Do I need a Title 24 report to sell a flipped house?

No. A sale does not trigger the Energy Code; the permits for the renovation do. The certificates from those permits should be left in the house at final for the owner, which on a flip means the buyer.

Does replacing a furnace like for like need Title 24?

Yes. Replacing a regulated component is an alteration, not a repair. Replacing the air handler, outdoor unit or coil brings duct sealing with ECC verification, unless an exception applies, such as a duct system under 40 feet.

Can a ductless heat pump avoid ECC testing?

It removes the duct tests, not all of them. In a house or duplex, air-source heat pumps, minisplits included, need refrigerant charge verification in every climate zone, done or confirmed by an ECC-Rater.

What if the previous owner did unpermitted work?

Legalising it is a new permit application, assessed under the current code. A room or garage conditioned without a permit is treated as an addition. See the page on unpermitted work.

Title 24 for House Flippers and Investors

Selling a house does not trigger Title 24, but most of the work that adds value to a flip does: replacement windows, HVAC, water heaters, roofing, lighting and added living space each bring in the Energy Code through the permit, and any ECC tests must pass before the final inspection that closes it.

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An investor meets Title 24 as a matter of scope and schedule rather than design. The Energy Code rides on the building permit, not the sale, so a house can change hands with no energy paperwork at all (see selling a house). The renovation is another story. Below: scopes that pull the code in, scopes that do not, and the closing-out problem.

The permit triggers it; skipping the permit does not escape it

Under § 100.0(a)2, Part 6 covers buildings for which a permit application is filed, or is required by law to be filed, on or after the code's effective date. Unpermitted work is still held to the code, and legalising it later counts as a new application, assessed under whichever edition is current (2025 standards since 1 January 2026). It cuts both ways. Only work inside the permit is regulated, and untouched parts of a house need not be upgraded because its kitchen was redone.

Scope by scope

For a house or duplex, § 150.2(b) governs alterations, and what matters is which component changes, not the budget.

Windows (§ 150.2(b)1B): replacements meet U-factor and SHGC limits, with a relaxed limit for up to 75 square feet. Reglazing an existing sash and frame, at equal or better performance, is a repair. Even window film is listed as an alteration. See windows.
HVAC (§ 150.2(b)1E–G): swapping an air handler, condenser or coil means ECC-verified duct sealing unless the ducts run under 40 feet, were verified before, or contain asbestos. Touching the refrigerant circuit (§ 150.2(b)1F) brings a setback thermostat, plus charge and airflow verification: heat pumps statewide, air conditioners in zones 2 and 8 to 15. Electric resistance cannot become the main heat source unless it already was and an exception fits. See HVAC changeouts.
Ducts (§ 150.2(b)1D): over 25 feet of new or replacement duct is sealed and tested; in a garage, altered ducts or equipment need a 6 percent leakage limit or a smoke test at any length.
Water heaters (§ 150.2(b)1H): gas or propane remains a prescriptive option in an existing house, as does a heat pump unit meeting set conditions, and an electric resistance heater may give way to a consumer electric one. Accessible hot water pipes get insulated. See water heaters.
Roofs (§ 150.2(b)1I): replacing over half the surface brings cool-roof values for steep roofs in zones 4 and 8 to 15, with equivalent options, and R-14 continuous insulation, or an equivalent U-factor, for low-sloped roofs in zones 1, 2, 4 and 8 to 16, subject to exceptions. See re-roofing.
Lighting (§ 150.2(b)1K): altered fixtures meet the residential lighting rules; screw-base recessed cans may stay with JA8-compliant trims or lamps. See replacing light fixtures.
Extra square footage (§ 150.2(a)): a garage conversion, an enclosed and conditioned patio, or a legalised unpermitted room is an addition, with no solar requirement (Exception 6). A loft inside existing conditioned volume is an alteration.

What stays outside the code

Repairs do. Section 100.1 defines them as reconstruction or renewal for maintenance that does not raise the repaired item's energy use. Paint, flooring, cabinets and countertops touch no regulated system either. The catch is replacement: swapping a regulated component, even like for like, is an alteration, so a dead furnace or water heater is replaced under the code.

Small jobs get some leeway. Where an alteration needs no field verification, water heaters and windows included, § 10-103(a)1C lets a department skip the certificate of compliance or accept a simplified one, while stating that this waives paperwork, not requirements. When a report is needed covers the usual cases.

When a gut rehab becomes new construction

Strip a house to its frame and the department may call it a newly constructed building: the CEC manual's example is a project removing all wallboard, insulation and exterior walls (SFCM p. 2-11). If your department agrees, new-home rules under § 150.1 apply, heat pump baseline and PV included. Settle the classification before demolition starts.

Closing the permit before you list

Final inspection closes the permit, and for a house or duplex § 10-103(d)2 says it is not complete until the department has verified that installed work matches approved plans and complies with Part 6. Book the ECC-Rater, and room for a retest, well ahead of the listing date. A permit allowed to expire before work starts also resets the code edition. The Title 24 timeline lays out the sequence.

Two details help. On an HVAC changeout without required plans, § 10-103(a)2A lets the certificate be approved before final rather than before the permit. And under § 10-103(b)1A the builder leaves completed certificates in the house for its owner at occupancy, so on a flip that paperwork passes to your buyer.

Unknown walls, multiple houses

Few older houses come with drawings. The performance approach can model existing house and alterations together, letting a component that falls short be offset by one that does better, with routes that do or do not use third-party verification of existing conditions. Investors renovating several houses can ask their HVAC contractor about sampling: up to seven homes may form one group, the ECC-Rater tests one, and a pass covers the group. For a single project, remodel rules gives the short version.