Locker Room Accessibility | AS 1428 and BCA Compliance for Australian Clubs

Australia has more than 4.4 million people with disability, and participation in community sport and recreational activity is a recognised pathway to improved health, social inclusion, and quality of life. Sport Australia’s Inclusive Sport Design initiative has placed accessibility at the centre of community sport infrastructure planning. The National Disability Insurance Scheme (NDIS) has substantially increased the number of Australians with disability who are actively participating in sport. And yet, in most Australian community sports clubs, the change room remains one of the most significant accessibility barriers.

The legal framework for accessible design has been in place since the Disability Discrimination Act 1992. The Premises Standards (the Disability (Access to Premises – Buildings) Standards 2010) made specific building requirements enforceable. AS 1428 has evolved through multiple editions to provide detailed technical guidance. Thirty-plus years on, the gap between legal requirement and actual practice in community club change rooms remains significant.

What follows is a practical look at accessible locker room design—not a regulatory checklist, but a genuine design discipline that creates spaces that work for all athletes.

The Legal Framework: What You Are Required to Do

Understanding the compliance framework starts with understanding which standards and laws apply.

AS 1428.1 and AS 1428.2

AS 1428.1 (Design for access and mobility: general requirements for new building work) is the primary Australian Standard governing accessibility in the built environment. It sets out requirements for:

• Accessible paths of travel (including aisles and circulation spaces)
• Doorway widths and configurations
• Sanitary facilities (including accessible shower and toilet requirements relevant to change rooms)
• Reach ranges and controls
• Signage and tactile indicators

AS 1428.2 (Enhanced and additional requirements) provides more detailed requirements for specific elements including:

• Seating specifications (relevant to change room bench seating)
• Handrail configurations
• Enhanced circulation requirements

When designing a locker room, both standards apply. AS 1428.1 is mandatory for all new work; AS 1428.2 applies where enhanced accessibility is required or where the design aspires to best practice.

National Construction Code (NCC) / BCA Volume 1

The National Construction Code (Building Code of Australia, Volume 1) applies to Class 9b buildings, which includes sports facilities and changing facilities. The NCC incorporates AS 1428.1 by reference, so compliance with the NCC means compliance with AS 1428.1 for the purposes of building consent.

For Class 9b buildings, the NCC requires:

• Accessible paths of travel from the accessible entry of the building to all facilities that serve the public
• Accessible sanitary facilities in proportion to total sanitary facilities provided
• Accessible change facilities where change facilities are provided

The key phrase is “accessible change facilities where change facilities are provided.” This means: if your facility has change rooms, at least some of them must be accessible. There is no exemption for existing clubs or small organisations.

Disability Discrimination Act 1992 (DDA)

The Disability Discrimination Act 1992 is federal legislation that makes it unlawful to discriminate against a person with disability in, among other things, access to and use of premises used by the public. Sports clubs and facilities that are open to the public are covered, and most community clubs are, at least to players and spectators.

A person with disability who is denied access to a facility because it is not accessible can make a complaint to the Australian Human Rights Commission. The DDA does not have a set of technical specifications the way the NCC does. It is a principles-based law. But the effect is that non-compliant facilities that cannot be accessed by people with disability are legally exposed.

Premises Standards 2010

The Disability (Access to Premises – Buildings) Standards 2010 (Premises Standards) give more specific regulatory force to accessibility requirements. They apply to building work done under the NCC and specify what “compliant” means for purposes of the DDA. The Premises Standards essentially translate the DDA’s anti-discrimination principles into buildable requirements.

DDA Compliance for Existing Facilities

A critical point: the DDA and Premises Standards apply to building work, not retrospectively to all existing buildings. An existing non-compliant building is not automatically a DDA violation. However, if a complaint is made, the building owner needs to demonstrate that making the building accessible would impose “unjustifiable hardship.” For a locker room upgrade project, which is a deliberate and planned improvement, it would be very difficult to argue unjustifiable hardship as a reason not to include accessible elements.

The practical implication: any planned locker room upgrade is an opportunity (and arguably an obligation) to bring the facility into compliance with current standards.

Technical Requirements: What Accessible Locker Room Design Looks Like

Aisle Width

The aisle between facing locker runs (or between a locker run and the opposite wall) is the most critical dimension in an accessible change room.

NCC/BCA minimum: 1.2 metres clear width between obstacles in the accessible path of travel.

AS 1428.1 requirement for wheelchair manoeuvring: A wheelchair user requires approximately 1.5 metres of clear width to approach a locker, open the door, and retrieve items while remaining seated. Technically compliant at 1.2 metres; functionally practical at 1.5 metres.

