What Happens If You Have No Title 24 Report?
For work the Energy Code covers, the permit waits: the building department may not issue it until it has determined in writing that the design complies, and the certificate of compliance has to be approved first. For a few small residential jobs, the department may waive or simplify the paperwork.
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At plan check
Section 10-103(a)2 requires each permit application subject to Part 6 to contain at least one copy of the compliance documents. For newly constructed buildings, additions, alterations and repairs the code regulates, the applicable certificate of compliance is submitted and must be approved by the department, by stamp or authorised signature, before the permit is issued.
Section 10-103(d)1 then bars the department from issuing a building permit unless it determines in writing that the construction is designed to comply with the Part 6 requirements in force on the date of application, and that determination confirms the documentation requirements were met. Where the CF1R has to be registered, the CEC's manual adds that only a registered copy, showing its registration number, is acceptable at plan check. A submittal without them comes back.
Small jobs where the department may waive it
Section 10-103(a)1C gives departments discretion for two kinds of residential work that need no field verification: alterations such as water heater and window replacements, and additions under 300 square feet. For those, the department may require no certificate of compliance at all, or develop simplified documentation of its own.
The same paragraph is careful to add that waiving the paperwork does not authorise work that breaks the code. The new windows still have to meet the U-factor and SHGC limits, and the new water heater still has to be a type the code allows. Ask the department before assuming your job is one of these.
When the report can come later
One case moves the deadline rather than removing it. For alterations to existing homes that need field verification, where the department does not require plans with the application, the certificate does not have to be approved before the permit is issued. It must be approved before final inspection, and be available at every inspection or on an approved data registry. A heat pump change-out where no plans are required can fall into this category. The report can follow the permit; it cannot be skipped.
At inspection and final
The paperwork continues after the permit. Installers sign certificates of installation, and where testing applies an ECC-Rater (called a HERS rater until 1 January 2026) registers certificates of verification. Under Section 10-103(d)2 the department inspects to confirm the work matches the approved plans and complies, and checks that the required certificates are posted or available. A final certificate of occupancy is not issued until that is verified, and for a house, Occupancy Group R-3, final inspection is not complete until then. The sequence is set out in what happens after the report.
Work already built without one
Work done without a permit, and so without energy documents, is usually dealt with when it comes to light: through a new permit, assessed under the code in force at that time. That route is covered in unpermitted work and as-built permits.
For whether your project needs a report in the first place, see do I need a Title 24 report and Title 24 exemptions. For how enforcement works more broadly, see who enforces Title 24.
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
Usually not; the certificate is approved before the permit is issued. The exception is a residential alteration that needs field verification where no plans are required: then it must be approved before final inspection.
For residential alterations that need no field verification, such as many window and water heater replacements, and additions under 300 square feet, it may waive or simplify the documents. The work must still comply.
The job does not final. The department has to verify that the required installation and verification certificates are posted or available before signing off.
