The certification pathway for a Queensland warehouse: Forms 15 and 16, private certifiers and the fire service
By Brenscot Builders | Last reviewed September 2026
A warehouse isn't lawful to occupy because construction has finished. In Queensland it has to pass through a building approval process under the Building Act 1975, run by a building certifier, with design certificates, inspections, a fire service referral in most cases, and a certificate of occupancy at the end.
This article explains the process in plain language for owners and investors, so you know what your builder and consultants are doing and what paperwork you should hold at the end.
The short answer
A private building certifier assesses the design against the National Construction Code (NCC) and Queensland's building laws and issues the building approval. Engineers and other designers certify their parts of the design on Form 15. During construction, nominated stages are inspected and certified. If the building has hydrants, sprinklers or a fire engineered solution, the application is referred to Queensland Fire and Rescue. When the work is complete the certifier issues a certificate of occupancy, and the building cannot lawfully be used without it.
More than one approval
Most new warehouses need three separate approvals, granted by three different parties:
- Development (planning) approval from the council under the Planning Act 2016, where the planning scheme requires it. This deals with land use, site layout, traffic, stormwater and similar matters. See how long a warehouse build takes.
- Operational works approval from the council under the Planning Act 2016, where the planning scheme makes the civil works assessable. This deals with earthworks, stormwater infrastructure, the driveway crossover and works in the road. It is a separate development permit, assessed by the council's engineers, and it is not covered by the building approval.
- Building approval (formally a building development approval) under the Building Act 1975. This deals with the building itself: structure, fire safety, access, health and amenity, and energy efficiency.
The certifier cannot issue a building approval that is inconsistent with the planning approval, so planning conditions feed into the building design. A building approval does not authorise the civil works, and an operational works approval does not authorise the building, so on most projects both are needed before the site is fully live.
The private building certifier
For most commercial and industrial work, the owner or builder engages a private building certifier. The certifier is licensed by the Queensland Building and Construction Commission (QBCC) and:
- Receives, assesses and decides the building application, acting as assessment manager
- Decides which competent persons' certificates to accept
- Refers the application to referral agencies where the law requires
- Sets the stages at which the work must be inspected
- Issues the certificate of occupancy
There are three licence levels. A Level 1 certifier may certify all classes of building. A Level 2 certifier is limited to buildings of up to 3 storeys and 2,000 m2 total floor area. A Level 3 certifier is limited to houses and minor structures. Many warehouses therefore need a Level 1 certifier.
Although you pay the certifier, the Building Act requires a private certifier to act in the public interest, and that duty overrides any obligation to the client. A good certifier engaged early is an asset, because the difficult compliance questions get answered while the design can still change. The certifier must notify the council of the engagement and lodge the approval documents with the council.
The forms you will hear about
| Form | What it is | Who signs it |
|---|---|---|
| DA Form 2 | The building application form | Applicant |
| Form 15 | Compliance certificate for building design or specification | A competent person for design, such as the structural, civil, hydraulic, fire services or energy efficiency designer |
| Form 12 | Aspect inspection certificate | An appointed competent person who inspected an aspect of the work, such as the structural engineer inspecting reinforcement |
| Form 43 | Aspect certificate | A QBCC licensee certifying their own work for certain aspects |
| Form 16 | Inspection certificate for a stage of the work | The certifier or a competent person |
| Form 71 | Commissioning certificate for fire hydrant and sprinkler systems | The appropriately licensed person who commissioned and tested the system |
| Form 11 | Certificate of occupancy | The building certifier |
A note on Form 21. In building certification, Form 21 is the final inspection certificate for houses and sheds (Class 1a and 10 buildings). It is not used for warehouses, which receive a certificate of occupancy. Confusingly, the survey plan lodged with Titles Queensland is also called Form 21. They are unrelated.
Form 15: design certificates
The certifier does not check every structural calculation personally. Under the Building Regulation 2021, the certifier can accept a certificate from a "competent person (design-specification)" stating that an aspect of the design complies. The certifier must first decide the person is competent, having regard to their qualifications, experience and any registration the law requires. For engineering design in Queensland, that means the certificate is signed by a Registered Professional Engineer of Queensland (RPEQ).
In practice, the certifier will not issue the building approval until the Form 15s they rely on are in, and design changes during construction need revised certificates. Uncontrolled changes on site create a paperwork problem at the end of the job.
Form 16 and Form 12: inspection certificates
During construction, the work is inspected at stages and certified as complying with the approval. The certifier may inspect personally or appoint competent persons, commonly the structural engineer for footings, slab and structural steel.
Inspection stages
For houses, the regulation lists mandatory inspection stages. For commercial buildings (Class 2 to 9), it does not. The stages are whatever the certifier states in the building approval, following the Queensland Government's Guidelines for inspection of class 2 to 9 buildings, which take a risk-based approach.
Typical stages for a warehouse are footings and slab before concrete is poured, the structural frame, fire-rated construction and fire-stopping before it is covered, the fire services, and the final inspection. Whatever the approval nominates, the builder must give notice at each stage and must not cover the work until it has been inspected.