Wheelchair passing: Two wheelchair users or a wheelchair user and a walking person passing in opposite directions in an aisle requires 1.8 metres of clear width. In busy shared facilities, 1.8 metres is the practical minimum for the principal aisle.

Our design standard: We target a minimum 1.5 metres in all locker room aisles, with 1.8 metres as the target where room dimensions allow. In rooms where existing constraints (structural elements, fixed wet areas) prevent 1.8 metres everywhere, we prioritise 1.8 metres in the accessible zone adjacent to accessible locker bays.

Accessible Locker Bay Dimensions

An accessible locker bay differs from a standard bay in several specific ways. The locker carcass (the outer shell, the door, the lock) is identical to a standard bay. The difference is in the internal fitting configuration and the provision for wheelchair access.

Hanging rail height. In a standard locker, the hanging rail is typically positioned at 1650 to 1800mm from the floor, comfortable for a standing person to hang a jersey or jacket. For an accessible bay, the hanging rail should be at 1050 to 1200mm from the floor. This is within the reach range of a seated wheelchair user (maximum forward reach is typically 1200mm; comfortable reach is 1100mm).

Reach range for storage. AS 1428.1 specifies reach ranges for accessible fittings: the usable storage range for a wheelchair user is generally 450mm to 1200mm from the floor. Storage elements above 1200mm should not be the only storage provided. An upper shelf that a standing person reaches easily but a seated person cannot is non-compliant if it is the only storage in the bay.

Knee clearance. Where a seat is integrated into the locker bay (common in our bench-integrated designs), the underside of the seat must allow knee clearance for wheelchair approach. AS 1428.1 specifies 900mm high, 600mm wide, 500mm deep as the minimum knee clearance space. This means the integrated seat in an accessible bay is mounted at a specific height with a specific clearance profile.

Seat height. Accessible seating in change rooms should be at 460 to 480mm from the floor (consistent with wheelchair seat height, facilitating transfer from wheelchair to bench). Standard change room bench seating is often at 430mm. That’s close, but the 460mm height makes transfer meaningfully easier.

Armrests. AS 1428.2 specifies that accessible seating include at least one armrest to assist with sit-to-stand transfer. Our accessible bay design incorporates an armrest on one side of the bench section adjacent to the accessible locker.

Turning Radius

AS 1428.1 requires that a wheelchair turning circle of 1500mm diameter be achievable at the point of use. In a change room context, this means at the accessible locker bay and in the adjacent circulation area.

This has layout implications. A locker bay at the end of a run, with open space in front of it and adequate aisle width, typically provides the required turning circle. A bay in the middle of a long run, with locker runs continuing on both sides and in front, may not. The layout design of the accessible bay (its position within the room) matters as much as the bay’s internal configuration.

Floor Surface

Accessible paths of travel need slip-resistant floor surfaces under AS 1428.1. For locker rooms, which often have wet floors, this is relevant throughout the room, not just in designated accessible zones. Our installation teams work with the floor surface specification provided by the facility manager; we do not supply or install flooring. However, we flag the slip resistance requirement as part of the design review process for any installation that will include accessible bays.

Signage and Tactile Indicators

Where building consent requires tactile ground surface indicators (TGSIs) to mark accessible paths, or tactile signage for accessible facilities, these are elements that form part of the building works rather than the locker installation itself. We note their locations in our design documentation to ensure they are not blocked or compromised by the locker run configuration.

How Many Accessible Bays Do You Need?

The NCC does not prescribe a specific ratio of accessible to standard locker bays. It requires that accessible change facilities be provided where change facilities are provided, and that access to those facilities be available on an accessible path of travel.

Practical guidance:

• Small change rooms (up to 15 lockers): A minimum of one accessible bay.
• Medium change rooms (16 to 30 lockers): A minimum of two accessible bays, or one per change room where there are multiple rooms.
• Large facilities (30-plus lockers, multi-room): One accessible bay per ten standard bays, distributed across rooms so that at least one accessible option is available in each change room.
• Facilities with active para-sport programs: Higher ratios, designed in consultation with the relevant sport’s para-sport program guidelines.

For council-operated and multi-sport facilities, the standard is higher. A facility that hosts wheelchair basketball, seated volleyball, or para-athletics programs needs to think about accessible change facilities at a more comprehensive level than a single-sport community club.

Existing Facilities: Addressing Non-Compliance

The majority of Australian sporting change rooms built before 2000 do not meet current AS 1428 requirements. Aisle widths are often too narrow. Accessible bays are absent or inadequate. Bench seating does not meet the height and armrest specifications of AS 1428.2. Shower and toilet facilities adjacent to the change room may also be non-compliant.

This is not a judgment on the clubs that operate these facilities. Standards were lower when the rooms were built, and retrofitting change rooms is expensive. But it is a reality that clubs need to address, particularly when a refurbishment provides the opportunity.

