Non-Combustible Facade Cladding: What NCC Compliance Actually Requires

The National Construction Code requires external walls of buildings of Type A and Type B construction to be non-combustible, and the requirement reaches the whole wall, not just the visible cladding. Clause C2D10(1) applies to external walls and common walls “including all components incorporated in them including the facade covering, framing and insulation”. A non-combustible panel over combustible insulation is not a compliant wall.

Before anything else, a jurisdictional point that catches people out in 2026: there is no single NCC edition in force across Australia right now. Check which edition applies to your project before citing a clause in a specification.

Which NCC edition applies, as at September 2026

The practical effect for a national supplier or a multi-state developer is that the same facade detail can sit under two different code editions in two states in the same month. Cite the clause and the edition together, and date the citation.

What C2D10 actually requires

C2D10 is titled “Non-combustible building elements”. The parts that matter for a facade:

• C2D10(1) requires external walls and common walls to be non-combustible, including the facade covering, framing and insulation, in buildings required to be of Type A or Type B construction.
• C2D10(4) lists concessions: items that may be present in an otherwise non-combustible element. There are seventeen, and they are narrow.
• C2D10(5) lists materials deemed non-combustible without testing, including concrete, steel, masonry, aluminium and stone.
• C2D10(6) lists further materials deemed non-combustible subject to criteria, including plasterboard, fibrous plaster, cement sheeting, metal sheeting and sarking.
• C2D13 provides the fire-protected timber concession, subject to strict conditions including sprinkler protection and non-combustible insulation.
• C2D14 governs ancillary elements: what may be attached to a non-combustible external wall.

Does the requirement apply to your building?

Only if the building is required to be of Type A or Type B construction. Type of construction is set by rise in storeys in Table C2D2. In broad terms, for Class 2, 3 and 9 buildings, four or more storeys is Type A, three is Type A, two is Type B and one is Type C. For Class 5, 6, 7 and 8, four or more is Type A, three is Type B, and one or two is Type C.

Type C construction is not caught by C2D10(1). A single-storey Class 5 office or a single-storey Class 6 retail building does not attract the non-combustibility requirement for external walls, which is why combustible cladding still appears legitimately on low-rise work. Confirm the classification and rise in storeys before assuming the requirement applies, and confirm it again if the building changes class or storey count during design.

The combustibility test: AS 1530.1

Non-combustibility is determined by AS 1530.1, the combustibility test for materials. It is a materials test carried out on a specimen in a furnace, and a material either passes as non-combustible or it does not.

For what a compliant report has to show, see GRC fire rating explained: AS 1530.1, AS 1530.3 and the test report.

Two things follow. First, a material test result is not a wall system approval: the assembly still has to be compliant as a whole. Second, the report has to match the product supplied. A specification should call for the test report with the sample description and the test date, not a supplier’s statement that a product is non-combustible.

Note also that while concrete appears in the C2D10(5) deemed list, manufacturers of engineered cementitious products generally test to AS 1530.1 anyway and publish the report, because a proprietary product with admixtures and coatings is not automatically the plain concrete contemplated by the deemed list. ShapeShift publishes independently tested fire performance data on its material fire rating page, and ShapeShell-RC is classified non-combustible when tested to AS 1530.1.

The concessions, and why they are narrower than people think

C2D10(4) permits specific items in an otherwise non-combustible element: gaskets, caulking, sealants, glass and adhesives, termite management systems, thermal breaks with size limits, damp-proof courses, compressible fillers under 50 mm, isolated packers, shims, blocking and fixings, acoustic mounts, below-ground waterproofing, joint trims and weather sealing under 50 mm, masonry wall ties, reinforcing bars in concrete, paints and lacquers, and fire-protective materials for service penetrations.

C2D14 then governs what may be attached to the wall: gutters and downpipes, flashings, grilles under 2 m², electrical components, light fittings, required signs, non-required signs subject to conditions, awnings and canopies meeting fire ratings, security and intercom systems, wiring, waterproofing to AS 4654.2, service collars and sleeves, vent screens to AS 3959, and door seals.

These lists are exhaustive rather than illustrative. If a proposed attachment is not on them, it is not covered by the concession and it needs its own compliance argument.

The Performance Solution route: AS 5113

Where a wall cannot satisfy the deemed-to-satisfy non-combustibility requirement, the alternative is a Performance Solution, and the standard usually involved is AS 5113:2016 with Amendment 1:2018, classification of external walls of buildings based on reaction to fire performance. It is a large-scale test of a complete wall system’s propensity for fire propagation rather than a test of a single material.

