If you manage a multi-tenant commercial building in South Australia, the AED question gets messy fast. Tenants think the landlord handles it. Landlords assume the strata manager has it covered. The strata manager points back at the lot owners. Meanwhile the Act is sitting on the desk, quietly already in force.
This piece walks through who’s actually on the hook under the Automated External Defibrillators (Public Access) Act 2022 — and what that means in practice for the most confusing case: a building with multiple tenants and shared common areas.
The short answer
Under section 3 of the Act, the owner is responsible. Not the tenant, not the occupier, not the property manager unless they hold ownership in their own right. For most South Australian commercial buildings, that means:
- Land held in fee simple — the owner of the estate in fee simple
- Land held from the Crown by lease or licence — the lessee or licensee
- Crown-unalienated land — the Crown
In a typical multi-tenant office tower, the owner of the building (or the body corporate, where one exists) carries the AED obligation. Tenants leasing space from that owner do not, regardless of how their lease apportions other building services.
That’s the rule. Where it gets interesting is how the rule applies when there’s more than one ownership boundary in the same building.
Why multi-tenancy trips people up
Most of the confusion in SA multi-tenant buildings comes down to three overlapping questions:
- Who counts as “the owner” when a building is broken into strata lots?
- Whose floor area do you measure when working out how many AEDs are needed?
- Who pays — and through what mechanism?
The Act answers the first one cleanly. The second and third are where you need to slow down.
Strata-titled buildings: common property is the body corporate’s problem
In a strata-titled commercial building — the standard arrangement in most modern Adelaide office, retail and mixed-use developments — each lot has a registered owner. Common property (lifts, foyers, shared corridors, plant rooms, shared toilets) belongs to all lot owners collectively, managed by the body corporate.
For the AED obligation, the question is where the publicly accessible floor area sits. If members of the public can walk into the foyer, take a lift, and reach a tenancy without being stopped at a security gate, that foyer and lift area is publicly accessible — and it sits on common property.
The body corporate is the practical “owner” of that common property and carries the duty to install, maintain, register and signpost the AED. Lot owners contribute through their levies in the same way they pay for the lift, the cleaner and the building’s compliance.
Two things worth flagging here:
- The body corporate isn’t a separate exemption — it’s just how a group of fee simple owners discharges their collective obligation under the Act on shared land.
- Where a single lot is large enough, or accessed independently of the common property, that lot owner may carry their own separate obligation. A ground-floor retail tenancy with a direct street entrance and no shared foyer access is a different ownership boundary.
If you manage a strata-titled commercial building and you’re not sure how that boundary falls in your case, get the survey plan in front of you and look at where the common property ends.
Single-owner multi-tenant buildings: the obligation stays with the owner
A lot of Adelaide office stock is still held by a single owner who leases entire floors or partial floors to tenants. The lease arrangement doesn’t transfer the AED obligation. The owner is the owner under the Act, full stop.
That’s true even where the lease puts general “compliance with laws” obligations on the tenant. The Act names the owner, and a private lease doesn’t override statute. If a tenant chooses to install an AED in their own tenancy beyond what the owner has provided, that’s a workplace decision they’re allowed to make — but it doesn’t reduce the owner’s duty.
The practical effect: if you’re a tenant in a single-owner building and there’s no AED in the foyer or shared common area, the owner is the one in breach, not you. If you’re the owner, you don’t get to delegate this through the lease.
How many AEDs does the building need?
This is where multi-tenant calculations need care. The two-step test from the Act and Regulations is:
- Is the building or facility “designated” or otherwise within scope (a public building or facility, a relevant building of 600 m² or more, or a designated category like a sporting facility, school, retirement village or aged care facility)?
- If yes, is the land used for commercial purposes AND is the publicly accessible floor area more than 1,200 m²?
If both parts of step 2 are yes, the count scales:
| Publicly accessible floor area | AEDs required |
|---|---|
| Less than 2,400 m² | 1 |
| 2,400 m² to less than 3,600 m² | 2 |
| 3,600 m² to less than 4,800 m² | 3 |
| 4,800 m² to less than 6,000 m² | 4 |
| 6,000 m² to less than 7,200 m² | 5 |
(Full table runs out to 30 AEDs at 130,000 m² and above — see the Best Practice Guide for the rest.)
For a multi-tenant building, “publicly accessible floor area” means the parts of the building the public can reach without obstruction. Lifts, foyers, and shared corridors that lead to publicly accessible tenancies count. A floor that’s locked behind a swipe-card barrier — say, the back-of-house tenancy of a single law firm with no public reception — doesn’t.
