The clock started without you
The single most expensive assumption a new building owner or property manager makes is that compliance begins when they start paying attention to it.
It does not. The compliance schedule runs on the anniversary of its issue, the inspection and maintenance procedures run monthly and annually regardless of who owns the building, and an Independent Qualified Person is prohibited from issuing a Form 12A if any procedure was missed in the previous 12 months — including the months before you arrived.
There is no new-owner grace period in the Building Act. If the previous owner skipped four monthly emergency lighting checks, that is now your problem, and you will discover it at your first Building Warrant of Fitness.
So the first week matters. Here is how to spend it.
This applies whether you have bought the building, started managing it, or simply inherited the portfolio from a colleague who left. The trigger is you becoming responsible, not the title changing.
Day one — get the documents
Five requests, all of which can go out in one morning.
1. The compliance schedule — from the council. Not from the vendor, not from the due diligence pack. Request your own copy from the territorial authority. Schedules get amended over a building's life and the version in a sale file may be years out of date. It is free.
2. The current Building Warrant of Fitness, and the previous two years'. Gaps here tell you immediately what you have inherited.
3. The Form 12A certificates behind those BWoFs. One per IQP per system. Missing certificates are the tell.
4. Any notice to fix issued against the building. Ask the council directly — a notice to fix that has not been complied with escalates to a maximum fine of $200,000 plus $20,000 for each day it continues, and it does not go away with a change of owner.
5. The logbook. From the vendor, the outgoing manager, or the caretaker. This is the one that is most often "somewhere".
If the building has specified systems and there is no compliance schedule at all, act immediately rather than investigating slowly. Failing to obtain one carries a maximum fine of $20,000 plus a further $2,000 for every day without one. That daily figure is the reason this is a day-one item.
Day two — read the compliance schedule
Most owners never do this. It takes an hour and it determines everything else.
For each specified system listed, note:
- The performance standard it was designed and installed to. For emergency lighting this tells you the duration — 30 minutes, 90 minutes or maintained. See how long emergency lighting must stay on.
- The inspection and maintenance standard. Commonly AS/NZS 2293.2:2019 for emergency lighting, but older buildings may sit on the 1995 edition or NZS 6104:1981. This is normal and not a defect.
- The frequency of each procedure and who must carry it out. Some are yours as owner; the more complex ones need an IQP.
- The reporting requirements — commonly records retained for the previous 24 months, held on site with the schedule.
- Any training condition. Schedules frequently state that the IQP is responsible for ensuring the people doing owner inspections have been trained, and that only trained people may do them.
The full list of what counts as a specified system is in Specified Systems under the Building Act 2004.
If you manage buildings in more than one district, do not assume they match. Councils use their own templates, so two comparable buildings can have genuinely different wording and different IQP attendance frequencies.
Day three — walk the building
Take the compliance schedule and a camera. You are checking whether the building matches the document.
Count the emergency lighting fittings and exit signs against the schedule and the plan. After any fitout the counts drift, and a mismatch is a problem to solve now rather than at BWoF time. It is fixed by an amendment to the compliance schedule, not by quietly testing a different number.
Find every specified system physically. Sprinkler valves, alarm panel, riser mains, backflow preventer, smoke control, lift machine room, HVAC plant. You want to know where they are before you need to know.
Check the obvious failures. Exit signs not lit or obscured by shelving and stock. Fittings hanging or damaged. Anything isolated during previous work and never restored.
Look at the switchboards. Is there a circuit schedule? Are there RCDs, and does anyone know what they protect? Most buildings cannot answer this. See when are RCDs required.
Check whether the compliance schedule statement or BWoF is displayed publicly, as it must be.
Photograph everything unusual. You are building a baseline of the condition you inherited, which is worth having if a dispute arises later.
Day four — find your IQPs
IQP engagements do not transfer with the building. The previous owner's arrangements ended, or did not, and you need to know which.
- Get the council's IQP register — usually on their website. It lists which specified systems each IQP is approved to inspect in that district.
- Establish who is currently engaged, for which systems.
- Settle who issues which Form 12A. One IQP can issue a certificate covering procedures carried out by another, but only if agreed. Buildings with several IQPs discover the gap in the week the BWoF is due.
- Book the year's attendances now, rather than waiting to be called.
- Ask them to train whoever does your owner-carried-out checks, and record that the training happened.
More on the role and its limits in what is an IQP and do you need one.
Day five — build the calendar
Build it from the compliance schedule itself, not from a house rule, and put it somewhere more than one person can see.
- Every owner-carried-out procedure, with its frequency
- Every IQP attendance, booked
- The BWoF date — the anniversary of the compliance schedule's issue
- A named person and a named backup against each recurring item
- A quarterly logbook review, not an annual one
That last item is the cheapest insurance available. A gap found in month three can be managed. A gap found in month twelve is a Building Warrant of Fitness you cannot supply.
While you are there, add the non-Building-Act items so it is one calendar rather than three: appliance testing rounds, RCD testing, and the 12 November 2026 changeover if you have electrical work in design.
What to do if you find a gap
You may well find one. Handle it openly, because the alternative is materially worse.
If inspection, maintenance or reporting procedures were missed in the previous 12 months, your IQP cannot issue a Form 12A and a valid BWoF cannot be supplied or displayed. The Building Act provides no exemptions for this, and it makes no difference that the omissions happened on someone else's watch.
The correct route is a BWoF Report and Declaration, supported by a Specified System Report and Declaration from an IQP for each affected system. It states what was missed, why, what has been put in place, and — importantly — whether the system is currently performing to its standard. That last distinction is what lets you tell a council and an insurer that the paperwork failed but the building is sound.
The whole process is set out in what happens if you miss a BWoF inspection.
Displaying a BWoF you are not entitled to is a separate offence carrying a maximum fine of $20,000. Do not be tempted; it converts an inherited records failure into a deliberate act of your own.
We baseline buildings in exactly this situation — establishing what the schedule requires, what has actually been done, what is performing and what is not, and handing your IQP something they can work with. It is not a comfortable first month, but it is a great deal better than the first BWoF.
Related: emergency lighting and your BWoF and why buildings fail emergency lighting.