As of this month, the bar for leasing office space to the Commonwealth moved. Under the Net Zero in Government Operations strategy, new government office leases now require a 6.0-star NABERS Energy rating and all-electric operation, heating, cooling and hot water included. For building owners chasing one of the largest, most reliable tenants in the country, the question has changed from "should we upgrade" to "in what order". This post lays out what the rules actually say, why 6.0 stars is a different kind of target from 5.5, and where measured occupancy fits in the compliance story.
01 · WHAT THE RULES ACTUALLY SAYWhat the rules actually say
The requirements arrived in phases, and the phasing is the strategy:
- From July 2025: new Commonwealth office leases of four years or longer, over 1,000 square metres of net lettable area, require a minimum 5.5-star NABERS Energy rating maintained for both base building and tenancy.
- From July 2026: the bar rises to 6.0 stars for new leases, and the building must be all-electric, with heating, cooling and water heating running without gas (backup generation excepted). New buildings built for the Commonwealth, and purchases or constructions over $15 million, carry the same 6-star requirement. The energy-efficiency framework behind this sits with the Department of Climate Change, Energy, the Environment and Water, and industry analysis has called it a tipping point for the net zero property sector, because the Commonwealth's leasing footprint is large enough to reset what "prime grade" means.
Two details deserve more attention than they get. First, the ratings are based on twelve months of measured operational data, not design intent; a building earns its stars in operation, every year, under the Commercial Building Disclosure framework. Second, the requirement covers tenancy ratings as well as base building, which pulls fit-out, plug loads and after-hours behaviour into scope, territory that is invisible to the plant room.
02 · WHY 6.0 STARS IS A DIFFERENT PROBLEM FROM 5.5Why 6.0 stars is a different problem from 5.5
The NABERS scale is not linear in effort. The step from 5.5 to 6.0 stars typically demands the kind of energy intensity that scheduling tweaks and lamp swaps cannot reach, because the remaining waste is structural: plant serving space that is not occupied the way the control logic assumes.
That is the connection to occupancy, and it is more direct than it first appears. HVAC is roughly 40 per cent of a typical office building's energy. A building that conditions and ventilates to a fixed schedule is spending that energy against an assumption, and hybrid work has made the assumption wrong by a margin that shows up at exactly the precision a 6.0-star rating demands. The fixes with headroom left in them are operational: run the plant against measured occupancy instead of the timetable, find the shadow vacancy that lets whole zones be set back, and use per-zone data to justify smaller after-hours conditioning envelopes.
Design gets a building to the door of 6.0 stars. Twelve months of measured operation is what walks it through.
Electrification runs on the same logic. All-electric heating and hot water shift load onto plant whose sizing and run-hours owners will want to minimise. The right size is a function of real demand, and real demand in an office is a function of when people are actually there.
03 · WHERE MEASURED OCCUPANCY FITS THE COMPLIANCE STORYWhere measured occupancy fits the compliance story
We build occupancy analytics, so this is the part we can speak to concretely. Three places the data earns its keep in a NABERS-driven programme:
- The energy case before the capital case. Four weeks of per-zone occupancy against the current HVAC schedule quantifies the gap between when the building is conditioned and when it is used. That number sequences the upgrade programme: it says which floors, which plant, and how much headroom operational change buys before capital is spent.
- Evidence in the submission pack. A rating built on measured performance is easier to defend with measured inputs. An audit-grade occupancy report documents the demand side of the energy story: this is when the building was occupied, this is how the plant responded.
- Keeping the stars once you have them. The rating is annual. Occupancy drift, a new tenant, a changed hybrid policy, a returned mandate, silently invalidates last year's control settings. A live feed catches the drift in the utilisation numbers before it appears in the metering.
The privacy note matters in this market specifically: government tenancies carry workforce-surveillance sensitivities that make camera-based monitoring a hard sell. Our architecture counts anonymously on the device, no video stored or transmitted, which is what lets the same data serve the energy programme without opening a staff-monitoring debate. That argument, in procurement terms, is made here.
04 · THE SEQUENCE THAT MAKES SENSEThe sequence that makes sense
For an owner staring at the gap between a 5.0-star asset and a 6.0-star requirement, the boring order of operations is the right one: measure how the building is actually used, harvest the operational savings that measurement reveals, then size the electrification capital against the corrected demand profile. Measurement first is not caution, it is sequencing: every percentage point of demand you remove operationally is plant you do not buy twice.
If the demand-side measurement is the piece you are missing, the reports layer is where our platform meets a NABERS programme, and a walkthrough of your building is the fastest way to scope what four weeks of data would show.