Most of the calls we get about South Australia’s defibrillator law are people trying to work out whether they’re in scope. Almost nobody rings to ask how to comply. They ring to ask whether they have to.
That’s a fair question, and the Act does answer it. There’s a genuine out-of-scope list, and some of the buildings on it surprise people. There’s also a trap in the middle of that list that catches owners who read half of it and stop.
Here’s the whole thing, in the order you should work through it.
First, the thing that decides everything else
The Automated External Defibrillators (Public Access) Act 2022 has applied to privately owned buildings since 1 January 2026. The duty sits with the owner, not the tenant or the operator. If you’re a tenant reading this because your landlord sent it to you, the obligation isn’t yours.
There are two separate ways a building comes into scope, and this is where most confusion starts.
Route one: it’s a designated building or facility. Section 4 lists these, and if you’re on the list you need at least one defibrillator regardless of how big you are. Public buildings and facilities, sporting facilities including gyms and yoga and Pilates studios, schools and universities and TAFE, retirement villages with shared amenities, residential aged care, caravan parks, residential parks with twelve or more residents, casinos and gambling venues, and theatres and performance venues.
Route two: it’s a relevant building. That means a total internal floor area of 600 m² or more, in a building the public can access. Note total internal — the whole floor plate inside the exterior walls, including stairs, toilets, lifts and lift shafts, plus balconies and rooftop terraces. Not just the bits the public walks through.
If neither route catches you, you’re out. If either one does, you’re in, and the exemption list below is the only thing that can pull you back out.
The actual out-of-scope list
These come from section 6A of the Act and section 2.9 of SA Health’s Best Practice Guide.
Hospitals and medical facilities. Public and private hospitals, GP clinics and emergency medical centres are out — but on a condition. The exemption applies where there’s a medical practitioner, nurse or paramedic on site and the facility already has defibrillators. Both parts. A medical suite with no on-site practitioner during some operating hours is worth a closer look rather than an assumption.
Carparks. Indoor and outdoor, both out of scope.
Correctional facilities. Prisons, custodial police stations and youth detention centres.
Licensed children’s residential facilities.
Buildings the public genuinely can’t get into. This is the big one and the one most often misread. If no part of the facility is accessible to the public, it’s out. Warehouses where only employees and contractors go, abattoirs, appointment-only premises. SA Health’s own worked example is a 700 m² dentist clinic operating by appointment only — well over the 600 m² threshold, and it needs zero defibrillators, because nothing in it is publicly accessible.
Temporary structures. Fringe tents and the like. Put up for a season, taken down again, out of scope.
The trap in that list
The “not publicly accessible” exemption has five words attached to it that decide a lot of cases: unless it’s a designated building or facility.
A warehouse with contractor-only access is out. A gym behind a swipe card is not, because gyms are designated. An appointment-only dental practice is out. A school with a locked front gate is not, because schools are designated. A gated retirement village with shared amenities is not, either — SA Health’s worked example puts a 2,500 m² gated village at zero publicly accessible area and still requires one device.
So the order matters. Check the designated list first. If you’re on it, public accessibility doesn’t rescue you and neither does size. If you’re not on it, then the accessibility question is live and can genuinely take you out of scope.
The same logic runs the other way for aged care. Residential aged care is designated, so it’s in — but it’s also the one category where the placement rule relaxes, because the requirement to make the device publicly accessible doesn’t apply. You need the defibrillator. You don’t need to put it where the street can reach it.
Being small isn’t an exemption, it’s a different question
People use “exempt” loosely to mean “doesn’t have to”. Worth separating the two, because they behave differently if your building changes.
A standalone café of 500 m² isn’t exempt. It just doesn’t meet the 600 m² relevant-building test, and it isn’t on the designated list. Extend it, or convert part of it into something designated, and it’s in scope with no exemption to fall back on.
The same goes for the count. Once you’re in scope you need at least one device, and you only need more if the building is on land used for commercial purposes and the publicly accessible floor area exceeds 1,200 m². That second measurement is a different number from the first one — publicly accessible area only, not total internal area. It catches people out often enough that we wrote a separate guide on calculating publicly accessible floor area.
Which is why a 7,800 m² office tower with only 900 m² of public area needs one defibrillator, and a 3,200 m² theatre with 2,500 m² of public area needs two.
The Ministerial exemption
Section 7 lets the Minister exempt a specified building, facility, vehicle or person from the Act. It’s case by case, it’s discretionary, and it isn’t a category you can put yourself in by deciding your circumstances are unusual.
If you think you have a genuine case — a building where installation is physically impractical, or where the Act’s purpose is already met some other way — that’s a conversation with SA Health, not a judgement call you make in-house and document in a file note.
How to actually run this check
Four questions, in order.
- Are we on the designated list? If yes, you need at least one device. Skip to the count.
- Is the total internal floor area 600 m² or more, in a building the public can access? If no, and you’re not designated, you’re out of scope.
- Does an exemption in section 6A apply? Work through the list above properly, including the conditions attached to the medical exemption.
- If we’re in scope, how many? One, unless the land is used for commercial purposes and the publicly accessible area is over 1,200 m². Then use the table in the Regulations.
Write down the answer and the reasoning. If an authorised officer turns up — and they have powers to enter, inspect, require documents and issue expiation notices — a considered assessment on file is a materially better position than a recollection.
When you’re not sure, get it measured
The honest position is that most of these questions are settled by two facts about your building: what it’s used for, and what its floor areas actually are. Both are checkable. Neither is a matter of opinion.
Where owners get into trouble is deciding they’re exempt on a partial reading, usually the “nobody from the public comes in here” one, without checking whether the designated list catches them first. That’s the single most common version of this mistake, and it’s on our list of common SA AED compliance mistakes for a reason.
If you’d like someone to walk the building and give you a straight answer on scope, count and placement, that’s a normal part of what we do before quoting anything. We install and maintain defibrillators across South Australia, including registration with SA Ambulance and the signage the Act requires. Start at our South Australia page, or have a look at how SA compliance has actually played out since the deadline passed.
