The rules around working on roofs in New South Wales have changed, and if you own, manage or maintain a commercial or industrial building, these changes may affect how rooftop access and fall risks are managed. SafeWork NSW’s new Work on Roofs – Commercial and Industrial Buildings Code of Practice commenced on 22 May 2026, and from 1 July 2026, a broader legal shift significantly increased the importance of following applicable Codes of Practice when working at height.
Two things matter most here. First, the new Code places greater emphasis on considering permanent access and higher-order fall protection at the design stage and throughout the life of the building, making reliance on harness-based systems alone harder to justify where safer controls are reasonably practicable. Second, from 1 July 2026, PCBUs must comply with an applicable Code or demonstrate that an alternative approach provides an equivalent or higher standard of health and safety.
Here’s what’s changed, what it means for your rooftop systems, and what you should be doing now.
Codes of Practice Are No Longer Just “Guidance”
Until 30 June 2026, approved Codes of Practice already carried significant legal weight and could be used as evidence of what was known about a hazard, risk or control measure. However, failing to follow a Code was not, by itself, the same direct statutory duty that now exists.
That changed with the introduction of Section 26A of the Work Health and Safety Act 2011 (NSW). From 1 July 2026, a business, referred to in the legislation as a PCBU or person conducting a business or undertaking, must comply with an approved Code of Practice that applies to its hazards and risks, unless it can demonstrate that another approach provides an equivalent or higher standard of health and safety.
In practical terms, SafeWork NSW now describes approved Codes as minimum performance standards. Where a Code says a PCBU “should” take a particular measure, that represents the standard required by the Code unless an equivalent or higher approach is used. Importantly, measures described as “may” remain optional.
Falling short of an applicable Code without an equivalent or higher alternative can now amount to a breach of the Section 26A duty, even where nobody has been injured. Inspectors can also refer to applicable Codes when assessing whether risks are being adequately managed or when considering enforcement action.
A New NSW Code of Practice Specifically for Roof Work
Timed alongside this legal shift, SafeWork NSW released a new Code of Practice in May 2026: Work on Roofs – Commercial and Industrial Buildings. It replaced the previous Safe Work on Roofs Part 1 Code, which had been in place since 2009.
The new Code provides updated guidance for commercial and industrial roof work and references current Australian Standards, including AS/NZS 1891.4:2025. Combined with the Section 26A changes, the Code now represents an important minimum performance standard for managing the roof-work risks it covers, unless an equivalent or higher level of safety can be demonstrated.
Here are the key changes building owners, facility managers and maintenance teams need to know about.
Fall Protection Now Needs to Be Designed In, Not Bolted On
Perhaps the biggest shift in the new Code is the greater emphasis on when fall protection should be considered. While designers already had statutory WHS duties under the WHS Act, the old 2009 Code placed less emphasis on incorporating measures such as parapets, permanent access and anchor systems into the initial building design.
The new Code strengthens this approach. It expects designers to consider how roofs, plant and equipment will be safely accessed, inspected and maintained throughout their service life. Where reasonably practicable, this can include permanent edge protection, fixed access, parapets of at least 900 mm, trafficable walkways, skylight protection and permanent fall protection or anchorage systems where required.
The practical effect is that relying on harness-based fall arrest as the primary solution may be harder to justify where higher-order controls are reasonably practicable. Guardrails, safe access, solid construction and other fall-prevention measures should be considered before relying on a system that allows a worker to fall.
This also increases the importance of good handover documentation. Mesh certification, anchor and lifeline certificates, access information and system documentation should be retained as part of good roof-safety and asset-management practice rather than being chased up after the building is already in use.
Roof Safety Compliance and the Three-Metre Rule for Lower-Pitched Roofs
One of the areas most likely to affect existing fall-protection systems relates to flat and lower-pitched roofs and the use of three-metre no-go areas.
For permanent access on industrial roofs with a pitch below 7°, the Code provides examples that include trafficable walkways located at least three metres from an unprotected roof edge, unless permanent guardrail protection is installed. Areas outside those designated access routes may be treated as no-go areas.
Where workers need to leave the protected access route or enter a no-go area, additional fall protection may be required. However, the three-metre distance should not be interpreted as a blanket rule that every person who comes within three metres of every roof edge must connect to a static line. The appropriate control depends on the roof configuration and the other protection already in place.
Roof pitch also matters. The Code includes a worked example involving a 15° roof where a no-go-area approach is not suitable because the slope creates a risk of a worker sliding or tumbling down the roof. In that example, permanent lifelines and anchor points are used instead.
Importantly, this does not mean all roofs at 7° or above automatically require lifelines or that no-go areas are prohibited. Roof pitch, trafficability, surface conditions, weather and the risk of sliding or tumbling all need to be considered when determining the appropriate system.
This has real implications for existing layouts. Take a static line installed two metres back from a roof edge around a bank of solar panels. If the access route requires a worker to enter an uncontrolled fall-risk area before they can safely connect, the arrangement should be reviewed.
Worth checking now: can workers reach your static lines, anchors, plant and solar equipment without first being exposed to an uncontrolled edge risk? Are walkways and access routes appropriately located, or is guardrail protection required? Under Section 26A, where you depart from the Code’s approach, you need to be able to demonstrate an equivalent or higher standard of safety, not simply a different approach.
Commercial vs Industrial Roofs Are Now Treated Differently
The new Code provides distinct guidance for industrial and commercial roofs and recognises that the fall-protection approach may need to vary depending on how the roof is designed and used.
