Access-controlled doors on escape routes: SS 3/2, fire alarm release and the BWOF

If you are adding swipe card or fob access to a commercial building, some of those doors will be on escape routes. Here is what New Zealand's fire safety rules expect of them, how they are inspected under the building warrant of fitness, and what to ask your installer.

By the Com4 team, Penrose · Updated 2 November 2026

Short answer: a card, fob, keypad or electrically locked door on an escape route must always let people out without a card, key or code. Under the Acceptable Solution C/AS2 (Second Edition), that means visible, easy-to-use release hardware, locks that either unlock or can still be opened when power fails, and any delayed-egress delay of no more than 15 seconds, overridden instantly by the fire alarm. In a building with a compliance schedule, these doors are normally specified system SS 3/2, access-controlled doors, and must be inspected and maintained for the annual building warrant of fitness (BWOF).

What is SS 3/2?

Specified systems are the safety systems in a building that are listed on its compliance schedule and checked for the BWOF. Specified system 3 covers doors and windows that are automatic or interfaced with other systems, and SS 3/2 is "access controlled doors", alongside SS 3/1 (electromagnetic or automatic doors) and SS 3/3 (interfaced fire or smoke doors). Councils, such as Whangārei District Council, list them separately in their compliance schedule forms.

The NZ Security Association's 2026 guideline describes SS 3/2 doors as access-controlled doors that form part of a building's means of escape. It lists card and proximity-controlled doors, keypad doors, electrically locked escape doors, delayed egress doors and doors interfaced with the fire alarm.

Why does this matter when buying a swipe card access system?

Most quotes for a swipe card or fob system focus on readers, cards and software. On an escape route, the door hardware and the fire alarm interface matter just as much, because they decide whether people can get out. When you compare quotes, check that each escape door includes:

  • The right lock for the door, such as a fail-safe magnetic lock or an electric lock or strike where the inside handle always opens the door mechanically.
  • Request-to-exit and emergency release where the lock cannot be opened mechanically from the inside, with signage where the release is not obvious.
  • A fire alarm interface wherever the design needs the door to unlock on alarm.
  • Commissioning, testing and documentation so the door can be added to the compliance schedule and inspected.

Our access control cost guide explains how these items show up in a price, and our access control page covers the systems we install.

What does C/AS2 say about locked doors on escape routes?

C/AS2 is the Acceptable Solution for protection from fire in most buildings other than houses. The Second Edition took effect on 28 July 2025; the First Edition could be used for building consent applications up to 31 July 2026. The key requirements for access-controlled doors are:

C/AS2 clauseWhat it requires (summary)
3.9.2.2Locking devices must be clearly visible, where you would expect them, and easy to operate in a fire without a key or other security device. An unusual action, such as pressing a button next to the door, needs signage complying with F8.
3.9.2.3Locking must not override panic fastenings where those are required.
3.9.2.4If power fails or the system malfunctions, electromechanical locks must unlock (fail safe) or be readily opened another way.
3.9.6.1Access control systems are not allowed across an escape route at any point leading into or within an exitway. They are allowed in an open path or at a final exit if they keep providing a safe means of escape when power fails or the system malfunctions, by opening automatically and staying open, or by being pushed open outwards.
3.9.8.1Delayed-action unlocking is only allowed with a Type 4 or Type 7 fire alarm system, where activating the fire alarm instantly overrides the delay. The delay can be no more than 15 seconds, with signage to F8/AS1.

This is a summary. Read the clauses in full, and remember that a fire engineer's alternative solution may set different requirements for your building. The fire report and consent documents are what the door has to match.

How should the fire alarm release work?

Where the design requires it, the access control system or the door hardware is interfaced with the building's fire alarm so the door unlocks when the alarm activates. On delayed-egress doors, the fire alarm has to override the delay instantly. Good practice is to:

  1. Take the release signal from the fire alarm panel through a monitored interface, not from software alone.
  2. Make sure the door unlocks if the access control controller, network or software fails.
  3. Size power supplies and batteries so that locks behave as designed during a power cut.
  4. Agree with the fire alarm contractor and IQP how the interface will be tested, and who resets it.
  5. Record the cause-and-effect for every door, so it can be tested the same way each year.

