Fibre Reinforced Facade Encyclopedia: Testing and standards
A Deemed-to-Satisfy Solution is a design that complies with the National Construction Code by following the Code’s prescriptive provisions exactly. The NCC states its mandatory requirements as Performance Requirements, which are outcomes rather than recipes, and then provides a set of Deemed-to-Satisfy Provisions which, if followed, are taken by the Code itself to satisfy those requirements. Nothing further has to be demonstrated. It is one of the two compliance routes the NCC offers; the other is a Performance Solution, and a building may use both in different places.
The Deemed-to-Satisfy route answers the question by reference, not by analysis. For an external wall on Type A or Type B construction the answer is: the material is not deemed combustible when tested to AS 1530.1. Produce the report, and the requirement is met.
At a glance
| Property | Typical value | Note |
|---|---|---|
| Defined in | NCC 2022 Volume One Part A2 (check the edition adopted in your jurisdiction) | Formerly A0.5 and A0.9 |
| Status | A Solution that complies with the Performance Requirements | Not a lesser standard, and not optional guidance |
| External wall combustibility | C2D10, relying on AS 1530.1 | Formerly C1.9 |
| Fire resistance levels | Specification 5, by type of construction | Formerly Specification C1.1 |
| Fire hazard properties | Specification 7, group numbers and indices | Formerly Specification C1.10 |
| Evidence required | Part A5 evidence of suitability: test report, certificate of conformity, CodeMark, accreditation or expert judgement | Documents, not analysis |
| Who checks it | The building surveyor or certifier | Against the provision, not against an outcome |
| Mixing routes | Permitted; a building may be part DtS and part Performance Solution | Each departure needs its own justification |
| Typical facade materials | Glass fibre reinforced concrete, fibre cement, terracotta, stone, metal | Each needs its own AS 1530.1 report unless listed in C2D10 |
How the NCC is structured
The Code is written in a hierarchy. At the top are the Objectives and Functional Statements, which explain why a requirement exists. Below them are the Performance Requirements, which are the only mandatory provisions: they state the outcome a building must achieve, such as avoiding the spread of fire via the external wall. Below those sit two routes to demonstrate that the outcome is met.
The first route is to follow the Deemed-to-Satisfy Provisions, the detailed prescriptive clauses, specifications and referenced Australian Standards that make up most of the volume of the Code. The second is a Performance Solution, in which compliance with the Performance Requirement is demonstrated directly using one of the assessment methods the Code allows. Both are full compliance. The Code does not rank them, and a Deemed-to-Satisfy design is not safer in principle; it is simply pre-assessed.
What the route looks like for a facade
For the external walls of a building of Type A or Type B construction, the Deemed-to-Satisfy answer is C2D10: the external walls, and anything built into or attached to them, must be non-combustible. Non-combustible means not deemed combustible when tested to AS 1530.1, together with the short list of materials C2D10 permits without a test, such as plasterboard, fibre-reinforced cement sheeting and sarking within stated limits.
Alongside that sit two other prescriptive requirements: the fire resistance levels in Specification 5, which apply to the wall element rather than to the cladding on it, and the fire hazard properties in Specification 7, which set group numbers for internal linings and indices for other components. Part C3 adds vertical separation of openings, normally a spandrel of at least 900 millimetres with an FRL of 60/60/60 or an equivalent projection.
A facade that meets all of those is compliant by reference. The submission is a document set: the AS 1530.1 report for the cladding, the evidence for insulation, membranes and sealants, the fire resistance test evidence for the wall behind, and shop drawings showing the details match.
Why it is cheaper and faster when the material qualifies
- No fire engineer needs to be engaged for the facade, no fire engineering brief negotiated and no report written, which removes a fee and several weeks from the programme
- No peer review, and no fire brigade referral triggered by the facade
- The certifier is checking a document against a clause, which is a fast and predictable assessment rather than a judgement call
- The outcome does not depend on a specific building, so the same specification can be reused across a portfolio
- There are no ongoing conditions attached to the building: no sprinkler dependency, no maintenance obligation and no restriction written into a fire safety schedule
- Insurers, lenders and purchasers understand it without explanation, and due diligence at sale is shorter
- Future alterations are simpler, because a change to the facade does not reopen a building specific fire engineering argument
None of that makes the route better engineering. It makes it lower transaction cost, and on a project where the material qualifies anyway, that is usually decisive.