Three points that get misunderstood:

• AS 5113 is never a deemed-to-satisfy pathway. The ABCB is explicit that the classification alone does not indicate NCC compliance and that a Performance Solution must be developed in all cases.
• An EW classification is evidence, not approval. Achieving the classification does not by itself demonstrate compliance.
• It is used through Verification Method CV3 for fire spread via external walls, and using CV3 brings further requirements with it, including CV1 or CV2 for fire spread between buildings and sprinkler protection requirements for Type A construction and for Type B Class 2, 3 and 9 buildings.

The sprinkler consequence is the one to raise early. A cladding choice made to save money on the facade can add a sprinkler system to the project.

Which cladding materials satisfy the requirement

Working from the deemed lists and from published testing:

• GRC, glass reinforced concrete. Cement based and classified non-combustible when tested to AS 1530.1. Takes curvature and relief, which sheet materials cannot.
• Fibre cement. Cement based and non-combustible, flat sheet.
• Precast concrete. Non-combustible and the only common cladding that can also carry a fire resistance level in its own right.
• Terracotta. Fired clay, non-combustible, modular.
• Metal sheet and aluminium. In the deemed lists, subject to the criteria in C2D10(6) for sheeting.
• Aluminium composite panel. Depends entirely on the core. Combustible polyethylene-cored panels are the subject of Australia’s cladding audits and rectification programmes, and any aluminium composite in an external wall now carries a heavy evidence burden.
• FRP, fibre reinforced polymer. A polymer composite. Non-combustibility is not the applicable measure, so on a wall required to be non-combustible it is either the wrong material or needs a Performance Solution. It remains the right material for sculptural and weight-critical elements outside that constraint.

What to put in the specification

1. The building class, rise in storeys and type of construction, so the requirement’s applicability is on the record
2. The NCC edition and clause relied on, with the date of the citation, given the current state by state split
3. The compliance pathway: deemed-to-satisfy, or a Performance Solution with the Verification Method named
4. For deemed-to-satisfy: the AS 1530.1 report for each material in the wall, with sample description and test date
5. For a Performance Solution: the AS 5113 classification report for the tested system, and the consequential requirements including sprinkler protection
6. Every component in the wall build-up, because the requirement reaches framing and insulation as well as the covering
7. Any attachment relied on under the concessions, checked against the C2D10(4) and C2D14 lists

Project evidence

The distinction this page draws is not academic. These projects show where it bites.

• Victorian Comprehensive Cancer Centre: the colonnade and veins carry a cementitious finish incorporated during manufacture, so the completed structure looks and feels like concrete. The substrate underneath is a polymer composite. A finish that looks like concrete does not make a panel behave like concrete in a fire.
• Docklands BeachBall: a fire retardant grade was specified because the element sits at an exit point for the apartments. Fire retardant reduces flame spread; it is not the same as non-combustible.
• Victoria Pride Centre: cement-based GRC on the exterior vaults, polymer composite inside. The split follows the logic this page sets out.
• Brisbane Cross River Rail: cladding custom designed against a transport client’s safety requirements, which go well beyond a commercial specification.

The fire standards atlas shows how the NCC compares with the UK ban on combustible materials in external walls, test by test.

Frequently asked questions

Does the NCC require all external cladding to be non-combustible?

No. The requirement in C2D10(1) applies to buildings required to be of Type A or Type B construction. Type C buildings, which in broad terms are the lowest-rise cases, are not caught.

Is a non-combustible panel enough to make a wall compliant?

No. C2D10(1) reaches all components incorporated in the wall, including the facade covering, framing and insulation. A non-combustible panel over combustible insulation does not satisfy it.

What standard determines whether a material is non-combustible?

AS 1530.1, the combustibility test for materials. Some materials, including concrete, steel, masonry, aluminium and stone, are deemed non-combustible without testing under C2D10(5), and a further group qualifies subject to criteria under C2D10(6).

Is AS 5113 a way of complying without non-combustible materials?

Only through a Performance Solution. The classification on its own does not demonstrate compliance, and using Verification Method CV3 brings additional requirements including sprinkler protection for Type A construction and for Type B Class 2, 3 and 9 buildings.

Which NCC edition applies to my project?

It depends on the state and on the approval date. As at September 2026 Victoria is on NCC 2025, the ACT is in a dual-compliance window, New South Wales, Queensland, South Australia, Tasmania and the Northern Territory are still on NCC 2022 or its amendments, and Western Australia’s transition should be confirmed with the state regulator.

Getting the evidence for a live project

If a facade package is being assessed for non-combustibility, the useful next step is to send the build-up, the building class and the nominated pathway rather than a request for a rate. Start at contact, or read cladding panels compared and what is GRC.

This page summarises code requirements as at September 2026 and is not a substitute for advice from a fire engineer or building certifier on a specific project.

Terms explained

Short definitions of the terms on this page, in our facade materials encyclopedia.

• Non-combustibility
• AS 1530.1
• Group number
• AS 5113
• NCC external walls
• Fire resistance level
• Combustible cladding