Who’s Responsible for TGSI Compliance?

If your building has stairs, ramps, platform edges, or public walkways, someone is legally responsible for ensuring that the tactile ground surface indicators (TGSIs) on your site comply with applicable standards.

The question we get asked most often isn’t “what are tactiles”, it’s “whose job is this, actually?” Building owners, strata committees, facility managers and even head contractors all assume compliance sits with someone else. In our experience across schools, healthcare sites, retail centres and strata buildings throughout Sydney and the Illawarra, that assumption is exactly how buildings end up non-compliant for years without anyone noticing.

This guide sets out who’s actually on the hook, what non-compliance can cost you, and how to find out where your site stands before it becomes a problem.

TGSI Compliance Isn’t Optional: It’s the Law

Tactile ground surface indicators aren’t a design nicety. They’re a requirement under the Disability Discrimination Act 1992 (DDA) and the Disability (Access to Premises, Buildings) Standards 2010, which work alongside the National Construction Code and AS/NZS 1428.4.1 to set out where TGSIs must be installed and how they need to perform.

That means TGSI compliance isn’t just a building code checkbox ticked off at construction sign-off. It’s an ongoing legal obligation tied directly to anti-discrimination law, and it applies whether your building was constructed last year or thirty years ago.

Who Actually Carries the Responsibility?

This is where things get murky, because the answer depends on who controls the property and when the obligation arose.

Building owners

As the ultimate controller of the premises, the building owner generally bears the primary compliance obligation for common property and public-access areas, regardless of who occupies the building on a day-to-day basis.

Strata and owners corporations

For strata title buildings, the owners corporation is typically responsible for TGSI compliance on common property: stairwells, lobbies, shared car parks and walkways. This obligation sits with the strata committee even if no individual lot owner raises it.

Developers and builders

At construction or major refurbishment stage, the developer and builder are responsible for installing TGSIs to specification as part of Building Code sign-off. Once the certificate of occupancy is issued, though, that responsibility transfers to whoever controls the building going forward.

Facility and property managers

Managers don’t usually bear the legal liability directly, but they’re the ones expected to identify risks and flag them to the owner or the owners’ corporation. In practice, this is where most compliance gaps are caught, or missed.

The common thread: compliance obligations don’t disappear because a building changes hands, gets a new manager, or was built before current standards existed. If you control the site today, the obligation is yours today.

What Non-Compliance Actually Costs You

Non-compliant TGSIs aren’t just a safety issue. They carry real financial and legal exposure.

DDA complaints: Any member of the public can lodge a disability discrimination complaint with the Australian Human Rights Commission over inaccessible premises. These complaints are public record and can result in enforceable undertakings.

Access to Premises Standards enforcement: Non-compliance can trigger formal conciliation processes, and unresolved complaints can escalate to the Federal Court.

Public liability exposure: A slip, trip or fall linked to a missing or non-compliant hazard indicator strengthens any subsequent injury claim against the building owner.

Insurance complications: Some public liability policies specify compliance with relevant Australian Standards as a condition of cover, and a gap here can affect a claim after the fact, not just before.

Reputational cost: For schools, healthcare providers and retail landlords in particular, an accessibility complaint becomes a public and community relations issue well beyond the immediate legal exposure.

None of this requires intent. Most non-compliant sites we assess weren’t neglected on purpose. The building simply predates current standards, or a refurbishment years ago didn’t account for TGSI requirements. The law doesn’t distinguish between deliberate and accidental non-compliance; the exposure is the same either way.

New Build vs Retrofit: Different Compliance Triggers

For new construction, TGSI installation is assessed as part of the standard Building Code approval process, so compliance is generally established at handover, assuming it was installed and certified correctly in the first place.

Retrofit situations are where most of the risk sits. A change of building use, a fit-out, a refurbished stairwell or even a repaved car park can trigger a fresh compliance obligation, and older buildings that have never been assessed against current standards often have no TGSIs at all in areas where they’re now required. If your building hasn’t had a dedicated TGSI review, age of construction is not a defence.

How to Find Out If Your Site Is Compliant

You don’t need to guess. A proper compliance check follows a clear process:

Site walk-through against AS/NZS 1428.4.1: identifying every hazard point that requires a warning or directional indicator: stairs, ramps, platform edges, pedestrian crossings and changes in level.

Luminance contrast testing: confirming that existing tactiles (if any) meet the required contrast against the surrounding surface, since faded or poorly matched tactiles can appear compliant but fail in measurement.

Placement and setback review: checking indicators sit at the correct distance from each hazard, not just that they exist.

A written compliance report: a clear record of what’s compliant, what isn’t, and what’s required to close the gap, which also becomes useful evidence of due diligence if compliance is ever questioned.

This process gives building owners and strata committees a defensible position: either confirmation the site is compliant, or a clear, budgeted path to get there, rather than an open-ended question mark hanging over the property.

Getting It Fixed Without Disrupting Your Site

Retrofitting TGSIs into an occupied building sounds more disruptive than it usually is. Installation is generally fast, and for active sites (schools, retail centres, healthcare facilities), the work can be scheduled after hours or on weekends so there’s no impact on operating hours or foot traffic.

For a deeper look at what compliant TGSIs actually involve, the standards, materials and installation process, see our companion guide, What Are Tactiles? A Guide to TGSI Compliance covers the technical detail in full.

Get a Clear Answer on Where Your Site Stands

JDA Services carries out TGSI compliance assessments and installation across Sydney and the Illawarra, working with building owners, strata managers and facility teams to identify gaps and close them with minimal disruption to your site.

Book a TGSI compliance check with JDA Services today. Get a clear, written picture of where your building stands and what it would take to close any gaps.