5 Things Developers Get Wrong About Koala Habitat Assessments in Queensland

Your assessment may be using an outdated tree definition

SDAP version 3.3 quietly expanded the definition of a “koala habitat tree” to include the genus Blakella alongside Corymbia, Eucalyptus, Lophostemon, and Melaleuca. If your ecological assessment was prepared under an earlier SDAP version, trees on your site that were previously excluded may now count as koala habitat trees.

SDAP v3.6, released in April 2026, is the current version. If your assessment references an older version, it may not satisfy the current performance outcomes, and council or the state assessor can request an update. Before lodging a development application, check that your ecologist has assessed against the current SDAP version.

You are only doing the state assessment and missing the federal one

This is the most expensive mistake we see. Developers engage an ecologist for a State Code 25 koala habitat assessment, get their state approval, and then discover the project also triggers a referral under the Commonwealth EPBC Act.

The koala was upgraded to endangered under the EPBC Act in February 2022. The Commonwealth referral guidelines indicate that clearing as little as one hectare of habitat for the koala can constitute a significant impact requiring federal assessment. That is a much lower threshold than many developers expect.

A State Code 25 assessment and an EPBC Act referral are separate processes with different criteria. You can pass one and fail the other. Taking an action that has a significant impact on a matter of national environmental significance without approval is an offence under the EPBC Act. Getting this wrong is not just a planning risk - it is a legal one.

You are stacking clearing exemptions - and that may be about to end

Under the current framework, some developers combine multiple clearing exemptions to achieve a larger clearing footprint than any single exemption would allow. For example, using a dwelling house exemption alongside an infrastructure exemption on the same lot.

The Queensland Government has proposed changes as part of the SEQ Koala Conservation Strategy 2026-2036 review that would restrict the stacking of clearing exemptions. Each exemption would need to be independently justified and could not be combined with others on the same lot.

Other proposed changes include:

• A new 800 square metre clearing exemption for lots greater than one hectare (replacing the current one-size approach)
• Child lots created through reconfiguration will not receive additional habitat clearing rights
• Fire management exemptions will only apply to clearing around existing infrastructure, not proposed buildings
• Consequential clearing for fences, driveways, and access roads must be included in the assessable development application

These changes are not yet in effect - the strategy consultation closed in March 2026 and the final regulations are expected later this year. But if your project timeline extends into late 2026 or 2027, you should factor in the possibility that the rules will be tighter when you lodge.

You do not know what “koala safe movement” means - and neither does anyone else

State Code 25 includes a performance outcome requiring that development supports safe koala movement and does not fragment koala habitat. Developers must demonstrate compliance with this outcome. The problem is that “koala safe movement” has no formal regulatory definition.

In practice, this means the interpretation is left to the assessing ecologist, the state assessor, and sometimes the council. What counts as adequate fauna-friendly fencing, sufficient canopy connectivity, or an acceptable wildlife crossing varies between assessments and between assessors.

A new definition for “koala safe movement” has been proposed as part of the regulatory amendments, but the technical definition has not been publicly released. Until it is, the safest approach is to document your design rationale clearly and demonstrate how each element of your development layout supports koala movement through the site and to adjacent habitat.

You think a fine is cheaper than doing it properly

In a recent enforcement case, a developer near Toowoomba was fined $14,375 for illegally clearing more than 4,000 square metres of mapped koala habitat without approvals. Environmental groups described the penalty as a “slap on the wrist” that sends a dangerous message.

The fine may seem low relative to the value of the land, but the real costs of non-compliance go beyond the penalty notice:

• Remediation orders requiring revegetation and ongoing monitoring at your expense
• Stop-work orders that delay your entire project timeline
• Reputational damage with councils, assessors, and future approvals
• EPBC Act penalties at the federal level, which carry significantly higher fines for individuals and corporations
• Offset obligations that can be triggered retroactively for unauthorised clearing

The cost of a proper koala habitat assessment is a fraction of any of these outcomes. For most development sites in SEQ, a koala habitat assessment takes two to three weeks from field survey to final report and gives you certainty about what you can and cannot do before you commit to a design.