Are email proxy appointments valid for strata meetings under the Strata Titles Act 1985?

Committee & Governance

Can a lot owner email another owner telling them to be their proxy at a meeting without filling out a proxy form and signing it? Is this a valid proxy? What are the legal requirements for a proxy to be valid at a strata company meeting?

Without completing a proxy form with a signature, there is no valid proxy.

Section 124 of the Strata Titles Act 1985 states that an instrument appointing a proxy to cast a vote must be in writing and executed by the appointer or the appointer’s attorney.

In my opinion, “in writing” means in a printed, written or typed document.

Therefore, I would suggest that an email from an owner telling another owner to be their proxy at a meeting without completing a proxy form with their signature on it is not a valid proxy.

We suggest that legal advice be obtained.

Please further note that a proxy has no effect if the person who gave the proxy attends the meeting and votes in person.

Comments

Published: 24 Apr 2026

Last Updated: 7 Jul 2026

After a free PDF of this Q&A?

Not a member? Join for free

Answer by

Marietta Metzger

magixstrata

Marietta Metzger is the Principal and founder of magixstrata, a boutique strata management firm based in Perth, WA. With over two decades of experience, she established the company in 2003 and incorporated it in 2005.

Marietta holds extensive qualifications including a Specialist Diploma in Property and Strata Company Management, Certificate IV in Strata Community Management, and multiple certificates in strata and risk management. Her SCA (WA) accreditations span from Accredited Strata Community Manager (2005) through to Honorary Fellow Strata Community Manager (HFSCM), awarded in 2025.

A prominent industry figure, Marietta served on the SCA (WA) Board for 12 years and as a Director of Strata Community Association Ltd from 2018 to 2020. She has also convened the SCA (WA) Best Practice Committee, led its Professional Development Committee for over a decade, and chaired the SCA Professional Standards and Membership Advisory Group.

magixstrata manages a diverse portfolio ranging from small residential complexes to large mixed-use developments, with a focus on integrity and attention to detail.