The Best Practice Guide’s worked example for a commercial office tower makes the point: a building with 7,800 m² total floor area but only 900 m² of publicly accessible space requires one AED. Total floor area determines whether the building is in scope. Publicly accessible floor area determines how many AEDs the count scales to.
If you’re working this out for your building, two practical tests:
- Walk the route the public actually takes from the street to the tenancy they’re visiting. Measure that.
- Anywhere a member of the public would be turned back by a barrier, key, security desk or appointment requirement, stop measuring.
Who pays?
In a strata-titled building, the body corporate pays out of admin fund levies. AED installation, ongoing maintenance, signage and registration are all building-running costs in the same category as the fire panel, the lift service contract or the building’s annual safety audit. Lot owners share the cost in proportion to their unit entitlement.
In a single-owner building, the owner pays. A landlord may pass costs through to tenants under a net lease or outgoings clause if the lease allows for “statutory compliance” outgoings — but the obligation to install and maintain still sits with the owner. The lease determines who carries the cash, not who carries the duty.
A subtle point worth raising with strata clients: the AED, cabinet, signage and install are typically capital. Pads, batteries and maintenance are operating cost. Sort the budget categories at the same time you commit to the install — bodies corporate that don’t tend to argue levy categorisations after the fact.
Common-area placement and signage
A few practical placement notes for multi-tenant buildings:
- Ground-floor foyers near the main entrance are usually the right answer. Lift lobbies on intermediate floors are second-best — only useful if the public reaches them, which often they don’t.
- Staffed reception desks are a defensible placement. Unattended foyer wall mounts are also fine — the Act allows AEDs to be publicly accessible without staff supervision, as long as they’re not behind a key or code.
- Multiple AEDs in larger buildings. Where the count scales above one, distribute them so the furthest publicly accessible point is no more than a 60-second round-trip walk to the nearest AED.
Signage is where multi-tenant buildings often slip up. The Act requires a sign near the AED itself, plus a sign outside and near the entrance of the building indicating an AED is nearby. “Near the entrance” means the building’s main public entrance, not each tenancy’s door. If your building has multiple street entrances used by the public, signpost each. SA Health publishes templates that match the Australian Resuscitation Council symbol. Floor-level wayfinding near lifts is best practice but not strictly mandated.
Registration: don’t skip the SAAS register
Whoever is the responsible owner has to register the AED on the SA Ambulance Service AED Register within two weeks of installation. The register is what Triple Zero call-takers use to direct callers to the nearest device.
In a strata-titled building, the body corporate or its strata manager handles registration. In a single-owner building, the building owner does. If the AED moves — say, the foyer is renovated and the cabinet relocates — the registration must be updated within two weeks too.
Email registrations to health.saasaedregister@sa.gov.au. If you’ve installed AEDs through SafePulse, registration is included as part of every install — we lodge it the same week.
Practical approach for property managers
If you manage a multi-tenant building and you’re trying to work out where you stand:
- Identify the legal owner under the Act. For strata buildings, that’s the body corporate’s responsibility for common property. For single-owner buildings, the freehold owner.
- Map the publicly accessible floor area. Walk it, measure it, mark up the plan. Distinguish between total floor area (in-scope test) and publicly accessible floor area (count scaling).
- Decide AED count. Apply the two-step test. Most multi-tenant buildings under 12,000 m² of publicly accessible space need one to three AEDs.
- Set placement. Foyer or staffed reception is the default. For larger buildings, distribute so coverage is even.
- Confirm signage. External entrance signage plus AED-adjacent signage. Wayfinding internally for anything bigger than a single floor.
- Register within two weeks. SAAS register, via email.
- Maintain per the manufacturer. Typically two-yearly pads (or one-yearly depending on model), four-yearly battery, monthly self-test verification.
If you need a hand working out where the boundaries fall in your specific building, that’s the kind of question we work through with property managers most weeks. Drop us a line and we’ll walk it with you — survey plan in hand, no charge to scope it.
Where to from here
The SA AED Act is settled law now. The work for property managers in 2026 is no longer “is this real?” — it’s “have we got the right number of AEDs in the right places, and is the responsibility line clear in writing?” Multi-tenant buildings are where that question gets the most awkward.
Get the ownership boundary on paper, the floor area mapped and the AED count right. The whole thing only takes a couple of weeks if you commit to it.
Looking for help with multi-tenant building installs across Adelaide? See our AED installation services or send us the building details and we’ll come back with a scope.
