A Step Forward for Inclusive Design

The NCC 2025 Draft introduces a significant and welcome shift: a Deemed-to-Satisfy (DtS) pathway for all-gender toilets under Part F4D4.

This marks real progress toward more inclusive, flexible amenities that better reflect how people use spaces today. For designers and developers, it simplifies compliance pathways and supports more contemporary planning outcomes.

But as with many regulatory updates, the detail matters and this is where things get more refined.

The Catch: What About Ambulant Facilities?

While all-gender toilets are now recognised under DtS provisions, all-gender ambulant sanitary compartments are notably absent from Part F4D5.

This creates a gap.

Ambulant facilities—designed for people with limited mobility who do not require a full accessible (AS 1428.1) cubicle—remain tied to existing prescriptive requirements that do not yet contemplate all-gender configurations.

What This Means in Practice

Performance Solutions Are Still Required

If your design includes all-gender ambulant toilets, you cannot rely on DtS compliance alone.
A Performance Solution will be required, supported by:

• Clear justification against the NCC Performance Requirements
• Evidence-based design reasoning
• Stakeholder consultation (including access specialists and, where relevant, user groups)

Increased Compliance Risk

Without addressing this gap early, projects may face:

• Delays during building permit or certification stages
• Requests for redesign to revert to binary or compliant DtS layouts
• Increased costs due to late-stage changes

Strategy Is Critical

This is not just a documentation issue—it’s a design strategy issue.

Early engagement with an access consultant allows you to:

• Align layout planning with both DtS and Performance pathways
• Avoid conflicts between accessible, ambulant, and all-gender provisions
• Present a clear and defensible compliance approach to authorities

Designing Beyond Minimum Compliance

While the NCC sets minimum requirements, inclusive design goes further. A well-considered amenities strategy should aim to:

• Provide dignified, equitable access for all users
• Integrate accessible, ambulant, and all-gender facilities seamlessly
• Ensure clear signage and intuitive wayfinding
• Maintain consistency across the entire building

The goal isn’t just compliance—it’s usability.

Key Takeaway

The NCC 2025 Draft supports all-gender toilets under DtS but not ambulant all-gender facilities.

If you want to include them, a Performance Solution is still required.