Which Energy Code Applies? 2022 vs 2025 by Application Date

01The short answer: the permit application date controls

The 2025 Building Energy Efficiency Standards, California Title 24, Part 6, became effective statewide on January 1, 2026. Building permit applications submitted on or after January 1, 2026 must comply with the 2025 Energy Code. At this transition, applications received on or before December 31, 2025 remain under the 2022 Energy Code. Use the application date recorded by the authority having jurisdiction (AHJ), not the construction start, permit issuance or drawing date.

The California Energy Commission’s 2025 page states the on-or-after rule directly. California Building Standards Commission Information Bulletin 25-01, dated July 1, 2025, explains the application rule under Health & Safety Code Section 18938.5 and the continued applicability of the 2022 code to earlier applications. Keep that statewide rule separate from your building department’s procedure for establishing an application date.

This guide addresses the 2022-to-2025 transition. The 2022 edition took effect January 1, 2023. A much older active permit may belong to an earlier edition; do not force every pre-2026 permit into 2022. The edition name remains 2025 even though statewide implementation began in 2026. Title 24 includes multiple parts: Part 6 is energy; CALGreen is Part 11 and is separate.

CEC: 2025 Energy Code and application-date rule CBSC Bulletin 25-01: effective date and application

02Five-stage decision checklist before ordering a report

Assign one person on the project team to resolve the edition question and retain the evidence. The owner can collect the permit record, the architect can describe the scope, and the energy preparer can identify matching software and documents. The AHJ confirms the recorded application date and how it applies to the actual permit. Do not ask the model to settle an unresolved administrative question.

+Stage 1 — Get the AHJ-recorded building permit application date. Save the application/permit identifier, receipt or portal record and any written confirmation. If an upload, appointment, payment or completeness review has a different date, ask which date the department recognizes; there is no universal rule here that any one of those events automatically controls.
+Stage 2 — Map the confirmed date to the edition. For this transition, a 2022-cycle application received on or before December 31, 2025 stays on 2022; one on or after January 1, 2026 uses 2025. Flag expiration, withdrawal, a new application or uncertain permit history for AHJ review instead of guessing.
+Stage 3 — Select matching software and forms. Use 2022-approved compliance software and 2022 documents for the 2022 application, or 2025-approved software and 2025 documents for the 2025 application. Confirm the building classification and scope as well: residential and nonresidential form families are not interchangeable.
+Stage 4 — Confirm field-verification labels and handoffs. Current 2025-cycle residential guidance uses ECC, Energy Code Compliance. Older software, reports and searches may say HERS. Preserve the applicable edition and ask the provider/rater about the actual registry process; a naming change is not permission to replace older forms arbitrarily.
+Stage 5 — Check local amendments or reach codes. Ask the city or other actual reviewing authority what adopted requirements apply to this project, scope and application date. Local requirements can be stricter than the statewide minimum. A county address or a nearby project’s report does not establish the applicable local provisions.

Start with the CEC’s edition-specific standards hub

03Worked example A: a December 2025 application

Illustrative scenario, not a real client or a local permitting determination: an architect completes a residential design, and the AHJ records its building permit application on December 18, 2025. Plan review continues in 2026 and the permit is issued later that year. The application belongs to the 2022 cycle; crossing January 1 during review or beginning construction in 2026 does not by itself change the governing edition.

The team retains the application confirmation, prepares the applicable 2022 CF1R using 2022-approved software and keeps the drawing revision aligned with that report. If older documents describe HERS verification, the team does not simply relabel every certificate as 2025 ECC documentation. It confirms the current provider process for that older-code project.

If a reviewer later requests corrections, identify whether they correct the same active application or involve a different administrative action. Obtain the AHJ’s direction before rebuilding the model under a newer cycle. This example assumes the original application remains valid; it is not a promise that every December upload secures a 2022 review.

CEC: 2022 Energy Code resources Coordinate corrections without assuming a new edition

04Worked example B: a January 2026 application

Illustrative scenario: drawings are dated December 2025, but the AHJ records the building permit application on January 12, 2026. The project uses the 2025 Energy Code. The old drawing date, an earlier consultant proposal or an earlier preliminary model does not establish a 2022 application. The team should confirm the edition before finalizing assemblies, equipment selections and compliance output.

For applicable single-family work, the preparer uses 2025-approved software and the appropriate 2025 CF1R. Where residential verification measures require it, coordinate ECC responsibilities and the applicable registration process. Report preparation does not itself perform the installer’s CF2R or the ECC-Rater’s CF3R work. For nonresidential work, choose the applicable 2025 NRCC pathway instead of substituting residential forms.

A preliminary 2022 study may still explain the design’s history, but it is not the final 2025 permit package. Confirm inputs, rerun the selected design under the matching rules and coordinate the resulting measures with drawings. Do not change only the report heading or assume an older compliance margin survives unchanged.

CF1R preparation and CF2R/CF3R handoffs New-construction design-to-permit workflow

05What does not decide the edition

Construction start is not the controlling date for this statewide transition. A project can start work after January 1, 2026 under a valid earlier application. Conversely, scheduling a contractor or starting design before that date does not establish an earlier building permit application.

Permit issuance is also different from application. Review, corrections and issuance may occur in a later calendar year. Retain both dates in the project record, but do not use the issuance date as a shortcut for choosing the Energy Code.

Drawing dates and energy-report dates show document history, not the AHJ’s application record. A December cover sheet, a consultant’s invoice or a file named “2022 report” cannot prove which edition governs. Nor does the date of a correction letter automatically reset the edition. If the permit history is unclear, ask the department to identify the application and applicable cycle in writing.