Who is responsible?

For facilities owned by the club, the club is the building owner and bears responsibility. For facilities owned by the council (the most common arrangement for community club change rooms), the council is the building owner and bears primary compliance responsibility. Clubs using council-owned facilities should formally raise accessibility deficiencies with their council. Most councils will treat a club-identified compliance issue as a legitimate infrastructure improvement request, particularly in the context of a planned club-led upgrade.

The refurbishment as compliance opportunity.

A locker room refurbishment that includes new locker installation provides an opportunity to address aisle widths (by reconsidering the locker layout), integrate accessible bays (designed into the new installation from the outset), and improve bench seating specification. The incremental cost of adding accessible elements during a full refurbishment is modest compared to retrofitting them after the fact.

The Inclusive Sport Context: Beyond Minimum Compliance

Compliance with AS 1428 and the NCC is the legal baseline. The best facility designs go further—creating change rooms that work well for all athletes, not just those who technically can use them.

Sport Australia’s Inclusive Sport Design guidelines encourage facility designers and clubs to think about accessibility as a continuum rather than a binary. A change room can be technically compliant but still practically difficult for a wheelchair user, a person with low vision, or a parent accompanying a young child with disability. The best design anticipates diverse users and makes the room work well for everyone who uses it.

NDIS and sport participation. More Australians with disability are playing community sport, thanks in large part to the National Disability Insurance Scheme (NDIS). Clubs in suburbs with significant NDIS participant populations should expect growing demand for accessible facilities. A change room that cannot accommodate a wheelchair user is a barrier to participation—and a reason for an NDIS-supported athlete to choose a different club.

Para-sport growth. Para-sport programs at the community level, including Blind Cricket, wheelchair rugby, deaf football, para-swimming, and sitting volleyball, are growing across Australia. National governing bodies are actively developing community para-sport programs. Clubs that can offer accessible facilities are positioning themselves to benefit from this growth.

Female and gender-diverse athletes. Accessibility for athletes with disability and accessibility for female athletes are often discussed separately, but they overlap in important ways. A change room designed for diverse users, with adequate space, appropriate privacy options, and flexible configurations, serves both populations better than a room designed for a single assumed user type.

Documenting Compliance: Supporting Grant Applications

Many Australian sport infrastructure grant programs include accessibility as a weighted selection criterion. Demonstrating that your proposed locker room upgrade meets or exceeds AS 1428 and NCC requirements strengthens your application materially.

We can certify, in writing on our letterhead, that a proposed locker installation meets the applicable accessibility standards. This certification is not a building consent document (that remains the responsibility of the certifying authority for the building works), but it provides grant assessors with assurance that the locker specification meets current standards.

Our design documentation includes:

• Dimensioned floor plan showing aisle widths and accessible bay locations
• Specification of accessible bay internal fittings (hanging rail height, shelf heights, seat height and clearance)
• Confirmation of standards compliance (AS 1428.1, AS 1428.2, NCC/BCA Volume 1)
• Material specifications relevant to floor interface and mounting

For clubs pursuing grant funding, including accessibility documentation in the application package is consistently associated with stronger assessment outcomes.

Practical Steps for Your Change Room Design

Whether you are planning a new installation from scratch or a refurbishment of an existing room, the accessibility design process follows the same steps.

1. Survey the existing room. Measure aisle widths, door widths, and identify any fixed elements (columns, plumbing, wet area walls) that constrain the layout. If existing aisles are narrower than 1.5 metres, note whether the locker run configuration can be adjusted to create more clearance.

2. Identify accessible bay locations. In consultation with our design team, identify which locker bays will be designated accessible. Accessible bays work best at the ends of locker runs, adjacent to open circulation space that provides the required turning radius.

3. Specify accessible bay internals. Our accessible bay configuration, with standard carcass and door, accessible-height hanging rail, appropriate shelf heights, and knee-clearance seat, is a standard option across all tiers. Confirm this specification during the design phase.

4. Confirm aisle dimensions. Review the final locker layout against the 1.5 metre target aisle width (1.8 metres in high-use circulation zones). Adjust the number of locker runs or their configuration if necessary to achieve the target.

5. Review adjacent facilities. Accessible locker bays should be on an accessible path of travel that connects to accessible shower and toilet facilities. Confirm that the path from the accessible locker to the accessible wet areas is clear and compliant.

6. Document for grant applications. Request our compliance certification and design documentation. Include these in any grant application.

Related Reading

• 10 Locker Room Design Mistakes Australian Clubs Make
• 7-Step Locker Room Planning Guide
• Locker Room Refurbishment Australia
• Multi-Sport Facility Locker Rooms