When the fire service is involved
The Planning Regulation 2017 requires a building application to be referred to Queensland Fire and Rescue where the work:
- Requires "special fire services", which include fire hydrants, fire mains, sprinklers, fire detection and alarm systems, smoke exhaust and smoke-and-heat venting systems, and vehicular access for large isolated buildings, or
- Includes a fire safety performance solution (the regulation still calls this an "alternative solution")
Queensland Fire and Rescue is part of the Queensland Fire Department, which replaced Queensland Fire and Emergency Services (QFES) on 1 July 2024. It acts as an advice agency to the certifier.
Because the NCC requires fire hydrants for buildings over 500 m2, most warehouses are referred. There are two points in the project where this matters:
- At design. The referral assessment takes time and attracts fees. Allow for it in the programme.
- At completion. The installer or builder must give the fire service notice to inspect and test the special fire services. Under the Building Regulation 2021, the fire service has 5 business days to advise that it won't inspect, or otherwise 15 business days to inspect and report. The certificate of occupancy cannot be issued until this step is complete or the period has lapsed.
See fire services for warehouses.
The certificate of occupancy
This is the document that makes the building lawful to use. It was called a certificate of classification until 1 October 2020.
- The certifier issues it when the building is substantially complete and the fire service inspection requirements have been met. The applicant must first provide a list and drawings of the building's fire safety installations
- It records the building's classification and use, and any restrictions or conditions arising from performance solutions
- A building, other than a house or shed, must not be occupied or used without one (Building Act 1975, section 114)
- The owner must display it as near as practicable to the main entrance (section 108A)
- A certificate of occupancy can be given for a completed part of a building, which allows staged occupation where the certifier is satisfied that part complies
Keep it safe. Buyers, lenders, insurers and tenants ask for it. If the use of the building later changes to a different classification, a new approval is needed.
Other completion requirements
- Plumbing and drainage. Approved and inspected separately by the council's plumbing inspectors under the Plumbing and Drainage Act 2018, with a final inspection certificate.
- Fire and evacuation plan. The occupier must have a fire and evacuation plan under the Building Fire Safety Regulation 2008 and keep it current. Have it ready for the day you move in.
- Maintenance of fire safety installations. An ongoing obligation, with an annual occupier statement.
- Planning conditions. Conditions of the development approval, such as landscaping, stormwater devices and car parking, must be complied with before the use starts.
- Operational works completion. Where the civil works were built under an operational works approval, the council inspects them and, where they become council assets, places them on maintenance for a period before accepting them. See how long a warehouse build takes.
- QLeave levies. Paid to QLeave before the building approval issues, on work costing $150,000 or more.
- Plan sealing and titles for multi-unit projects. See community titles and plan sealing.
Questions to ask on your project
- Who is the certifier, and do they hold the right licence level?
- Which Form 15s are required, and who is providing each?
- Does the fire service referral apply, and has it been lodged?
- What inspection stages has the certifier nominated?
- Are there any performance solutions, and what ongoing conditions do they impose?
- What documents will I receive at handover?
On a Brenscot design and construct project we manage all of this. We are not the certifier, and the certifier's independence matters.
Frequently asked questions
What does a private building certifier do?
They assess the building design against the NCC and Queensland building law, issue the building approval, arrange or carry out inspections during construction, and issue the certificate of occupancy.
What is a Form 15 in Queensland?
A compliance certificate for building design or specification, given by a competent person such as an engineer, confirming that their part of the design complies with the relevant codes and standards.
What is the difference between Form 15 and Form 16?
Form 15 certifies a design. Form 16 certifies that a stage of the constructed work has been inspected and complies with the approval.
Does the fire brigade have to approve my warehouse?
If the building needs hydrants, sprinklers or other special fire services, or uses a fire safety performance solution, the application is referred to Queensland Fire and Rescue for advice, and they may inspect and test the systems at completion.
Can I move in before the certificate of occupancy is issued?
No. Occupying or using the building without one is an offence under section 114 of the Building Act 1975.
Sources
- Building Act 1975 (Qld), sections 11, 48, 74, 102, 103, 108A, 114, 136, 143 and 152 to 154
- Building Regulation 2021 (Qld), sections 33, 34, 44 and 65 to 67
- Planning Regulation 2017 (Qld), Schedule 9 Part 3 Division 3 and Schedule 19
- Queensland Government, building forms, the Guidelines for inspection of class 2 to 9 buildings (March 2023), and guidance on the certificate of occupancy, business.qld.gov.au
- Queensland Fire Department, referral agency advice, fire.qld.gov.au
- Building Fire Safety Regulation 2008 (Qld)
General information only
This article is general information, current as at September 2026. It is not legal advice or a lodgement checklist. Forms, competent person rules and referral triggers are set by Queensland legislation and change over time. Confirm the requirements for your project with your building certifier.
Planning an industrial warehouse?
Talk to Brenscot about your site or your requirements. Call 0480 800 077, email enquiries@brenscot.com.au, or start an enquiry. You can also read how we work.