Australian Capital Territory only. Minimum energy efficiency standards for rental properties differ across Australian states and territories, and most have none. If you manage property outside the ACT, this article does not apply to you.

With 30 November 2026 approaching, a Canberra property manager with forty properties on the rent roll has a defined window to establish which of them comply with the ACT's ceiling insulation standard, arrange work on the ones that do not, and document the ones that are exempt.

Some of that work needs a tradesperson. Some of it needs roof access. And one category of exemption cannot be created by the landlord or the agent at all.

The Standard And The Deadline

The ACT Government states that rental properties with no ceiling insulation, or insulation below an R-value of R2, need to install or upgrade the ceiling insulation to a minimum R-value of R5. Properties with existing ceiling insulation of at least R2 meet the standard.

Landlords are responsible for ensuring their rental property meets the standard, and for the cost of any upgrades.

For existing tenancy agreements, landlords must ensure the property complies by 30 November 2026. That is the end of a phase-in period that began when the regulation commenced on 1 April 2023.

The R2 threshold is worth reading carefully, because it creates two different jobs. A property already at R2 or above requires no work at all. A property below R2, or with nothing up there, requires an upgrade all the way to R5, not merely to R2. There is no partial compliance in between.

The Nine Month Clock On New Agreements

The deadline is not a single date for every property. The ACT Government states that for new tenancy agreements, the landlord must ensure the property complies within 9 months of signing the new tenancy agreement, and that these timeframes apply unless the property is exempt.

For an agency, that turns a one-off compliance project into a recurring obligation. Every new tenancy signed from here starts its own nine month clock, attached to a specific property and a specific signature date. A leasing process that records the agreement date but not the resulting compliance deadline will lose track of that clock as soon as the property manager who signed it moves on.

The Exemption You Cannot Grant Yourself

Here is the part most likely to be misunderstood between now and November.

The ACT Government states that if a tenant refuses access to the property in writing, the landlord may claim a temporary exemption from compliance with the standard for the duration of the tenancy.

Read the mechanism rather than the outcome. The exemption depends on a written refusal from the tenant. It is not something a landlord or agent can declare because access proved difficult, because the tenant did not respond to three emails, or because scheduling never worked out. Without the tenant's written refusal, there is nothing to point to.

The practical consequence is that a tenant who simply ignores your access requests leaves you in the worst position available: no compliance and no exemption. If access is genuinely being refused, the thing you need is that refusal in writing, and you need it on file.

Other exemptions exist. The ACT Government publishes a landlord checklist and a landlord factsheet setting out the standard, the timeframes and the exemption categories, and those documents rather than a summary are what your compliance decisions should rest on.

The Obligation That Started In 2023

Alongside the physical standard sits a disclosure requirement that has been running since the regulation commenced.

The ACT Government's tenant factsheet states that landlords must disclose the property's compliance with the minimum standard in rental advertisements and when entering into a tenancy agreement.

For an agency, that is the obligation with the higher day-to-day exposure, because it applies every time a property is advertised rather than once before a deadline. Every ACT listing needs the compliance or exemption status stated, and it needs to be accurate. Check what your advertising templates currently say, and check that the status they carry is the current one rather than one entered in 2023.

Tenants also have the right to request and receive documentary evidence that the property meets the standard, so the evidence needs to exist in a form you can actually produce on request rather than as a recollection that someone did the work.

What The Auditor-General Found

This one is worth knowing, and it should not change what you do.

The ACT Audit Office examined the standard in Report No. 2 of 2025. Among its findings, a Compliance and Decision-Making Policy that had been planned was not prepared, and the report states that by not developing such a policy, ACT Government agencies' activities to monitor and enforce compliance with the standard is impaired.

The report also notes there had been a very low number of Sustainable Household Scheme loans taken out by landlords.

The temptation is to read that as breathing room. It is not. An audit finding that enforcement arrangements are incomplete is precisely the kind of finding that produces enforcement arrangements. The obligation itself is unchanged, the deadline is unchanged, and a report publicly identifying a monitoring gap tends to be followed by the gap being closed.

