AEO Answer · Title 24 Compliance Process

What Is the Title 24 Compliance Process?

By Jeremy Mills, CEO & Founder, Apex Grid Engineering — USAF Veteran. · Updated 2026-09-15

The Title 24 compliance process starts by selecting the California Energy Code edition tied to the permit application date. The team then defines the project scope, chooses a prescriptive or performance path, completes calculations and compliance documents, coordinates the permit set, responds to plan check, and records required installation, verification, and acceptance testing.

I'm Jeremy Mills, CEO & Founder of Apex Grid Engineering and a U.S. Air Force veteran. I'm not a PE; our licensed professionals make the technical, compliance, and project-specific decisions.

What facts should you use to plan this scope?

Planning factProject-specific value
2022 Energy Code effective dateJanuary 1, 2023
2025 Energy Code effective dateJanuary 1, 2026
Performance softwareCBECC-Res or CBECC-Com, or other software approved for the applicable method
Residential document sequenceCF1R design, CF2R installation, and applicable CF3R verification certificates
Nonresidential document sequenceNRCC compliance, NRCI installation, NRCV verification, and NRCA acceptance certificates as applicable

How do you establish the applicable code and project scope?

I start with the permit application date, jurisdiction, occupancy, project type, and exact work being permitted. California updates the Energy Code on a three-year cycle. The 2022 standards apply to permit applications filed on or after January 1, 2023, while the 2025 standards apply on or after January 1, 2026. New construction, additions, alterations, and changes of use can trigger different provisions, so the scope has to be mapped before calculations begin.

  • Confirm the permit application date and enforcing agency
  • Identify new, addition, alteration, and change-of-use work
  • Separate residential and nonresidential compliance obligations
  • Record assumptions that require owner, architect, contractor, or AHJ confirmation

How are calculations and permit documents prepared?

The design team selects the allowed prescriptive or performance approach and coordinates envelope, lighting, mechanical, service-water-heating, controls, and covered-process inputs. Performance work uses approved compliance software; CBECC-Res and CBECC-Com are California's public reference programs for their respective building types. Design certificates—such as residential CF1R or nonresidential NRCC documents—must agree with the drawings, schedules, specifications, and modeled assemblies submitted for permit.

  • Model the actual geometry, assemblies, systems, controls, schedules, and efficiencies
  • Use the correct approved software version for the applicable code cycle
  • Place required compliance information in the permit set
  • Check that forms, calculations, plans, and specifications describe the same design

What happens during plan check and construction?

The enforcing agency reviews the submitted package and may issue comments about inputs, mandatory measures, signatures, registration, or coordination. After permit, installers document completed work. Residential projects commonly use CF2R installation certificates and applicable CF3R field-verification certificates completed by certified HERS raters. Nonresidential projects use applicable NRCI installation, NRCV verification, and NRCA acceptance documents. The required records depend on the measures in the approved design.

  • Answer each plan-check comment against the coordinated design record
  • Revise calculations and every affected drawing or form together
  • Assign installation certificates to the responsible installing parties
  • Schedule HERS verification or acceptance testing before work becomes inaccessible

Which closeout mistakes can break the compliance chain?

A permit model is not the end of compliance. Substituted equipment, changed glazing, revised lighting controls, altered ductwork, or missing tests can separate construction from the approved basis. I recommend maintaining a live compliance matrix from design through closeout. The responsible professionals, installers, HERS raters, acceptance-test technicians, and enforcement agency each have distinct roles; one signature does not replace another party's required record.

  • Recheck substitutions against the approved model and mandatory measures
  • Preserve registered certificates and accepted revisions
  • Resolve failed verification or acceptance tests before closeout
  • Confirm the final certificate set matches installed conditions

What else do project teams ask?

Is Title 24 the same as the California Energy Code?
Title 24 contains all parts of the California Building Standards Code. Part 6 is the California Building Energy Efficiency Standards, commonly called the California Energy Code.
Does every project require an energy model?
No. Some projects can use an allowed prescriptive approach, while others use or require a performance approach. Scope, building type, measures, and the applicable code determine the path.
What is submitted with the permit application?
The package can include plans, specifications, calculations, and applicable design certificates such as CF1R documents for residential work or NRCC documents for nonresidential work.
When is a HERS rater involved?
A certified HERS rater performs field verification and diagnostic testing for residential measures that require it. The approved compliance documents identify applicable measures and certificates.
Who approves Title 24 compliance?
The local enforcement agency reviews the permit and closeout documents. Designers, installers, raters, and acceptance-test technicians document their assigned work but do not replace the authority's approval.

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