Title 24 Accessibility vs the Energy Code: Which Do You Mean?
They are different codes with the same nickname. A Title 24 report is the Energy Code, Part 6. The accessibility rules people search for as “Title 24 ADA” are in the California Building Code, Part 2, in Chapters 11A and 11B. The energy report does not cover them, and your local building department decides how they apply to your project.
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Where accessibility rules live
The Building Standards Commission describes two chapters. Chapter 11A is developed by the Department of Housing and Community Development for accessibility in multifamily dwellings. Chapter 11B is developed by the Division of the State Architect for public buildings, public accommodations, commercial buildings and public housing, and its model is the 2010 federal ADA Standards for Accessible Design, with California amendments.
Which chapter fits which building
- Apartment buildings of three or more dwelling units, condominiums of four or more, lodging houses and dormitories are covered multifamily dwellings under Chapter 11A.
- Shops, offices, restaurants, hotels and motels are places of public accommodation or commercial facilities under Chapter 11B.
- The Commission’s guide says one- and two-family dwellings are not subject to these accessibility requirements unless they are public housing. Your department confirms how that applies to a lot.
Restroom signs
Searches for Title 24 restroom signs are about Chapter 11B, which has a Signs section (11B-216) with its own rules for toilet rooms and bathing rooms (11B-216.8). The Energy Code does regulate signs, but only their lighting: Section 130.3 requires time-switch or photocontrol of sign lighting in nonresidential buildings.
Title 24 and the ADA
The Division of the State Architect says California’s accessibility regulations date from eight years before the federal ADA, and that the state code was written to meet the most stringent of the original state code, the 1991 Fair Housing Amendments Act and the ADA guidelines. DSA also notes that state and local officials cannot enforce the ADA for the federal government. An ADU is not an ADA matter, whatever the acronyms suggest; do ADUs need Title 24 covers its energy side.
Who answers an accessibility question
Only the local building authority can make a final determination on enforcement, and DSA says it cannot settle a dispute with a local inspector. DSA publishes an Access Compliance Advisory Reference Manual with commentary on Chapter 11B. For the energy side, who enforces Title 24 and Title 24 requirements are the places to look, and the parts of Title 24 shows where each code sits.
Common Title 24 Questions
- What is Title 24?
- Do I need a Title 24 report?
- How much does a Title 24 report cost?
- How long does a Title 24 report take?
- What is included in a Title 24 report?
- What plans do I need to upload?
Frequently Asked Questions
No. The energy report is the Part 6 certificate of compliance. Accessibility is Chapters 11A and 11B of the Building Code, checked by the building department separately.
No. Title 24 is state building code enforced by building officials. The ADA is federal law, and DSA notes state and local officials do not enforce it for the federal government.
The local building authority makes the final determination on enforcement. DSA publishes commentary but says it cannot settle a dispute with a local inspector.
Explore What Is Title 24?
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View all What Is Title 24? guides → · Title 24 Guide · Title 24 guide