Your annual Fire Safety Statement (AFSS) due date is one year after the previous year’s AFSS was submitted. But while this anniversary is every 12 months, unless the AFSS is submitted on the same day each year, the AFSS due date can be a moving target, creeping backward or forwards. This can is what we call an AFSS ‘creep’.

An AFSS is similar to a car pink slip in the way it is completed every 12 months, but rarely exactly on the same day. This means you may either be early- causing you to end up paying more over time, or late – leaving yourself open to non-compliance fines.

Because the building owner submits the AFSS to the council, and the council only correspond with the building owner, the practitioner is not informed of the date change unless the building owner advises them.

AS1851 calls for the routine schedules to be based on the original commissioning date. The monthly, 6 monthly, yearly, etc., are determined by when the system first came online. If an inspection is done late (or early), AS1851 specifies the next inspection should still be done based on the commissioning date. The routine inspections are not reset based on when the last inspection was done.

For example, if a building has an annual inspection in January every year and the AFSS is due in March. If the AFSS is submitted one month early in February, the following year, the annual inspection is carried out in January, but the AFSS is now due in February.

This may not leave enough time to conduct the inspection and any subsequent repairs if necessary. This is further compounded if the AFSS is summited 1 month early again. The opposite can happen when the AFSS is submitted late, as the AFSS may be rejected if the inspection date is greater than three months prior.

So, what can be done about it?

Our preference is to conduct the annual inspection in the same month each year and submit the AFSS on the due date each year. If the AFSS due date is March 15th, we conduct the annual inspection in January, and the building owner submits the AFSS on the 15th of March every year.

If an AFSS is submitted one month late, the following year, it should be submitted 1 month early.

If an AFSS is submitted early, we recommend the building owner contacts the council and explain the situation. The council may update the due or accept the AFSS late if they understand why.

It is not advisable to adjust the inspection schedule as this is against the guidance given in AS1851. Moving an inspection forward (e.g., less than 12 months between annual inspections) is better than delaying an inspection. If there are more than 12 months between annual inspections, it could expose the building owner to liability in an emergency event.

*Please note that some local councils are determining the anniversary using the date the building owners signs the AFSS, not submission date, so just be mindful of this.

If you’re unsure of how best to manage your AFSS due date, get in touch with our AFSS experts on (02) 8669 9100 and we can guide you through the process to ensure you remain compliant without breaking the bank.