Submitted 1 July 2026
This submission from the Real Estate Institute of New South Wales (REINSW) provides feedback on the NSW Government’s Emergency Services Funding Reform Options Paper (Options Paper).
It sets out REINSW’s concerns with the proposed approaches to replacing the Emergency Services Levy (ESL), particularly where reform would place additional financial pressure on property owners.
REINSW’s submission calls for any replacement funding models to be carefully assessed based on fairness, reliability and broader impacts on the property sector. REINSW’s submission raises significant concerns about the reform options presented in the Options Paper, all of which are based on a high-level framework of increasing fixed charges by reference to land values. REINSW cannot support any of the proposed replacement levy options at this stage, particularly given the existing and growing burden of taxation, levies and statutory charges already carried by the property sector. REINSW has recommended that Government consider alternative funding models targeting sectors that financially benefit from well-funded emergency services or whose activities contribute to higher emergency risks and costs.
REINSW’s submission also highlights concerns about the potential impact of the proposed reforms on housing and insurance affordability. REINSW is concerned that shifting the levy onto property may make owning, buying and renting housing more expensive, despite the stated objective of easing cost-of-living pressures. The submission questions Government’s assumption that removing the ESL from insurance premiums will necessarily result in lower premiums for consumers or increased insurance uptake, noting that insurers are not required to pass on any savings to consumers. If premiums are not reduced, the cost of funding emergency services may simply be shifted from insurance premiums to property owners and, ultimately, buyers and renters.
The submission also raises concerns about the modelling and data relied upon in the Options Paper. While the Options Paper suggests that most insured residential property owners will pay less under the proposed options, REINSW has noted that this does not tell the full story. The conclusions drawn in the Options Paper rely on speculative data models that lack evidence and outdated land values, while also understating increased costs for properties in metropolitan areas, uninsured property owners and unit owners. REINSW has recommended that Government conduct further research on rental affordability impacts before preferencing or proposing any levy reform option.
REINSW’s submission further challenges the assumption that land value is an appropriate measure of capacity to pay. Land value does not account for cash flow, rental income, vacancies, maintenance costs or personal financial circumstances. This is particularly relevant for owners by inheritance, retirees who rely on investment properties for retirement income, and commercial or industrial property owners.
On an implementation level, REINSW’s position is that further research should be undertaken before any replacement option is settled. If Government proceeds with one of the proposed fixed land value options, which is not recommended, REINSW has proposed a phased transition period over three years to avoid penalising owners who have recently renewed insurance and paid ESL. REINSW has also noted that timing and communication will be critical for property managers and strata managers, who will need to respond to owner questions and manage expectations following the implementation of any replacement levy.
Overall, REINSW’s submission aims to ensure that any reform to emergency services funding is not directed at the property sector and is fair, evidence-based and reflective of the practical impacts on property owners, buyers, renters and real estate businesses.
REINSW remains committed to representing its members and ensuring the real estate industry has a strong voice in the development of policy and reforms.