The legal position, in one paragraph
Since 6 September 2026 the Physical Agents Regulations (PAR), issued under the Occupational Health and Safety Act, have made emergency escape-route lighting an explicit statutory requirement for every qualifying workplace. Every emergency luminaire must be certified to SANS 1464-22 (compulsory under VC8055), the installation must be designed to SANS 10114-2, and the building must hold records that prove the system is tested and maintained. The National Building Regulations (SANS 10400-T) separately govern means of escape and exit signage for the building itself. An office block has to satisfy both.
Landlord or tenant — who is responsible?
Under the OHS Act the duty sits with the employer for the workplace it controls. In practice a multi-tenant building splits that duty two ways: the landlord or managing agent is responsible for the base building and common areas — lobbies, lift lobbies, stairwells, corridors, parkades, plant rooms and final exits — while each tenant is responsible for the escape routes inside its own let premises. Leases usually say so explicitly; where they are silent, the safest reading is that both parties are exposed.
Section 16 of the OHS Act places the duties on the chief executive officer of the employer personally, which is why boards and property funds now ask for compliance evidence rather than assurances. A landlord who can show a certified, tested base-building system — and can ask tenants for the same inside their premises — has answered the question before it is asked.
Where the fittings go in a typical office building
SANS 10114-2 defines three kinds of emergency lighting, and an office block needs all three in different places:
- Escape-route lighting — every corridor, stair flight, change of direction, corridor junction, change of floor level, final exit and the area immediately outside it, plus each fire-equipment and first-aid point. "Near" means within two metres horizontally.
- Open-area (anti-panic) lighting — large open-plan floors, reception atriums and canteens, so people can find the start of an escape route rather than freezing in the dark.
- High-risk task-area lighting — server rooms, plant rooms, kitchens and any workstation where a sudden blackout is itself dangerous.
Parkades, stairwells and the signage trap
Enclosed parkades and stairwells are the places where a building most often fails an inspection. They are windowless, they are the last part of the route out, and they are usually signed with photoluminescent (glow-in-the-dark) signs on their own. A photoluminescent sign is not emergency lighting: it needs a certified luminaire close by to charge it and to light the ground beneath it. Running-man exit signs to SANS 1186-1, backed by SANS 1464-22 luminaires, are the compliant answer at every final exit and change of direction.
Fit-outs change the escape route — every time
The single most common compliance failure in commercial property is not a missing system; it is a system designed for a floor plan that no longer exists. A tenant fit-out that adds a boardroom, moves a partition or closes a door changes the escape route, and the emergency lighting has to be re-validated against the new layout. Build it into the fit-out sign-off: no occupation certificate from the landlord until the tenant produces a current emergency-lighting design and test record for the new plan.
Testing, records and the logbook
A compliant building is a documented building. The standards call for a monthly function test of every luminaire and an annual full-duration discharge test, with the results logged. In a building with several hundred fittings across many floors that is a real workload, which is why self-test luminaires and wireless monitoring (the GELS Lynk gateway) matter: each fitting tests itself and reports, the logbook fills itself, and the facilities manager gets an exception list instead of a clipboard.
A phased roadmap for a commercial building
- Week 1 — a free gap assessment of the base building: walk the escape routes with the 9-point check, count what exists, check certificates.
- Weeks 2–4 — design to SANS 10114-2 for the common areas; prioritise stairwells, final exits and parkades.
- Weeks 4–10 — install certified luminaires and exit signs. Conversion kits bring existing fittings up to standard without a rip-and-replace where the fitting is sound.
- Ongoing — tenant programme: a standard clause in the lease and fit-out guide, and a shared logbook so the whole building can be evidenced in one place.
The GELS view
We work with landlords, managing agents and tenants as one accountable team: assessment, design, certified product, installation and the logbook that proves it. If you manage a commercial building and are not sure where it stands, the most useful first step is a walkthrough — it turns a vague worry into a costed, prioritised list.
Questions building owners ask
- Is emergency lighting compulsory in office buildings in South Africa?
- Yes. Since 6 September 2026 the Physical Agents Regulations under the OHS Act require emergency escape-route lighting in every qualifying workplace, and the National Building Regulations (SANS 10400-T) require exit signage and means of escape in the building itself.
- In a multi-tenant office block, is the landlord or the tenant responsible for emergency lighting?
- Both. The landlord or managing agent is responsible for the base building and common areas (stairwells, corridors, lobbies, parkades, final exits); each tenant is responsible for the escape routes inside its own premises. Check the lease — where it is silent, both parties are exposed.
- What standards must office emergency lighting meet?
- Every luminaire must be certified to SANS 1464-22 (compulsory under VC8055), the installation must be designed to SANS 10114-2, and exit signs must comply with SANS 1186-1.
- Do glow-in-the-dark exit signs make a building compliant?
- No. Photoluminescent signs are not emergency lighting on their own — each one must be backed by a certified emergency luminaire within about two metres that charges it and lights the route beneath it.
- How often must emergency lights in an office be tested?
- A monthly function test of every fitting and an annual full-duration discharge test, with results recorded in a logbook. Self-test luminaires and wireless monitoring automate both.
Sources
See where your building stands.
Run the free 9-point escape-route check, or talk to the compliance team — we advise on the technical and legal detail wherever you need it.