Multiple Pools or Spas on One Property: One Form 23 Per Barrier

Published by Local Pool Inspections · inspections carried out by Ryan Gaw, Building Inspector (Pool Safety), BPC-registered (formerly the VBA) — Licence IN-PS 100055.

A Form 23 certifies a barrier, not a body of water. So the question is never “how many pools do I have.” It’s “how many separate barrier enclosures.” A pool and spa inside one fence is one Form 23. A pool and a separately fenced spa is two. We see both layouts most weeks across Point Cook and the Bellarine. Owners get caught out in both directions. Some expect two certificates when they need one. Just as many assume one will cover the lot.

The Underlying Rule

AS 1926.1, the Australian Standard for residential pool and spa safety barriers, applies to swimming pools and spa pools, meaning any body of water capable of being filled to more than 300 mm deep. Each such body of water needs a compliant barrier around it, and each barrier needs its own Form 23 certificate. Where two bodies of water sit inside the one barrier, that single enclosure is certified once.

The layouts we turn up on Victorian properties sort into six cases.

• Pool with spa inside the same barrier: one Form 23 covers the combined enclosure.
• Pool and separate spa, each with its own barrier: two Form 23s, one per enclosure.
• Two pools sharing one barrier: one Form 23 covers the shared enclosure.
• Two pools with separate barriers: two Form 23s.
• Water feature over 300 mm deep in its own enclosure: Form 23 required.
• Water feature under 300 mm deep: no Form 23, though other compliance considerations can still apply.

One Victorian quirk catches people out here. Each pool is assessed against the Australian Standard in force when it was built, and keeps that standard for life. So on a property with a 1990s pool and a newer spa, we can be measuring the two enclosures against different editions of the standard on the one visit. The older pool isn’t automatically held to the current figures.

Common Multi-Body Configurations

Pool and spa in the same barrier (most common)

This is the setup we walk into most often. One pool fence encloses the pool and the spa together, so one Form 23 covers the lot. The thing being assessed is the barrier around the whole enclosed area, which means the perimeter fence, every gate and the non-climbable zone. The bodies of water sitting inside it are not what gets certified.

Pool with separately fenced spa (high-end residential)

Some Bellarine and Sanctuary Lakes properties run a primary pool with a separately enclosed spa, often where the spa is tucked into an outdoor entertaining area with its own fence and gate. Two barriers means two inspections and two certificates. Both get done on the same visit, and there is no second travel charge for the extra one.

Pool plus indoor spa (luxury homes)

An indoor spa can sit outside the outdoor-barrier requirements, but only where the room itself controls access the way the regulations require. Whether it does hinges on the specific room and how it is secured, and owners tend to assume one way when the answer turns out to be the other. It is not worth guessing at. Mention the indoor spa when you book and we will scope it against your actual setup before quoting.

Pool plus reflective water feature

A decorative pond or water feature deeper than 300 mm falls under the same barrier rules as a pool. Owners with elaborate landscaping get blindsided by this one more than anyone. The threshold turns on water depth rather than design intent, so an ornamental pond that reads as shallow can still cross the line. If you are not sure how deep yours runs, measure it before you book, or send us a photo.

Pricing for Multi-Body Properties

Each separate barrier is its own inspection and its own $250 inc GST fee. So one pool barrier plus a separately fenced spa barrier is two inspections at $250 each, done on the same visit. Our guide to what the $250 fee covers lists everything included in each one.

Three things you are not charged twice for.

• Travel: one trip covers the whole property visit.
• Council lodgement: both Form 23s go in under the one submission.
• Re-inspections: if a barrier fails and comes back with a non-conformance report, that re-inspection is free, per barrier.

Point Cook: Sanctuary Lakes, Saltwater Coast, Featherbrook

This Wyndham corridor throws up more multi-body pool properties than anywhere else we cover. On the estate-design lots, one block can hold several of these at once.

• A formal pool with its own barrier.
• A spa within or beside the pool, sometimes separately enclosed.
• An entry or courtyard water feature, occasionally deeper than 300 mm.
• On lake-frontage lots, a private water interface with the lake that adds further considerations.

The layouts vary enough that scoping one from a photo beforehand is worth the two minutes it takes. Send images of each pool zone when you book. We will tell you up front how many Form 23s you are looking at, rather than working it out on the day. Lodgement in this corridor goes through Wyndham City, which runs its own process; the Wyndham council process guide covers that side of it.

Higher-End Bellarine Properties

Larger blocks around Drysdale, Curlewis, and the Portarlington and Indented Head strip occasionally run a pool with a separately enclosed spa. It is a less common pattern here than at Sanctuary Lakes. It still comes up enough to say plainly. If your spa has its own fence and gate, it is its own certificate.

Selling a Multi-Body Property

The Section 32 vendor statement has to carry every required Form 23. A missing certificate on the spa stalls a sale exactly the way a missing certificate on the pool does. So if you are preparing to list, check that you hold a current certificate for each barrier. Everyone remembers the main pool. The spa is the one that gets left off. The Section 32 timeline guide walks through what’s needed and when.

If you have inherited or recently bought a multi-body property and do not know how many certificates it needs, tell us the layout at booking. We will work it out with you before the visit.

Council Registration for Multi-Body Properties

Each barrier-enclosed body of water needs its own entry on the council’s Pool and Spa Register. If you have a pool plus a separately enclosed spa and only the pool is registered, the spa has to go on the register before its Form 23 can be lodged. Most councils handle this through a single form with multiple entries. A spa that shares the pool’s barrier is a different case. It is part of the one enclosure, so it does not need its own registration. If yours is a stand-alone spa, see the spa safety certificate guide.

FAQ

Do I need a separate Form 23 for my pool and my spa?

Only if they sit in separate barrier enclosures. A spa inside the same fence as the pool is covered by one Form 23. A spa with its own fence and gate is a second barrier and needs its own certificate.

Does a water feature need a Form 23?

If it’s deeper than 300 mm, capable of being filled, and in its own enclosure, yes — it’s treated as a pool or spa under the standard. Under 300 mm deep, no Form 23 is required, though other compliance considerations can still apply. If you’re unsure of the depth, measure it or send us a photo before booking.

How much does it cost to inspect two barriers on one property?

$250 inc GST per barrier, both done on the same visit with no second travel charge. A pool barrier plus a separately fenced spa barrier is two inspections at $250 each, and each barrier keeps its own free re-inspection if remediation is needed.

Can two pools built in different years be on the same property?

Yes, and each is assessed against the Australian Standard in force when it was built. An older pool isn’t automatically required to be upgraded to the current standard — the inspector measures each enclosure against the edition that applied at the time it was constructed.

Do pond regulations in Victoria apply to a water feature?

Yes, if it can hold water deeper than 300 mm. Depth decides it, not design intent: a decorative pond or reflection pool over 300 mm deep is treated as a pool or spa under the barrier rules and needs its own compliant barrier and Form 23 unless it shares an enclosure with the pool. Under 300 mm, no Form 23 is required.