An EDC report is a small document with a long reach. The estimated development cost it certifies decides which approval pathway a development application follows, what assessment fees are payable and which lodgement requirements apply. Get it wrong in one direction and the applicant pays fees on a number that was never real. Get it wrong in the other and council’s own quantity surveyor picks it up, a request for information follows, and the application sits still while the report is redone. This guide covers what a compliant EDC report has to contain, the mistakes councils most often reject, and how to avoid them before the application is lodged.
What an EDC report is and who has to prepare it
Estimated development cost replaced the two earlier NSW cost measures, capital investment value and the genuine estimate of construction costs, with a single definition. According to the NSW Department of Planning, Housing and Infrastructure’s planning circular PS 25-004, the regulatory changes commenced on 4 March 2024. The department’s EDC guidance sets out what the figure covers and who can prepare it.
The preparer requirement scales with the size of the project. Below $3 million*, the estimate can be prepared by the applicant or a suitably qualified person, and individual councils set their own detail requirements. Above $3 million*, the report should be prepared by a quantity surveyor who is a member of the Australian Institute of Quantity Surveyors (AIQS) or the Royal Institution of Chartered Surveyors (RICS), following the AIQS practice standard for EDC construction cost assessments and using the department’s standard form. For State significant development and infrastructure above that threshold the bar is higher again: the quantity surveyor must be AIQS certified or RICS chartered, and the report must be dated within 30 days of submission.
*Thresholds reflect NSW Planning guidance current at the time of writing and should be checked against the department’s published requirements before lodgement.
What goes in and what stays out
Most rejected EDC reports fail on scope rather than arithmetic. The department is specific about what the figure captures and what it excludes, and a report that blurs the line in either direction invites a query.
| Included in EDC | Excluded from EDC |
| Design and erection of a building and its associated infrastructure | Land costs, including marketing and selling the land |
| Carrying out a work | GST (shown separately, not in the EDC figure) |
| Demolition of a building or work | Developer contributions and planning agreement costs |
| Fixed or mobile plant and equipment | Any part of the development that needs a separate approval |
| Ongoing maintenance and use of the completed development |
Source: NSW Department of Planning, Housing and Infrastructure, estimated development cost guidance. Always confirm inclusions and exclusions against the current guidance for the specific application.
The pitfalls councils reject most often
Reusing a figure prepared for a different purpose
A development usually carries several cost figures at once: a feasibility budget, a lender’s cost-to-complete, a builder’s tender, a Section 7.12 cost assessment and the EDC. Each has its own inclusions, exclusions and date. The most common shortcut is to lift the contract sum or the feasibility number into the DA form and call it the EDC. A contract sum can exclude demolition, external works, or authority fees the developer is carrying directly, and it usually excludes design. A feasibility budget often includes land, finance, marketing and contributions, all of which the EDC excludes. Either way the number is wrong, and council’s assessing officer or reviewing quantity surveyor will usually see the mismatch against the drawings.
Understating the cost to reduce fees
Assessment fees are calculated from the EDC, so there is an obvious temptation to keep the figure lean. Councils know this. Many engage their own quantity surveyors to benchmark submitted costs against comparable projects, and an EDC that sits well under market rates for the building type and floor area will be challenged. The consequences are not limited to a corrected fee. An understated EDC can put the application on the wrong pathway, so that a project which should have been assessed as regionally significant is lodged with council and has to be re-lodged. The delay costs far more than the fee saving ever could.
Overstating it by leaving excluded costs in
The opposite error is just as common and less often noticed, because nobody at council is motivated to reduce a fee. Reports that include GST in the headline figure, carry land or acquisition costs, or fold in contributions and planning agreement payments overstate the EDC. The applicant pays fees on money that does not belong in the calculation, and the inflated figure can push a smaller project across the $3 million threshold into a report standard it did not need to meet.
Missing scope the drawings clearly show
The EDC has to cover the full scope of works in the application, including staging. Reports regularly omit demolition of existing structures, site preparation and remediation, external works, landscaping, civil and stormwater works, retaining structures, and fixed plant such as lifts, mechanical plant or kitchen equipment. Where a project is staged, every stage covered by the consent belongs in the figure. Council’s reviewer works from the same drawings the applicant lodged, so anything drawn but not costed is easy to find.
The report does not match the drawings lodged
A cost report prepared on an earlier design revision is one of the fastest ways to draw a request for information. Floor areas change, basements grow or shrink, a level is added, and the EDC report still describes the scheme from three months ago. The standard form requires the report to list the documents relied upon, with their dates and revisions. If that list does not match the drawings in the DA package, the report is not certifying the development being applied for.