Industrial roofs are often relatively simple structures containing plant and equipment and may primarily be accessed for inspection, maintenance or repairs. Commercial roofs can be more complex, with balconies, rooftop gardens, carparks, glazed areas and other architectural or habitable spaces.
For height safety compliance, the takeaway is that a one-size-fits-all height-safety system may not be appropriate. Commercial and industrial roofs require site-specific fall-protection strategies based on how the roof is actually accessed and used.
Two Hierarchies Need to Be Considered
SafeWork NSW has long required higher-order controls to be considered before relying on personal fall-arrest equipment.
Under the WHS Regulation, work involving a risk of a fall should first be carried out on the ground or on solid construction so far as reasonably practicable.
Where the risk cannot be eliminated, the fall-control hierarchy then requires consideration of:
- Fall-prevention devices, such as edge protection
- Work-positioning systems
- Fall-arrest systems
Only where the higher-order options are not reasonably practicable should the system move further down the hierarchy towards fall arrest. Administrative controls such as procedures, training and signage can support these measures but do not replace the requirement to consider higher-order physical controls first.
Where a harness-based system is appropriate, AS/NZS 1891.4:2025 also provides a hierarchy for selecting between harness-based systems:
- Total restraint
- Restrained fall
- Limited free fall
- Free fall
- Restraint technique
The practical message is that selecting anchors and lifelines should involve more than simply determining whether a harness can be connected. The system should minimise the potential for a fall wherever reasonably practicable, and the reasoning behind the chosen controls should be properly considered and documented.
What the New Code Means for Existing Height Safety Systems
An existing height-safety system is not automatically non-compliant simply because it was installed before the new Code came into force.
However, the system still needs to safely support the work being carried out today. If workers cannot safely reach the areas they need to access, or the existing arrangement no longer provides adequate protection, the system should be inspected, assessed and, where necessary, modified or upgraded.
Changes to a roof can also trigger the need for a fresh assessment. Adding rooftop plant such as solar panels, HVAC units or antennas can alter access routes, increase the frequency of roof access, obstruct existing systems and introduce new hazards.
Any significant change to how the roof is configured or used should therefore prompt a review of the existing access and fall-protection arrangements to ensure the controls remain effective. Regular reviews are therefore an important part of ongoing roof safety compliance.
Working at Heights Training and Competency Should Be Reviewed
Between AS/NZS 1891.4:2025, the new roof Code and the Section 26A changes, there are a number of updated requirements and work practices that businesses need to understand.
This does not mean every worker who accesses a commercial or industrial roof automatically needs to complete a new formal refresher course.
PCBUs do, however, have a responsibility to ensure workers receive suitable information, training, instruction and supervision for the work they undertake. Where procedures, equipment, fall-protection systems or work methods have changed, training needs should be reviewed and appropriate instruction or refresher training provided where required.
The Code also deals with a broad range of hazards associated with roof work. Alongside falls, asbestos, electrical risks and manual handling, it addresses environmental exposure, RF radiation, roof-mounted plant such as HVAC and solar, psychosocial hazards and remote or isolated work.
The Cost of Getting It Wrong
Section 26A is now a statutory WHS duty, and failures can attract the offence provisions of the WHS Act depending on the seriousness and circumstances of the breach.
For the 2026–27 financial year, maximum penalties for a company can reach approximately $779,145 for a Category 3 offence, $2.33 million for a Category 2 offence and $11.61 million for the most serious Category 1 offences.
Category 1 offences involve significantly more serious circumstances, including reckless or grossly negligent conduct that exposes a person to a risk of death or serious injury or illness, and can also result in imprisonment of up to 10 years for individuals.
These are maximum penalties and do not mean that every failure to follow a Code will attract these amounts. What they do demonstrate is the importance placed on preventative WHS duties. Regulators do not need to wait for somebody to be injured before taking action where risks are not being adequately managed.
What Building Owners and Managers Should Do Now for Height Safety Compliance
The good news is this is manageable work, not a reason to panic. We’d recommend:
- Reviewing your current rooftop fall-protection systems against the new Work on Roofs Code, particularly access routes and areas near unprotected roof edges.
- Engaging a height-safety specialist early on new builds or major roof works so permanent edge protection, walkways and fixed access can be considered during the design stage rather than retrofitted afterwards.
- Checking whether your systems and work methods properly apply the WHS fall-control hierarchy and, where harness systems are used, the system-selection hierarchy referenced by AS/NZS 1891.4:2025.
- Reviewing worker training and competency and arranging refresher training where changes to equipment, systems or work methods mean it is required.
- Keeping handover documentation, mesh information, anchor and lifeline certification, inspection records and access details available throughout the life of the system.
- Triggering a roof-safety review whenever roof use changes or new plant is installed, such as solar panels, HVAC units or antennas.
- Keeping records of inspections, risk assessments and decisions to use an alternative approach to an applicable Code, including the reasoning supporting an equivalent or higher standard of safety.
- Getting a professional height-safety audit if you’re not confident your current rooftop access and fall-protection arrangements meet the current requirements.
Talk to Anchor Safe
Working through a new code of practice alongside legislative change isn’t something you need to tackle alone. Anchor Safe’s height safety specialists can audit your existing rooftop systems against the new code, identify any gaps around access points and fall edges, and design, install or upgrade systems to keep your workers, and your business, compliant.
From facility managers and councils to HVAC teams, solar installers and gutter cleaners, we help businesses of every size meet their obligations under NSW’s new code of practice requirements.
Contact Anchor Safe to book a height safety audit or speak with our team about what these changes mean for your buildings.