Accessible Toilets in Public Events

The National Construction Code 2025 was adopted in Victoria from 1 May 2026, with no transition period.

It is important to note that a POPE area, or a structure located within a POPE, is not automatically a Class 9b building. The classification of any building or structure forming part of a POPE must be determined separately according to its particular use, form and the applicable requirements of the NCC and Victorian building legislation.

To address the POPE requirements, Schedule 10 Victoria of NCC 2025 Volume One includes specific Victorian provisions relating to Places of Public Entertainment.

For POPEs that are places other than buildings, the Victorian provisions require sanitary and amenity facilities to be provided based on patron numbers, including:

1. Female sanitary facilities: one closet fixture for every 200 female patrons or part thereof; and
2. Male sanitary facilities: one closet fixture or urinal for every 200 male patrons or part thereof, with at least 30% of the required fixtures being closet fixtures; and
3. Washbasins: one washbasin for every 200 patrons or part thereof; and
4. Accessible sanitary facilities: one unisex accessible sanitary facility for people with disability for every 100 closet fixtures, or part thereof, required under the male and female sanitary facility calculations; and
5. Drinking facilities: one drinking fountain or drinking tap for every washbasin required under the applicable sanitary facility calculations; and
6. First-aid facilities: first-aid facilities must also be provided where required by the Victorian POPE provisions.

Where a POPE involves a building, the sanitary facility requirements applicable to that building are determined in accordance with the relevant sanitary and amenity provisions of NCC 2025 Volume One, rather than simply applying the sanitary facility ratios applicable to a POPE that is a place other than a building.

When the total number of sanitary facilities is spread across several locations within an event space, consideration should also be given to the appropriate distribution of accessible sanitary facilities. Providing all accessible toilets in one location may result in unreasonable travel distances for people with disability, particularly at large events.

The location of accessible sanitary facilities should therefore be considered together with the accessible paths of travel throughout the event site, the location of event activities and the distribution of other sanitary facilities.

Similarly, accessibility should be considered in the location of first-aid facilities, including the provision of an appropriate accessible path of travel to the facility and the accessibility of any building or temporary structure in which first aid is provided.

The Victorian POPE provisions also require one drinking fountain or drinking tap for each washbasin specified in the applicable sanitary facility calculations. While the POPE provisions do not establish a separate numerical requirement specifically for accessible drinking fountains, the accessibility, location and approach to drinking facilities should still be considered when planning an accessible public event.

Temporary Structures

Temporary structures used at public events should not be assumed to fall outside the building regulatory framework simply because they are temporary.

Marquees, stages, viewing platforms, tiered seating and other temporary structures may be subject to requirements under the Building Act 1993 (Vic), Building Regulations 2018 and NCC 2025, depending on their particular type, use, size and configuration.

Accordingly, both the classification of structures and the accessibility requirements that apply to them should be considered when planning a POPE.

Other States and Territories

The POPE provisions discussed above are Victorian-specific provisions contained within Schedule 10 Victoria of NCC 2025 Volume One.

If you are not in Victoria and your State or Territory does not have similar provisions, the Victorian requirements may provide a useful reference point when considering the number and distribution of accessible sanitary facilities at a public event.

However, the Victorian requirements should not be presented as a legislated minimum requirement outside Victoria, as the applicable legislation, NCC variations and regulatory requirements may differ between jurisdictions.

Ultimately, check with the relevant building surveyor, Council or regulatory authority to determine the requirements applicable to the particular event and jurisdiction.

Questions?

If you want to read more about Victorian POPE requirements, accessible public events, temporary structures and the accessibility considerations that apply to public events, visit our Accessible Public Events page or give us a call.