A cafe for up to 25 patrons needs one male closet pan, one urinal, one female closet pan and a washbasin for each, and no patron toilets at all are required where not more than 20 persons are accommodated, under NCC 2022 Table F4D4d.
Skai Solutions answers the phone for cafes and restaurants across Australia and New Zealand, and this is one of the questions operators cannot get a straight answer to. Most of what ranks for it is written for the United Kingdom or sells washroom fittings. So here is the Australian table itself, in full, with the two rules that decide which row you are on: how design occupancy is calculated from your floor area, and the 20-person exemption that lets a small takeaway counter trade with no customer toilet.
Here is the table, which is the thing almost nobody publishes. The National Construction Code 2022, Volume One, Table F4D4d sets patron facilities for restaurants, cafes and bars by design occupancy.
| Design occupancy | Male closet pans | Male urinals | Male washbasins | Female closet pans | Female washbasins |
|---|---|---|---|---|---|
| 1 to 25 | 1 | 1 | 1 | 1 | 1 |
| 26 to 50 | 1 | 1 | 1 | 2 | 1 |
| 51 to 100 | 1 | 2 | 2 | 3 | 2 |
| 101 to 150 | 2 | 3 | 2 | 4 | 2 |
| 151 to 200 | 2 | 4 | 2 | 5 | 3 |
| 201 to 250 | 2 | 5 | 3 | 6 | 3 |
| 251 to 300 | 2 | add 1 per 100 | 3 | add 1 per 100 | 3 |
Read the columns separately, because the male and female requirements diverge fast. At a design occupancy of 100 a venue needs one male pan but three female pans. That asymmetry is deliberate and it is the single most common thing operators get wrong when they look at a floor plan and count doors.
Two notes that come straight from the code. Unless your premises are used predominantly by one sex, you calculate on the basis of equal numbers of males and females, so a 100-person venue is 50 and 50. And in a Class 6 building, which is what a cafe is, employees and the public may share facilities as long as the total meets the combined requirement for both groups.
This is where the number comes from, and getting it wrong is how a 40 square metre shop ends up being told it needs three toilets.
Clause F4D3 says that where the actual number of occupants is not known, you use the occupancy figures in D2D18. For a restaurant that is one person per square metre of floor area. So a 60 square metre cafe has a design occupancy of 60 unless you can show otherwise, which splits to 30 male and 30 female, which means one male pan, one urinal, one male basin, two female pans and one female basin.
The code gives you the way out, and it is worth taking. Where fixed tables, booths or alcoves take up much of the floor area, you may instead count the number of seats available to patrons, allowing for staff and for alternative seating layouts that could increase the numbers. A 60 square metre cafe with 28 fixed seats plus four staff is a design occupancy of 32, not 60. On the table above that is the difference between two female pans and two female pans, so nothing, but at 90 square metres it is the difference between three female pans and two. Count the seats and write the count on your plan.
Sometimes yes, and the threshold is specific. Table F4D4d says patron facilities need not be provided where the total number of persons accommodated is not more than 20. That is the rule behind every small takeaway counter and laneway espresso bar with no customer toilet.
Three warnings before you rely on it. First, 20 is persons accommodated, and if your fit-out seats 18 but people stand, the fire and occupancy figure your certifier uses may be higher than your seat count. Second, the exemption covers patron facilities, not staff: food premises requirements for hand washing and staff amenities are separate and come from the food standards and your local council, not from this table. Third, the NCC is adopted with state and territory variations. The New South Wales variation of this table, for example, adds an exemption for patrons of a small live music or arts venue that is not licensed premises. Check your state's adopted version rather than the generic one.
An honest answer, because the code is a minimum and not a design.
It assumes an equal gender split in a venue that may not have one. It counts fixtures, not queues, so a compliant 100-seat venue with three female pans will still have a line at 8pm on a Saturday. It says nothing about accessible sanitary facilities, which come from Part F4 elsewhere and from the Disability (Access to Premises) Standards, and nothing about baby change facilities, which some councils require as a condition of a fit-out approval. And it is silent on the operational cost of the choice: a venue that meets the minimum with a single unisex pan and 50 seats will spend real money on cleaning and on the reputational cost of an out-of-order sign on a Friday.
So treat the table as the floor. If you are already building, the marginal cost of one more pan at fit-out is far less than adding it in two years, and our page on cafe fit-out cost in Australia has the figures for the rest of the build.
Three groups. Anyone in New Zealand, because the NCC does not apply there and the relevant document is the New Zealand Building Code clause G1, with your territorial authority setting the detail; our food control plan page covers the New Zealand compliance path. Anyone designing a licensed venue, because liquor licensing conditions and state variations routinely require more than the NCC minimum. And anyone who has a certifier already engaged, because the Australian Building Codes Board publishes its own adopted text and worked guidance for NCC 2022 Volume One, and a certifier's stamped output beats a table on a website every time.
Use this page to arrive at that conversation knowing the numbers, which is the point. Skai Solutions answers the phone for cafes and restaurants in Australia and New Zealand, and the reason a compliance page sits on a phone company's site is simple: the questions operators ring about are rarely about phones. If you are at the planning stage, our guides on seating capacity per square metre and how many staff a cafe needs use the same floor area you just measured.
How many toilets does a cafe need in Australia?
It depends on design occupancy. Under NCC 2022 Table F4D4d a venue for up to 25 patrons needs one male closet pan, one urinal, one male washbasin, one female closet pan and one female washbasin. At 51 to 100 patrons it is one male pan, two urinals, two male basins, three female pans and two female basins. Facilities are calculated on equal numbers of males and females unless the premises are used predominantly by one sex.
Can you open a cafe with no toilets?
Yes, where the total number of persons accommodated is not more than 20. Table F4D4d says patron facilities need not be provided below that threshold. It is an exemption for patron facilities only: staff hand washing and amenities come from the food standards and your council, not from this table.
How do I work out my cafe's design occupancy?
If the actual number of occupants is not known, clause F4D3 sends you to D2D18, which for a restaurant is one person per square metre of floor area. So a 60 square metre cafe is 60 people. Where fixed tables, booths or alcoves take up much of the floor you may count the seats available to patrons instead, allowing for staff and for layouts that could increase numbers.
Do staff and customers have to have separate toilets in a cafe?
Not under the NCC. In a Class 6 building, which is what a shop or cafe is, employees and the public may share sanitary facilities provided the total number of facilities meets the combined requirement for both groups. Separate staff amenities can still be required by a lease, a licence condition or a council approval.
Why does a cafe need more women's toilets than men's?
Because the table is written that way. Male closet pan requirements start at one for up to 100 patrons, while female closet pans go one for up to 25, two to 50, three to 100 and four to 150. Urinals carry the male load, which is why counting doors on a floor plan misleads people.
Does the NCC toilet table apply in New Zealand?
No. The National Construction Code is Australian. New Zealand sanitary facility provision comes from clause G1 of the New Zealand Building Code with the detail set by your territorial authority, so do not apply Table F4D4d to an Auckland or Christchurch fit-out.