WHO CAN LEGALLY ACT AS A PROJECT MANAGER FOR YOUR BODY CORPORATE IN QUEENSLAND?

In Queensland’s building and construction industry, the role of a “Client-Side Project Manager” is commonly used across strata and body corporate projects, particularly for defect remediation, façade works, and capital upgrades.

However, what many committees and managers don’t realise is that this role is not formally recognised as an exempt category under legislation. Instead, it is regulated under the Queensland Building and Construction Commission Act 1991 (QBCC Act), which focuses on what activities are being performed, not what the role is called.

This distinction is critical—and often misunderstood.

Why This Matters for Body Corporates

Any building work in Queensland exceeding $3,300 falls under the QBCC regulatory framework. If a person or company is coordinating, directing, or taking responsibility for building work, they may legally be considered to be performing “building work”, even if they are called a “project manager.”

This means:

They must hold an appropriate QBCC licence, or
Be a registered architect or engineer operating within their professional scope.

Failing to meet these requirements can expose all parties, including the Body Corporate, to:

Invalid or unenforceable contracts.
Loss of payment entitlements.
Regulatory penalties.
Increased defect and compliance risk.

Who CAN Act as a Client-Side Project Manager?

Under Queensland legislation, the following can legally undertake project management functions where they involve control or responsibility over building work:

QBCC Licensed Builders (Project Management Services)

These professionals can:

Coordinate and manage trades
Administer construction contracts
Direct works and sequencing
Assess variations and progress claims
Take responsibility for delivery outcomes

Registered Architects and Engineers

They may provide project management or contract administration services, provided:

They operate strictly within their registration
They do not contract to carry out building work

QBCC Licensed Trade Contractors

Only where the services remain within the scope of their specific licence class

Who CANNOT Legally Perform These Functions?

A common compliance issue in strata arises when individuals unintentionally step into regulated roles.

The following cannot perform project management involving building work unless licensed:

Body Corporate Managers.
Onsite/Building Managers.
Body Corporate Committee Members.
Consultants providing more than administrative support.

Where the Line Is Drawn

A person does NOT require a licence where their role is strictly limited to:

Obtaining quotes.
Reporting information.
Acting as a liaison.
Supporting decision-making without authority.

However, once they begin:

Directing contractors.
Sequencing works.
Approving variations or payments.
Certifying quality or completion.

They may be deemed to be undertaking “building work”, triggering licensing requirements.

Common Compliance Breaches in Strata

Across Queensland, ASQ frequently sees well-intentioned committees and managers unknowingly breach the QBCC Act by:

Issuing instructions directly to contractors.
Coordinating multiple trades onsite.
Approving or negotiating variations.
Recommending contractor payments.
Acting as a “de facto” construction manager.

These actions may seem minor, but legally, they can shift liability and risk onto the Body Corporate.

The Key Takeaway

There is no standalone “project manager” licence in Queensland. Instead, the legal requirement comes down to one simple question:

Are you influencing or controlling how building work is carried out?

If the answer is yes, a QBCC licence (or appropriate professional registration) is likely required.

Why This Is Becoming Increasingly Important

With rising defect claims, insurance scrutiny, and larger remediation projects across strata buildings, regulators are paying closer attention to who is actually controlling construction outcomes.

Engaging a properly licensed, independent client-side project manager ensures:

Compliance with legislation.
Reduced risk exposure.
Proper contract administration.
Independent oversight of contractors.

Final Thoughts

For Body Corporate committees, the safest approach is clear:

Stay in governance and decision-making roles.
Avoid directing construction activities.
Engage appropriately licensed professionals for project delivery.

Understanding these boundaries is not just about compliance, it is about protecting your building, your finances, and your legal position.

Article Contributed by Kate Broadbent, Director at ASQ.

Kate Broadbent will also be guest speaking at the upcoming Cairns seminars next week on the 28^th of May, where attendees can learn more about who can legally act as a project manager for your body corporate.

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