Most of the AED problems we find in Victorian buildings aren’t caused by people ignoring the rules. They’re caused by people misreading them — usually in one of two directions. Either they’ve assumed Victoria has no AED obligations at all, or they’ve assumed Victoria works like South Australia.
Both are wrong, and they produce different failures. Here are the ones we see most, and what to do instead.
Mistake 1: Reading “should consider” as “you can ignore this”
Victoria has no AED-specific legislation. No Act, and unlike New South Wales, no Bill has ever been tabled in the Victorian Parliament. No minimum building size, no deadline, no penalty for not having a defibrillator.
What you do have is a duty under section 21 of the Occupational Health and Safety Act 2004 to ensure, so far as is reasonably practicable, that the workplace is safe. WorkSafe Victoria’s Compliance Code: First Aid in the Workplace — November 2021, still the current version — puts it plainly: employers should “consider whether it is reasonably practicable to have an automated external defibrillator in the workplace as these are not difficult to use and save lives.”
The word doing the work is consider, and it genuinely is discretionary. The mistake is treating the absence of a mandate as the absence of a question.
“Reasonably practicable” gets applied after the fact, against what you knew and what it would have cost you to act. A workplace with high public foot traffic, an older workforce or physically demanding work has a more foreseeable cardiac arrest risk than a quiet three-person office — and if the question was never asked, there’s nothing on the record showing you weighed it. So ask it and write down the answer. If the conclusion is genuinely no, a dated note explaining why is worth more than silence. We go deeper on the Code’s language in what the WorkSafe Victoria Compliance Code says about AEDs.
Mistake 2: Importing the South Australian rules into Victoria
More common since January 2026, when South Australia’s AED laws started applying to privately owned buildings. Multi-state operators read the SA rules, assume they’re a national standard, and start quoting them at Victorian sites.
None of the following apply in Victoria:
- The 600 m² building threshold
- The publicly accessible floor area calculation and the AED count table above 1,200 m²
- Mandatory signage at the device and at the building entrance
- Mandatory registration within two weeks of installation
- Designated facility categories requiring an AED regardless of size
- Penalties for failing to install, maintain, register or sign
Those are all real obligations — in South Australia, under the Automated External Defibrillators (Public Access) Act 2022. In Victoria they’re best practice at most.
This isn’t pedantry. When someone discovers that half of what they were told was a legal requirement isn’t one, the credibility of the rest goes with it — including the parts that genuinely carry weight.
Mistake 3: Assuming Victoria has no AED rule anywhere
There is exactly one. The Non-Emergency Patient Transport Regulations 2016 (Vic) require an AED in vehicles used for non-emergency patient transport (regulation 44) and in “first aid stations” under those regulations (regulation 51).
That’s the entire scope of AED mandates in Victoria, and it applies only to licensed NEPT operators — no bearing on offices, retail, hospitality, sporting facilities or industrial sites. Worth knowing either way: if you run a NEPT operation it’s not something you can risk-assess your way out of, and if you don’t, it’s a reminder that “Victoria has no AED law” needs one small asterisk.
Mistake 4: Locking the cabinet
The most common physical mistake, and the most frustrating, because the intention is good. Someone worries about theft, so the AED goes in a cabinet with a key, into a locked comms room, or behind a door that’s swipe-card only after hours.
WorkSafe Victoria is direct on this: AEDs “should be installed in well-known, visible and accessible locations. They should not be locked.”
A cardiac arrest gives you a few minutes. If the response starts with finding whoever has the key, the device has stopped being a defibrillator and become an expensive ornament — you’ve paid for the equipment and the install and kept none of the benefit.
If security is a genuine concern, the answer is supervision rather than restriction. Put it where staff can see it — reception, a security desk, a monitored corridor — and use an alarmed cabinet that makes tampering obvious rather than access difficult.
Mistake 5: Skipping registration because it’s voluntary
Ambulance Victoria runs a free AED register integrated with GoodSAM. Registration is voluntary, so plenty of owners never get around to it, and two things get given up.
Registered devices are visible to Triple Zero call takers, who can direct a caller to the nearest AED, and to GoodSAM Trusted Responders, who get alerted with AED locations when a nearby arrest is reported. That’s the difference between your device being found by someone who doesn’t work in your building and it sitting unused thirty metres from an arrest.
The second is post-use support. If a registered device is used in a public emergency, Ambulance Victoria arranges recommissioning, downloads the patient data for the treating hospital, returns the unit within 72 hours and provides free replacement pads. Unregistered, you’re organising all of that yourself at the worst possible time. Enquiries go to aed.register@ambulance.vic.gov.au — it takes minutes and costs nothing.
