it' is not a position the regulator or an insurer recognises.
Insurance
What non-compliance does to your cover.
Many insurers now ask about cladding at policy renewal — the question has become routine on commercial and residential strata cover alike. Where non-compliant cladding is identified and unaddressed, insurers commonly respond with coverage exclusions (the cladding-related risk is carved out), surcharges (premium increases reflecting the risk), or non-renewal. For a building owner or facilities manager, the practical implication is that the compliance position needs to be presentable at every renewal — and 'we are working on it, here is the plan and the timeline' is a far stronger position than 'we have not looked'.
Enforcement
The VBA's enforcement posture after CSV.
With CSV wound up, the VBA and the Building and Plumbing Commission retain enforcement powers under the Building Act. The direction of travel is clear: the regulator's attention has shifted from operating a funded programme to ensuring compliance via enforcement levers. Building notices and orders can be issued with specific timeframes for action; non-compliance attracts penalties. The Commission has not signalled an immediate enforcement blitz, but for any building owner waiting for the regulator to be the trigger, that is not a posture an insurer will reward at renewal.
Documentation
Building your compliance record.
A defensible compliance record is the combination of three things: an accredited defect report on file, evidence that the recommended action was taken (works documentation, sign-off, or a documented and executed risk-management plan), and an ongoing maintenance or inspection schedule that demonstrates the asset is actively managed. That record is what you present at insurance renewal, in a board paper, in response to a VBA inquiry, or in a building sale due-diligence pack. The work it takes to build it is roughly the same as the work to not have it — the difference is whether the work produces a paper trail.
Questions
Building-owner cladding compliance, answered.
Establish your compliance position with a documented assessment.
Summit Facades carries out accredited cladding assessments and delivers the documented record your risk register, board paper or insurer review needs.
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