The 1 January 2026 deadline for privately owned commercial buildings under SA’s AED Act has come and gone. We’re four months in. So what’s actually happening on the ground?
This piece is for SA property managers and building owners who’ve been watching from the sidelines. The ones who weren’t sure if the law applied to them, weren’t sure whether anyone would actually check, and haven’t yet committed to a plan. Here’s an honest read on what the first months have looked like.
A quick recap on what changed on 1 January 2026
The Automated External Defibrillators (Public Access) Act 2022 (SA) came into full effect for privately owned buildings and prescribed vehicles on 1 January 2026. Crown-owned buildings had already been in scope since 1 January 2025.
If you own a commercial building with a total floor area of 600 m² or more and the public can access it, you’re now legally required to have at least one TGA-approved AED installed. Above 1,200 m² of publicly accessible floor area, the Regulations scale the count up — capping at 30 AEDs for buildings over 130,000 m².
Designated facilities — sporting clubs, gyms, schools, aged care, retirement villages, theatres, caravan parks, places of worship, casinos — need at least one AED regardless of size.
The obligation falls on the owner, not the tenant. That’s the bit that catches landlords off guard.
If any of that is news to you, our practical AED checklist for SA workplaces walks through whether your building is in scope.
What the deadline has actually triggered
In the lead-up to 1 January and the months that have followed, we’ve seen a few patterns repeat across our installs.
The ones who were ready
Larger property groups — listed REITs, big strata managers, government tenants — handled it cleanly. Most of them had compliance reviews running from mid-2025 and had AED programs scoped, budgeted, and installed before the deadline.
For these owners, AED compliance was just another item on the same risk register that already covers fire safety, lift inspections, and electrical testing. Nothing dramatic.
The middle ground — a slow drift
A larger group sits in the middle. Smaller commercial owners with one or two buildings, body corporates, and family-owned commercial properties. Many of them knew about the law in principle but pushed action into 2026 because the deadline felt far away.
We’ve seen those owners come through in waves since January. The triggers are usually one of these:
- A tenant or facility manager raising it
- A WHS audit or insurance renewal flagging it
- A neighbouring building visibly installing one
- A change in property management, where the new manager runs a compliance check
There’s no public list of buildings being chased by SA Health, but we’ve taken enough enquiries to say the pressure is real and growing.
The ones still hoping it won’t apply
The third group is the most concerning. These are owners who’ve decided their building isn’t in scope based on a quick internet search or a chat with someone in the office.
The most common reasons we hear:
- “We’re under 600 m²” — but the calculation includes lift shafts, balconies, and rooftop terraces, not just internal lettable space.
- “We’re appointment-only” — true if access is genuinely restricted, but most buildings have some publicly accessible foyer or reception that pulls them back in.
- “We’re a tenant, the landlord handles that” — the Act puts the obligation on the owner, but tenants aren’t off the hook for their own WHS duties under separate legislation.
- “We’re exempt because we have a first aid kit” — first aid kits are not AEDs.
For this group, the risk of being wrong has grown month by month, not shrunk.
What enforcement looks like (and doesn’t)
Section 6 of the Act gives authorised officers — appointed by the Minister for Health and Wellbeing — broad powers to enter and inspect any building, facility, or vehicle that should have an AED installed. They can require documents, inspect records, and issue expiation notices.
What we haven’t seen, four months in, is a public enforcement campaign. No news cycle of named buildings being penalised, no published statistics on inspections, no obvious sweep through any one industry.
That doesn’t mean enforcement isn’t happening. It means it isn’t yet visible. Three things we’d expect to see develop over 2026:
Complaint-driven inspections. Most regulatory regimes start out reactive. Tenants, employees, or members of the public who notice missing AEDs (or non-compliant ones) are the first signal source.
Cross-referencing with the SAAS register. Every installed AED should be registered with the SA Ambulance Service within two weeks. Buildings that are clearly in scope but have no registered device become easy targets for follow-up.
Insurance pressure. Commercial insurers are starting to ask about AED compliance during renewals. That’s not enforcement, but it’s a strong nudge.
For the exact penalty amounts under the Act, owners should refer to the Act and Regulations directly, or ask their lawyer. The published Best Practice Guide doesn’t list dollar figures — they sit in the Act itself.
What’s actually changed in the SA market
Smart AEDs are getting more interest
Cellular-connected AEDs — units that report status, battery health, and pad expiry automatically — are getting more attention from owners managing more than one device. A fleet of three or four AEDs across a portfolio is much easier to keep compliant when each one reports its own status to a dashboard, rather than depending on someone walking past and checking the indicator light.
For a single AED in a single building, a standard unit with a documented maintenance schedule does the job. For multi-site portfolios, the smart option pays for itself in admin time.
SA Health guidance is getting clearer
The SA Health Best Practice Guide is now in version 3.0 (February 2026), and the worked examples have been refined since the initial release. The 1,200 m² threshold scenarios in particular are easier to follow now, including the difference between “total internal floor space” (used to determine whether your building is in scope at all) and “publicly accessible floor area” (used to determine how many AEDs you need).
If you read the original 2024 guide and concluded the law didn’t apply to you, it’s worth re-reading the current version with fresh eyes.
What property managers should do this quarter
If you’re not yet compliant, the path forward is straightforward.
- Confirm scope. Calculate total internal floor area. If you’re at or above 600 m², or if your facility falls into one of the designated categories, you’re in.
- Calculate the AED count. For commercial-purpose buildings above 1,200 m² of publicly accessible space, work through the AED scaling table in the Regulations.
- Plan the installation. Mounting height 1.2–1.4 m, publicly accessible (no locked cabinets), close to high-traffic and high-risk areas.
- Register with SAAS within two weeks. Email [email protected] with the AED location and accessibility hours.
- Install signage. One sign near the AED, one near the building entrance.
- Set a maintenance schedule. The Act requires maintenance per the manufacturer’s instructions. A documented six-monthly service is the standard approach.
We help SA building owners through all six steps. If you’d like a no-pressure scope check on your building, get in touch — most enquiries take less than ten minutes to triage on a phone call.