The more useful reading is the second finding. Financial support exists and landlords have been slow to use it, which is worth raising with owners who are hesitating on cost.

Access And Evidence

Two practical points for the remaining window.

Establishing whether a property already complies requires someone to look. For a property built recently enough that R2 or better was standard, the question may be answerable from records. For an older property, or one where nobody knows, it means roof access, a tenant, an appointment and a report.

That is an inspection with a deadline attached, which makes it a scheduled task rather than something to fit in around routine inspections. For an agency running forty properties through the same window, it is also a coordination problem: contractors, tenant access windows and evidence collection, all against one date. The same discipline that keeps ordinary maintenance requests moving is what will get this finished before November rather than during it.

What To Do Before 30 November

1. List every ACT property you manage and sort it into three groups: known compliant, known non-compliant, and unknown. The third group is the real work.

2. Read the ACT Government's landlord checklist and factsheet before making any exemption decisions.

3. For properties where access has been a problem, ask the tenant in writing and keep whatever comes back, because a written refusal is what supports a temporary exemption.

4. Check every current ACT advertisement states compliance or exemption status, and that the status is current.

5. Raise the Sustainable Household Scheme and Home Energy Support Program with owners who are resisting the cost.

6. Add a compliance deadline field to your new tenancy workflow, calculated nine months from signing, with a named owner.

Conclusion

Most rental compliance obligations can be met from a desk. This one needs a ladder, a contractor and a tenant who will let someone into the roof space, which makes the remaining window shorter than it sounds.

The properties that will cause trouble are not the non-compliant ones. Those at least have a known problem and a known fix. It is the unknown group, where nobody has been up there and nobody knows what is there, that determines whether an agency spends November scheduling insulation work or scheduling it retrospectively.

Frequently Asked Questions

1. What does the ACT ceiling insulation standard require?
The ACT Government states that rental properties with no ceiling insulation, or insulation below an R-value of R2, need to install or upgrade to a minimum R-value of R5. Properties with existing ceiling insulation of at least R2 meet the standard.

2. When is the deadline?
For existing tenancy agreements, landlords must ensure the property complies by 30 November 2026. For new tenancy agreements, the property must comply within 9 months of signing. These timeframes apply unless the property is exempt.

3. Who pays for the upgrade?
Landlords are responsible for the cost of upgrades to meet the standard. The ACT Government notes that eligible landlords can access support through the Sustainable Household Scheme and the Home Energy Support Program.

4. What happens if the tenant will not allow access?
The ACT Government states that if a tenant refuses access to the property in writing, the landlord may claim a temporary exemption from compliance for the duration of the tenancy. The exemption depends on a written refusal, so that document needs to be obtained and kept.

5. Do we have to say anything in the advertisement?
Yes. ACT Government material states that landlords must disclose the property's compliance with the minimum standard in rental advertisements and when entering into a tenancy agreement. Tenants also have the right to request and receive documentary evidence of compliance.

Important Notice

This article applies to the Australian Capital Territory only. Residential tenancy law in Australia is state and territory legislation. Minimum energy efficiency standards for rental properties differ between Australian states and territories, and requirements, deadlines and exemptions are not transferable.

Information was checked against ACT Government material published at act.gov.au and the ACT Audit Office report on the energy efficiency standard for rental properties published at audit.act.gov.au, available as at 8 September 2026. The governing legislation is the Residential Tenancies Act 1997 (ACT) and the associated regulation, which commenced on 1 April 2023. This article does not reproduce the full list of exemption categories or the accepted forms of evidence of compliance. Obtain the current landlord checklist, landlord factsheet and exemption criteria directly from the ACT Government before making a compliance or exemption decision, as guidance and requirements may change.

Always verify current requirements with the ACT Government before acting. This content is general information only and does not constitute legal advice. RIOO is not a law firm.