Where the route runs out
The Deemed-to-Satisfy provisions are prescriptive, which means they are also narrow. They describe the building the Code anticipated. Where a design uses a cladding that cannot pass AS 1530.1, an attachment outside the concessions in C2D10, an atrium, an unusual compartment size or a spandrel arrangement the Code does not contemplate, the route is simply unavailable and the design has to be justified against the Performance Requirement directly.
That is not a failure of the design and it is not a loophole in the Code. The performance route exists because prescriptive rules cannot anticipate every building, and a great deal of ordinary Australian construction relies on it. It costs more in time, fees and documentation, and it produces a result that is specific to one building.
Which ShapeShift system sits on which route
ShapeShell-RC, the glass fibre reinforced concrete system, is Not Deemed Combustible under AS/NZS 1530.1, tested by Ignis Labs. That report is what places it on the Deemed-to-Satisfy route for external walls of Type A and Type B construction. At 30 to 50 kilograms per square metre it is the heavier of the two systems, and it is the one to specify where the client or the certifier wants a prescriptive submission.
ShapeShell-RT, the fibre reinforced polymer system, is combustible. It cannot pass AS 1530.1, EN ISO 1182 or ASTM E136, and it is never described as non-combustible. It is not a Deemed-to-Satisfy material for an external wall on Type A or Type B construction. Its route is a Performance Solution, supported by an AS 5637 Group 1 classification from AWTA Product Testing, an EN 13501-1 class of B-s2,d0 from Intertek Testing Services, and a full-scale BS 8414 and AS 5113 pass at BRE Global. At 5 to 32 kilograms per square metre it buys weight and geometry, and it costs a fire engineering process.
Standards and references
- NCC 2022 Volume One Part A2 (compliance with the NCC) and Part A5 (evidence of suitability) (check the edition adopted in your jurisdiction)
- NCC 2022 Volume One C2D10 (non-combustible building elements), Table C2D2 (type of construction), Specification 5, Specification 7, Part C3
- AS 1530.1 (combustibility), AS 1530.3 (early fire hazard indices), AS 5637.1 (group number), AS 1530.4 (fire resistance)
- ABCB Performance Solution Process Handbook (for the alternative route)
- AS 5113 (external wall systems), used on the performance route rather than the Deemed-to-Satisfy route
Related terms
Questions specifiers ask
What does Deemed-to-Satisfy mean?
It means a design that follows the NCC’s prescriptive provisions, which the Code itself deems to satisfy the relevant Performance Requirements. No further demonstration is needed beyond evidence that the products and details are what the provision calls for.
Is Deemed-to-Satisfy compulsory?
No. The only mandatory provisions in the NCC are the Performance Requirements. A design may comply by following the Deemed-to-Satisfy Provisions, by a Performance Solution, or by a combination of the two in different parts of the building.
What is the Deemed-to-Satisfy route for external walls?
For Type A and Type B construction, C2D10 requires external walls and attachments to be non-combustible, meaning not deemed combustible when tested to AS 1530.1, or one of the materials C2D10 lists as usable without a test.
Is a Deemed-to-Satisfy solution safer than a Performance Solution?
The Code treats both as compliance with the same Performance Requirements. Deemed-to-Satisfy is pre-assessed and generic; a Performance Solution is assessed for one building and can address risks a prescriptive rule cannot see. The practical differences are cost, time, certainty and how transferable the outcome is.
Can FRP cladding be Deemed-to-Satisfy?
Not on an external wall of Type A or Type B construction. Fibre reinforced polymer is combustible and cannot pass AS 1530.1, so it requires a Performance Solution. ShapeShell-RC, the glass fibre reinforced concrete system, is the Deemed-to-Satisfy option.
If the project needs a prescriptive submission, ShapeShell-RC is Not Deemed Combustible under AS/NZS 1530.1, tested by Ignis Labs. See ShapeShell-RC specifications
Reviewed by Richard Halvorsen, General Manager, ShapeShift Technologies. Last updated September 2026.