Mistake 6: Waiting until staff are trained
We’re occasionally told a site is holding off installing because nobody’s trained yet. Well-meant, and it delays the wrong thing.
WorkSafe Victoria’s position is unambiguous: “Anyone can use an AED on someone who is suspected of being in cardiac arrest. You do not need specialised AED training.” The devices talk you through it, and they won’t deliver a shock unless they detect a rhythm that needs one.
CPR and AED training is worth doing — trained staff act faster and hesitate less. But it’s an improvement on having a device, not a prerequisite. An untrained bystander with an AED beats a trained one without.
Mistake 7: Installing it, then forgetting it
The failure we find most on service calls anywhere in the country: a device on the wall three or four years, pads well past expiry, battery flat, nobody assigned to look at it.
Victoria has no legal AED maintenance duty — South Australia is the only state that does. But Ambulance Victoria’s baseline isn’t onerous: assign one or two people to check monthly that the AED is functioning and the pads haven’t expired. Add a six-monthly service on top — pads and battery replaced ahead of expiry rather than after, connections checked, placement still sensible — and you’ve covered it. Pads date from manufacture, not installation, so read the printed date rather than assuming a full run.
An AED with expired pads is worse than no AED, because it reads as cover. Nobody standing in front of it goes looking for another option.
Mistake 8: Building the plan around a grant round
Defibrillators are eligible under Sport and Recreation Victoria’s grant streams — the Sporting Club Grants Program lists first-aid and safety equipment in Category 1, and the Emergency Sporting Equipment Grant Program covers urgent replacements after an incident.
Both are worth pursuing if you’re an eligible not-for-profit sporting organisation, but rounds open and close — the 2025–26 Sporting Club Grants round closed in April 2026. Check sport.vic.gov.au/funding for the current position rather than assuming a round is live, and don’t treat a closed round as a reason to wait. If the risk assessment says you need a device, funding is a question of how you pay, not whether you have one.
Mistake 9: Quoting an IP rating as a Victorian requirement
For outdoor or semi-outdoor placements an enclosure rated IP55 or above is sound practice, and we specify to that standard. It is not a Victorian regulation — neither WorkSafe Victoria nor Ambulance Victoria publishes a minimum IP rating. Recommend it as best practice; don’t attribute it to a regulator that hasn’t said it.
One requirement is genuinely binding, though it’s federal rather than Victorian: AEDs installed in Australia must be approved by the Therapeutic Goods Administration.
Mistake 10: Assuming someone else has it covered
In a multi-tenant Victorian building the OHS duty can sit with several parties at once — owner, managing agent, and tenants each running their own workplace. Victoria has no equivalent of the SA Act’s single named “owner”, which sounds like flexibility and often works as a gap.
The pattern is predictable. The owner assumes tenants will sort out first aid; the tenants assume common-area safety equipment belongs to the building. Nobody installs anything, and nobody’s exactly wrong, which is the problem.
Fix it by naming it: who provides the device, who maintains it, who holds the register entry — in the lease, the building’s emergency plan, or both. Ambiguity is what leaves a foyer without a defibrillator.
Where this leaves you
Victoria’s position is straightforward once you stop looking for a rule to comply with. There isn’t one, and there’s no sign of one coming — the push for mandatory legislation is real but no Bill has been tabled, which we’ve covered in will Victoria mandate AEDs.
What you’ve got instead is a duty that asks whether you considered a foreseeable risk and acted reasonably on what you found. Every mistake above is a version of skipping that step, or of answering a different state’s question. The full framing is in Victorian OHS duty of care: first aid and AED obligations.
If you’d like a second set of eyes on a Victorian site — where a device should go, whether your current placement would work under pressure, what upkeep it needs — start at our Victorian AED page or get in touch for a no-obligation assessment.
Frequently asked questions
Are AEDs mandatory in Victoria?
No. Victoria has no AED-specific legislation and no Bill has ever been tabled. The only exception is the Non-Emergency Patient Transport Regulations 2016, covering NEPT vehicles and first aid stations. For everyone else it’s the general OHS duty plus the Compliance Code’s “should consider” guidance.
Do the South Australian AED rules apply in Victoria?
No. The 600 m² threshold, the AED count table, mandatory signage and mandatory registration are all South Australian requirements under the Automated External Defibrillators (Public Access) Act 2022.
Can I keep a Victorian workplace AED in a locked cabinet?
You shouldn’t. WorkSafe Victoria says AEDs should be installed in well-known, visible and accessible locations and should not be locked. If theft is a concern, use a supervised location and an alarmed cabinet rather than a key.
Do staff need training before we install an AED?
No. WorkSafe Victoria states anyone can use an AED on a person suspected of being in cardiac arrest, and that specialised training isn’t needed. Training helps people act faster, but it isn’t a reason to delay the device.