The NZSA guideline sees the fire alarm interface, delayed egress override and reset as key items in technician testing.

How are access-controlled doors inspected for the BWOF?

Building owners must issue a BWOF to the council every 12 months, confirming that the specified systems on the compliance schedule have been inspected and maintained. MBIE's Compliance Schedule Handbook (first edition, amendment 3, published February 2014) explains how compliance schedules, inspections and BWOFs work. Check the handbook page for any newer edition before relying on it.

The NZSA's June 2026 good practice guideline for SS 3/2 doors, developed with input from MBIE, describes three levels of inspection:

LevelWhoTypical checks
1. Routine checksBuilding owner or occupier, usually monthlyEmergency release visible and unobstructed, no added deadlocks or chains, signage in place
2. Technical testingQualified technician, at least annuallyEmergency door release, request-to-exit, lock release, fire alarm interface, delayed egress override, reset, power supplies and batteries
3. IQP verificationIndependent qualified person, annuallyConfirms the inspection, maintenance and reporting procedures were followed, so the BWOF can be issued

The guideline suggests more frequent technical testing for some buildings, for example six-monthly in hospitals and every 6 to 12 months in retail. It also recommends fixing defects that affect egress as a priority, and adding emergency door releases to existing doors where practicable. Keep the records, because they support your BWOF.

What should building owners and managers check?

  • Every access-controlled escape door is on the compliance schedule. Doors added since the last consent often are not, and adding a specified system needs a building consent.
  • Nobody has added a padlock, chain, deadbolt or "hold" setting that stops the door releasing.
  • Your service contract covers SS 3/2 testing, including the fire alarm interface, not just the access control software.
  • Defect reports go to someone who can authorise repairs quickly.

This comes up most often in schools, offices and managed property portfolios, where doors are added over time by different contractors.

How Com4 can help

Com4 has been installing commercial security in Auckland since 2011, as Com4 since 2023, and holds PSPLA licence 25-128630. We design and install access control with door hardware and fire alarm interfaces that suit escape routes, work with fire engineers, fire alarm contractors and IQPs during commissioning, and provide SS 3/2 inspection and maintenance through our service and maintenance team. See our commercial security installation page for how we run projects. Call 0800 266 444 or use the form below.

Frequently asked questions

Can a swipe card door be on a fire escape route?
Yes, in many places, provided people can always get out without a card, key or code and the door stays safe if power fails or the system malfunctions. C/AS2 does not allow access control across an escape route leading into or within an exitway, and the building's fire design may add other limits.
Do access-controlled doors need to be on the compliance schedule?
In buildings that have a compliance schedule, access-controlled doors that form part of the means of escape are normally listed as specified system SS 3/2, and they must be inspected and maintained for the annual BWOF. Adding a new SS 3/2 door needs a building consent so the compliance schedule can be amended.
How often should SS 3/2 doors be tested?
Follow your compliance schedule. The NZSA's 2026 guideline suggests monthly owner checks and technical testing at least annually, with an annual IQP verification. It suggests more frequent technical testing in some buildings, such as six-monthly in hospitals.
How long can a delayed-egress door hold?
Under C/AS2, no more than 15 seconds. It must be in a building with a Type 4 or Type 7 fire alarm system that instantly overrides the delay, and it needs signage complying with F8/AS1.
Does the fire alarm have to unlock every access-controlled door?
Not always. It depends on the door, its lock and the building's fire design. Delayed-egress doors must be released by the fire alarm, and many designs require other escape doors to unlock on alarm too. The fire report and compliance schedule set out what each door must do.

Sources

This guide is general information, not fire engineering or legal advice. Your building's fire report, consent documents and compliance schedule set the requirements for each door.

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