Mandatory energy disclosure for hotels is coming to Australia in stages through to 2035. Large hotels will eventually be required to obtain a NABERS energy rating on a recurring basis and display it publicly, rather than disclosing only at the point of sale or lease as the office sector does today. Here’s what the roadmap actually sets out, and what hotel owners and operators should be doing now.
Key facts
- Mandatory energy disclosure for hotels is expected to apply first to large hotels, likely those over 100 rooms.
- The relevant rating is the NABERS hotel energy rating, in operation since 2009.
- Disclosure would move from a one off, point of sale event to a recurring requirement, likely every two to three years.
- The rating and the NABERS Renewable Energy Indicator would need to be displayed on the hotel’s website and booking pages, plus a public government register.
- The roadmap runs through to 2035, with hotels named as a high priority sector for near term expansion.
When will mandatory energy disclosure for hotels take effect in Australia?
There is no confirmed date yet, but hotels are named as a high priority sector in the Commercial Building Disclosure (CBD) Program Roadmap, released by DCCEEW in October 2025. Large hotels are expected to be brought into scope not long after the periodic disclosure trigger is legislated, ahead of medium priority sectors like shopping centres and data centres, which aren’t expected until the 2030s.
The roadmap does not set mandatory energy disclosure for hotels as an immediate obligation. It sets a direction and a sequence, with legislative change to the Building Energy Efficiency Disclosure Act 2010 required before any hotel specific determination is made.
What does mandatory energy disclosure for hotels actually require?
Under the current Commercial Building Disclosure Program, only office buildings over 1,000 square metres are required to disclose an energy rating, and only when sold or leased. The roadmap changes both settings for hotels specifically.
Large hotels would be required to obtain a NABERS hotel energy rating periodically, most likely every two or three years, regardless of any sale or lease event. The rating and the NABERS Renewable Energy Indicator would then need to be disclosed continuously on the hotel’s website and booking pages, as well as on a public government register. That is a meaningfully different obligation to a one off certificate produced at settlement.
The NABERS hotel energy rating itself is not new. It has been in operation since 2009 and has been reviewed with substantial industry input, which is part of why the roadmap treats it as ready for mandatory use rather than something still being developed.
The Green Building Council of Australia welcomed the roadmap, pointing to the track record of the existing office program as evidence the approach works. Office buildings covered by the CBD Program have reduced energy use by more than 40 percent on average since 2011, and the program has been credited with avoiding more than 11 million tonnes of emissions annually and saving an estimated 1.6 billion dollars in energy costs. The Energy Efficiency Council also welcomed the direction, though it argued the pace could be faster, noting that other large energy users such as shopping centres and data centres are not expected to be brought into scope until the 2030s.
Why is Australia introducing mandatory energy disclosure for hotels now?
Demand for verified hotel energy data is already outpacing voluntary reporting. Governments, corporates and increasingly personal travellers want trusted information about a hotel’s energy performance, particularly as more organisations formalise sustainable procurement policies for business travel. The Australian Government’s own Net Zero in Government Operations Strategy already requires public servants to weigh the environmental impact of work travel, and NABERS ratings are displayed against eligible hotels in its internal booking tool.
The NABERS hotel energy rating itself is not new, and that maturity is part of why the roadmap treats hotels as ready for mandatory disclosure rather than something needing further tool development. It has operated since 2009 and was reviewed with substantial industry input.
Industry response so far has been broadly supportive. The Green Building Council of Australia welcomed the roadmap and pointed to results from the existing office program as evidence the model works, office buildings covered by the CBD Program have cut energy use by more than 40 percent on average since 2011, avoided more than 11 million tonnes of emissions annually, and saved an estimated $1.6 billion in energy costs. The Energy Efficiency Council supported the direction too, though it argued other large energy users should be brought forward faster given Australia’s 2035 emissions target.
CBD Roadmap Hotel Timeline
How does Australia's approach to hotel energy disclosure compare globally?
Australia is not moving in isolation, but its method differs from most existing schemes. The UK introduced mandatory disclosure of Energy Performance Certificates in 2008, and several US states run their own disclosure policies, though adoption remains uneven. Both are largely attribute based, assessing a building’s features rather than its actual metered performance.
NABERS is different. It is performance based, built on real metered energy consumption rather than a checklist of attributes, and the roadmap document itself notes that many jurisdictions are now shifting toward performance based measurement because attribute only assessments have not reliably driven real reductions in energy use. For an international hotel group, this means a rating obtained under a UK or US scheme will not translate automatically into Australian compliance, since NABERS sits on its own performance based footing.
What should hotel owners do before mandatory disclosure applies?
The roadmap gives the sector a runway rather than an immediate deadline, and that runway is worth using. Obtaining a NABERS hotel energy rating voluntarily now means a hotel already understands its baseline, has time to address underperforming areas before disclosure is mandatory, and can use the rating today as a point of difference with corporate and government travellers already screening for it.
Bueno works with hotel owners and operators to build that baseline, track performance against it over time, and turn a NABERS rating into an ongoing operational advantage rather than a one off compliance exercise. For a closer look at how ratings translate into performance improvement, see Bueno’s NABERS ratings and building performance guide and our hotel energy management overview.
If you have any questions about mandatory energy disclosure for hotels, we have the answer.
Talk to Bueno about hotel energy disclosure
Want to know more? Contact Bueno for a demonstration of how our analytics platform helps hotels prepare for mandatory energy disclosure ahead of time.
