Is emergency lighting testing legally required in New Zealand?

Yes. Emergency lighting is a Specified System under the Building Act 2004. If it appears on your building's compliance schedule, maintaining and testing it in accordance with that schedule is a legal obligation, with or without an incident. This is the opposite of the position with portable appliance testing.

How often does emergency lighting need testing?

Your compliance schedule states it. A common New Zealand pattern is a monthly check by the owner or their agent plus Independent Qualified Person inspections six-monthly and annually, working to AS/NZS 2293.2:2019, but councils word schedules differently and older buildings sit on older standards.

Is the discharge test always 90 minutes?

No. Building Code clause F6 sets the duration by risk group. Many ordinary New Zealand commercial buildings require 30 minutes. Ninety minutes applies to larger or higher-risk buildings, and some must maintain lighting until the supply is restored.

What is the penalty for not having a current BWoF?

BWoF offences carry a maximum fine of $20,000, with instant fines from $250 to $1,000. A notice to fix that is not complied with escalates to a maximum of $200,000 plus $20,000 for each day the offence continues. Insurance cover may also be affected.

Emergency lighting testing and your Building Warrant of Fitness

Q: Emergency lighting testing and your Building Warrant of Fitness

Emergency lighting is Specified System 4 under the Building Act 2004. If it is on your building's compliance schedule, carrying out the inspection, maintenance and reporting procedures is a legal obligation, and your annual Building Warrant of Fitness depends on it. The frequency and duration come from your compliance schedule, not from a generic rule.

Why this one is different

We spend a fair amount of the test-and-tag section of this site explaining that testing portable appliances is not legally required in New Zealand. Emergency lighting is the opposite case, and it is worth being just as clear about it.

If your building has emergency lighting on its compliance schedule, maintaining and testing it is a legal obligation under the Building Act 2004, and failing to do it puts you in breach — with or without an incident.

Building owners are frequently surprised by this, particularly those who have taken over an existing building and inherited a compliance schedule they have never read.

What the Building Act requires

Emergency lighting is Specified System 4 — one of a defined list of building systems that must be maintained and reported on because people's safety depends on them working when everything else has failed. The full list is in Specified Systems under the Building Act 2004.

The chain works like this:

Your building has a compliance schedule issued by the council, listing its Specified Systems.
Each system has inspection, maintenance and reporting procedures, drawn from the relevant standard — for emergency lighting, commonly AS/NZS 2293.2.
An Independent Qualified Person (IQP) inspects and certifies that the procedures have been followed, issuing a Form 12A.
The building owner submits an annual Building Warrant of Fitness (BWoF) to the territorial authority, supported by those certificates, and displays it publicly.

Operating a building that requires a BWoF without a current one is an offence under the Building Act, carrying a maximum fine of $20,000 and instant fines from $250 to $1,000. Councils do enforce this, and it is one of the first things a purchaser's due diligence will check. Your insurance may also be affected.

Your compliance schedule governs

This is the point that most published guidance on this subject gets wrong, including a great deal of it written by people selling the service.

There is no single national rule for how often emergency lighting is tested, or for how long the discharge test runs. There is a rule for your building, and it is on the compliance schedule the council issued.

That document names, for Specified System 4:

the performance standard the system was designed and installed to
the inspection and maintenance standard — commonly AS/NZS 2293.2:2019, Section 3, though older buildings may sit on AS/NZS 2293.2:1995 or NZS 6104:1981
the frequency of each procedure and who must carry it out
the reporting requirements, commonly records retained for the previous 24 months and held on site

Two comparable buildings in two districts can have genuinely different schedules, because councils use their own templates. If you run a portfolio, you cannot operate one calendar from memory — build it from each schedule.

If you do not have your compliance schedule, request a copy from your territorial authority. It is free and it is the single most useful thing a new building owner or property manager can do. Everything else follows from it.

The monthly check

Most schedules place a monthly check on the owner or their agent. It does not require an IQP, but it does require care, and it needs to be recorded per fitting in the logbook that lives on site with the compliance schedule.

What it catches: dead lamps, failed drivers, fittings isolated or disconnected during other work, and exit signs that are simply not lit or have been obscured by new shelving or partitions.

What it does not catch: a battery that lights the fitting for ninety seconds and then dies. That is what the full-duration test is for.

Compliance schedules commonly state that the IQP is responsible for ensuring proper training is delivered, and that only trained people may perform owner inspections. Very few owners have read that sentence. If your caretaker has been signing the logbook for three years and nobody ever trained them, that is a gap. Ask your IQP to train them and record it.

There is more detail in how often emergency lighting needs to be tested.

The full-duration discharge test

Periodically, every emergency fitting is run on battery for the full duration the system is designed to provide, and checked at the end to confirm it is still producing adequate light.

That duration is not automatically 90 minutes. Under Building Code clause F6 it depends on the building's risk group — 30 minutes for many ordinary commercial buildings, 90 minutes for larger or higher-risk ones, and maintained until the supply is restored in some cases. Testing a 30-minute system for 90 minutes is as much an error as the reverse. See how long emergency lighting must stay on.

This is the test that finds problems. Emergency lighting batteries degrade quietly, and a fitting that passes its monthly flick test can easily fail at a fraction of its rated duration — which is precisely the point in an evacuation when it is still needed.

Practical points:

Batteries need a full recharge period afterwards. The building is not fully protected during that window, which is why the test is scheduled deliberately rather than casually.
Fittings that fail get their battery or the whole fitting replaced, then retested.
Results are recorded per fitting, not as a site-level pass.
Record the battery age against each fitting. Batteries are consumables with a finite service life and they tend to reach end of life in cohorts, because they were all commissioned in the same month.

What your IQP needs to see

When the IQP comes to certify the system, they are checking that the procedures on the compliance schedule have actually been carried out. In practice they want:

A logbook or digital record showing every scheduled check, by date, with results per fitting
The discharge test results, per fitting, at the correct duration
Records of any failures and what was done about them, including the re-test
Evidence that the people doing the owner-carried-out checks were trained
A current plan of the fittings matching what is on site

The most common failure is not a broken light. It is a building where the testing has probably been done but nobody can produce the records. The nine most common causes are set out in why buildings fail emergency lighting on their BWoF.

An IQP is prohibited from issuing a Form 12A if any procedure on the schedule was missed, and MBIE states that the Building Act provides no flexibility or exemptions. If something has been missed, there is a proper process — see what happens if you miss a BWoF inspection.

Where to start

If you have taken over a building and are not sure what you are dealing with:

Request the compliance schedule from the council. Not from the vendor — from the council, so you know it is current.
Get the last two years' BWoFs and Form 12As. Gaps tell you what you have inherited.
Find the logbook. If there is not one, your records problem starts today.
Walk the building against the schedule and count the fittings.
Find out who the IQPs are and whether they are still engaged.
Diarise the next twelve months before the first check falls due.

We can baseline the emergency lighting against your actual schedule and tell you honestly where you stand — including when the answer is that you are fine and your existing contractor is doing the job properly.