Not using the standard form, or leaving parts of it blank
For projects above $3 million the department expects the standard form: an executive summary stating the EDC, a description of the basis of preparation, a statement of the scope of the calculation and a detailed calculation schedule. The form also requires the preparer’s qualifications, a statement of any matters that might impair the objectivity of the calculation, and a certification that the calculation is accurate and covers the full scope of works at the date of submission. Reports that arrive as a one-page letter with a total, or that skip the certification, are routinely sent back.
Showing one total instead of two
The EDC excludes GST, but the department asks for the GST incurred and the sum of EDC plus GST to be shown as separate line items alongside it, because different fees are calculated on different bases. A report that shows a single figure, or that does not say whether GST is in or out, forces the assessing officer to ask.
No basis, assumptions or provisions
The detailed calculation schedule is meant to show, for each component, the cost, the quantities and rates behind it, the assumptions about site conditions and market, and the provisions carried for contingency and escalation. A schedule that lists trade totals with nothing behind them cannot be reviewed, and a council quantity surveyor who cannot review a figure will usually ask for it to be redone rather than accept it on trust.
Confusing the EDC with the Section 7.12 levy base
This one causes problems in both directions. The department’s guidance is clear that EDC does not affect development levies. Section 7.12 contributions are calculated on the proposed cost of carrying out the development under the relevant council contributions plan, which has its own inclusions and exclusions. An applicant who submits the EDC as the levy base, or who uses a Section 7.12 cost assessment as the EDC, has answered the wrong question. The two figures often sit close together, but they are not interchangeable, and councils assess them separately. A quantity surveyor can prepare a Section 94 / DA cost report for the contribution alongside the EDC report so that each figure is built for its own purpose.
Not updating the report after the application changes
Amendments during assessment, and modification applications after consent, change the scope and usually the cost. Where the change is material the EDC should be revisited, and for a modification application councils will normally expect a revised or confirmed figure. Submitting an amended scheme with the original report attached is a common and avoidable cause of delay.
What happens when a report is rejected
A rejected or questioned EDC report rarely ends the application. What it does is stop the clock. Council issues a request for information, the applicant’s consultant revises the report, and the application waits. Where council has engaged its own quantity surveyor to review the figure, the cost of that review may be passed to the applicant. Where the correction changes the assessment pathway, the application may need to be withdrawn and re-lodged. Each of those outcomes costs weeks, and in a staged project or one with finance conditions tied to consent dates, weeks are expensive.
How to lodge an EDC report that holds
The reliable approach is unglamorous. Prepare the report from the current DA drawings and record the revisions used. Measure the full scope shown, including demolition, site works, external works and fixed plant, and state the staging. Apply the department’s inclusions and exclusions and nothing else. Show the EDC, the GST and the total including GST as three separate lines. Use the standard form, complete every section, and have the report prepared and certified by a quantity surveyor who meets the requirement for the project size. Then check the date: for State significant projects the report must be no more than 30 days old at submission, and for every project a stale report is a weak one.
Section 94 prepares developer cost reports for development applications across NSW, including EDC reports in the department’s standard form, prepared by AIQS-accredited quantity surveyors and cross-checked against benchmarked projects of the same type. The aim is a figure council can accept the first time, so the application keeps moving.
Talk to Section 94 about an EDC report for your next NSW development application.
Frequently asked questions
What is an EDC report?
An EDC report certifies the estimated development cost of a proposed development for a NSW development application. Councils and the department use the figure to determine the approval pathway, calculate assessment fees and apply lodgement requirements. For projects above $3 million* it should be prepared by an AIQS or RICS quantity surveyor in the department’s standard form.
Who can prepare an EDC report in NSW?
Below $3 million*, the applicant or a suitably qualified person. Above $3 million*, a quantity surveyor who is a member of AIQS or RICS, following the AIQS practice standard. For State significant development and infrastructure above that threshold, the quantity surveyor must be AIQS certified or RICS chartered and the report must be dated within 30 days of submission.
Does the EDC include GST?
No. The EDC figure excludes GST, but the department asks for the GST incurred and the sum of EDC plus GST to be shown as separate line items in the report, because some fees are calculated on the GST-inclusive amount.
Is the EDC the same as the Section 7.12 levy amount?
No. The department states that EDC does not affect development levies. Section 7.12 contributions are calculated on the proposed cost of carrying out the development under the relevant council contributions plan, which has its own rules. The two figures are prepared separately and should not be substituted for each other.
Why did council reject my EDC report?
The usual reasons are scope that does not match the lodged drawings, excluded items left in or included items left out, a figure that sits well below market benchmarks for the building type, a report not in the standard form or missing its certification, a single total with no GST split, or a report dated on an earlier design revision. Most are fixed by having the report re-prepared from the current documents by a qualified quantity surveyor.