06The software, model and document family must agree

Once the application’s edition is confirmed, use the corresponding CEC-approved software version and edition-specific compliance documents. For a 2022 application, select the approved 2022 implementation; for a 2025 application, select the approved 2025 implementation. Keep the software/version information with the report. Updating a software installation does not, by itself, authorize changing an existing permit’s code basis.

The same edition decision carries into applicable CF1R or NRCC documentation. The correct family also depends on building classification and affected scope. Do not assume all multifamily buildings use the single-family CF1R/CF2R/CF3R sequence, or that a commercial tenant improvement uses residential forms.

Separate a preliminary comparison from final compliance output. If the application timing changes, ask what needs to be remodeled, rechecked or reissued; do not promise that the same inputs will produce the same result across editions. Keep assumptions, selected specifications, signatures and required registration coordinated with one controlling plan revision.

Energy modeling: preliminary studies versus final permit output CF1R vs CF2R vs CF3R: who does what

07ECC and legacy HERS: keep the edition visible

Use ECC (Energy Code Compliance) for current 2025-cycle residential field-verification guidance. The CEC explains that the field-verification program continues under ECC and that 2025-based tools and forms replace HERS terminology as appropriate. HERS remains a useful legacy search term and appears on older-cycle documents; separate whole-house ratings are another context.

Do not tell an owner that HERS documentation for an already-permitted 2022 project has simply been abolished. The CEC discusses older-code projects within the ECC program, so confirm both the original compliance edition and the current provider/rater procedures. Preserve the document lineage rather than creating a hybrid packet of old inputs, new labels and mismatched forms.

CEC ECC program and older-project transition questions HERS to ECC: what changed

08Local reach codes are a separate check

Choosing the statewide edition does not finish the local review. A city’s adopted energy reach code or other applicable local amendment can be stricter than the statewide Energy Code. CBSC Bulletin 25-01 also addresses local amendment procedures. This article does not list or interpret city-specific ordinances, equipment restrictions or exemptions.

Ask the actual reviewing department for the current official ordinance or guidance, its effective date and how it applies to your permit scope. Confirm applicability rather than borrowing an older city checklist, a neighboring jurisdiction’s requirements or an unsourced online summary. Keep the response with the project record so the designer and energy preparer work from the same direction. No statewide article can establish a particular parcel’s local requirements.

09Send a small edition-evidence packet with your plans

Include the application/permit identifier, AHJ-recorded date, current scope and any written edition determination. Add current drawings, prior energy documents marked as reference, correction comments and the status of any separate or phased permits. If a permit expired, state whether a new application is required rather than describing it only as an old project.

For example, a main-house alteration and a separately filed ADU may need separate application histories. Do not automatically transfer the older permit’s edition to the newer application. Ask how the AHJ treats linked scopes and keep that answer visible at intake. Resolve uncertainty before commissioning final modeling; otherwise the team may have to repeat work for a different edition.

What to send your energy consultant Practical plan-intake checklist

10Six practical application-date questions

Use these answers to prepare questions for the AHJ—not to override its determination of your application history.

My permit expired. Does a new application keep the old code?

If expiration requires a new building permit application, assess it under the code in force on the new application date. Do not assume a prior report preserves the old edition indefinitely. Ask the AHJ whether your specific permit can be extended or reinstated, or whether a new application is required; those are different administrative circumstances.

Can I voluntarily opt into the newer Energy Code?

Do not assume you can elect a different edition or mix favorable requirements from both. Ask the AHJ whether review under a newer edition is permitted for your application and how that decision must be documented. Have the preparer explain the effects on the complete model, forms and coordinated plans before changing the package.

Do amended drawings after filing automatically trigger the 2025 code?

Not automatically from the revision date alone. Describe the changes to the AHJ and ask whether they remain within the existing application or require a new application or another edition determination. Keep written direction with the revised package. There is no invented percentage-of-change threshold or universal local revision rule in this guide.

What if my upload receipt and the department’s application date differ?

Ask the AHJ which event establishes the recorded building permit application date and request clarification for the specific application. Retain both records. An upload timestamp, payment, intake appointment or completeness notice should not be treated as a universal statewide substitute for that recorded date.

My 2022 report says HERS. Must I replace it with a 2025 CF1R?

Not simply because 2025 took effect. Confirm the active permit’s edition and current provider requirements. Older-cycle documents may retain HERS labels while the ECC program addresses applicable field verification. A terminology transition alone does not establish that the project must be remodeled under the 2025 Energy Code.

What if I cannot establish the date before requesting a quote?

Identify the uncertainty in the request and send the available permit history. A preliminary scope discussion can identify missing evidence, but final edition-specific production needs the confirmed code basis. Do not choose a year just to complete a form. Ask the AHJ for the recorded date before treating a modeled option as permit-ready.

11Next step: confirm the edition, then scope the report

Once the date and scope are clear, review Title 24 Lab’s existing simple residential/commercial square-footage pricing and exclusions, or request project-specific preparation with your plans. No new rate or turnaround promise is introduced by this guide. Saving an intake request is not payment, production acceptance or a permit guarantee.

This is educational information, not legal advice or a project-specific engineering determination. The AHJ has final say on the recorded application date and applicable local amendments for the permit. Keep its direction with the coordinated document package.

Review published pricing and exclusions Request a quote and upload plans Apply the edition to ADU and garage-conversion scope Apply the edition to a tenant-improvement NRCC package

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